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HomeMy WebLinkAbout13-1792 Supreme Court of Pennsylvania Cour C m14flea bar I l � F CU County_ Cr rzr y 4o- 3 M The ittfi)rmation collected on this form is used solely, for court administratiott purposes. This f grin does not supplement or replace the ft`lin r and serv of pleadin s or other papers as required by laN or rules o 'court. Commencement of Action: 9 Complaint ❑ Writ of Summons El Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: SUNTRUST MORTGAGE, INC. Lead Defendant's Name: KAREN E. TURNER A/K/A KAREN E. WEEKLEY Dollar Amount Requested: ❑ within arbitration limits Are money damages requested. ❑ Yes [X] No (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes Cl No Is this an MDJ Appeal? ❑ Yes 9 No Name of Plaintiff/Appellant's Attorney: John Michael Kolesnik, Esg. , Id. No.308877 Phelan Hallinan LLP ❑ Check here if you have no attorney (are a Self- Represented 1Pro Sel Litigant) u WJ i C1 Vh Ono TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance _ ❑ Dept. of Transportation ❑ Premises Liability _ ❑ Statutory Appeal: Other ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board ❑ Other: MASS TORT ❑ Other: E,. ❑ Asbestos — ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title El Other: F1 Medical El Other: ❑ Other Professional: — Pa.RC.P. 205.5 Updated 0110112011 M t p D�Ot FlC P RO 3 H ©NO TA , 1013 APR _8 Ah 9: eU ' 21 P6 0SYt,V4 OU NTY PHELAN HALLINAN, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 215 -563 -7000 SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE COURT OF COMMON PLEAS P.O. BOX 27767 RICHMOND, VA 23224 -7767 CIVIL DIVISION Plaintiff TERM V. � � -� ��a C l KAREN E. TURNER AWA KAREN E. WEEKLEY NO. CHARLES E. WEEKLEY, JR CUMBERLAND COUNTY 21 BIG SPRING TERRACE NEWVILLE, PA 17241 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE s File #: 264578 2A W0703 1. Plaintiff is SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE P.O. BOX 27767 RICHMOND, VA 23224 -7767 2. The name(s) and last known address(es) of the Defendant(s) are: KAREN E. TURNER A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY, JR 21 BIG SPRING TERRACE NEWVILLE, PA 17241 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/29/2004 KAREN E. TURNER and CHARLES E. WEEKLEY, JR made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS 1 ST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1864, Page 1241. By Assignment of Mortgage recorded 05/04/2004 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book 707, Page 4681.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File #: 264578 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 04/02/2013: Principal Balance $165,711.86 Interest @ 6.12500% $34,706.43 11/01/2009 through 04/02/2013 $0.00 Late Charges $164.07 Property Inspections $438.82 Property Preservations $3,958.50 AppraisalBPO $0.00 Mortgage Insurance Premium/ $2,760.02 Private Mortgage Insurance $0.00 NSF Charges $0.00 Escrow Deficit $14,649.59 TOTAL $222,389.29 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with File #: 264578 the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $ 222,389.29 , together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: John ichael Kolesnik, Esq., Id. No.308877 A rney for Plaintiff File 4: 264579 • LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, being more fully described as follows: BEGINNING at a point on T -397 at a railroad spike, thence along said roadway North 63 degrees 48 minutes 50 seconds East 400.00 feet to a railroad spike; thence South 26 degrees 11 minutes 10 seconds East 500.00 feet to an iron pin; thence South 63 degrees 48 minutes 50 seconds West 400 feet to an iron pin; thence North 26 degrees 11 minutes 10 seconds West 500.00 feet to a railroad spike, the place of BEGINNING. SAID tract of land being comprised of Lots 20A, 20B and 21 on certain subdivision plans and surveys developed by Carl D. Burk, Registered Surveyor, dated May 16, 1979 and being recorded in Cumberland County Plan Book 37, Page 132. It is the intention of the grantor and grantees that these former separate tracts shall be considered to be one integrated lot for the purpose of the erection of a single family residence. There shall be no further development of any of the tracts separately identified in said surveys or subdivisions and the grantor and grantees agree that the Doctrine of Merger of Estates and Land applies to this conveyance. SUBJECT, NEVERTHELESS, to an easement granted by grantor to The United Telephone Company. Said easement being set forth in a certain survey done by Thomas Michael Englerth for United Telephone Company. Said survey conducted on June 8, 1992. File #: 264578 BEING THE SAME PREMISES Matthew L. Cunningham and Karyn L. Cunningham, husband and wife, by their deed to be simultaneously recorded herewith, granted and conveyed unto Karen E. Turner and Charles E. Weekley, Jr. PROPERTY ADDRESS: 4 SUBDIVISION ROAD, NEWVILLE, PA 17241 -8602 PARCEL # 44 -06- 0035 -002. File #: 264578 VERIFICATION . t�q 5 ( um h'er�by states that he /she is of SUNTRUST MORTGAGE, INC., Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. Name: efi 0 e M t n�5 DATE: Title: C JL - SUNTRUST MORTGAGE, INC. File #: 264578 Name: TURNER File k 264578 SUNTRUST MORTGAGE, INC. IN THE COURT OF COMMON PLEAS Plaintiff(s) OF CUMBERLAND COUNTY, PENNSTLVANIA VS. Cl) C C= KAREN E. TURNER A/K/A KAREN E. WEEKLEY -03 C." --� CHARLES E. WEEKLEY, JR Defendant(s) / 3 - I�9,2 Civi1 = r - NOTICE OF RESIDENTIAL MORTGAGE o-n 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 a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at not charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all the requested 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 attempt to work out a reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Res tfully submitted: A14 Date ?61`re of Counsel for Plaintiff Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Please 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: 0 -- - 0 Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different):_ City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date you Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Y ear: Amount owed: Value: Automobile #2 : Model: Y ear: Amount owed: Value: Other transportation (automobiles boats motorcycles . Model: Tear: 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 Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other ro . a ment Install. Loan Payment Cable TV Child Su rt/Alim. - Spending Money Da /Child Care/Tuit. Other Expenses 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: 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 delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if you know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this page along with the following information to lender: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 264578 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED-OF ICE Sheriff O ME PROTHONOT R', Jody S Smith rk ��ygtit�t,�t 2013(SAY -3 KZ-'06 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Suntrust Mortgage Inc. Case Number vs. Charles Edgar Weekley, Jr(et al.) 2013-1792 SHERIFF'S RETURN OF SERVICE 04/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Charles Edgar Weekley, Jr, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 4 Subdivision Road, Mifflin Twp, Newville, PA 17241. Residence is vacant. 04/30/2013 05:45 PM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves MLINE, wit: Karen E. Turner n/k/a Karen E. Copenhaver at 7 Railroad Avenue, Newville B241. 05/02/2013 07:58 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the D endant, to wit: Charles Edgar Weekley, Jr at 21 Big Spring Terrace, Newville, PA 17241. LLIAM CLIN , DEPUTY SHERIFF COST: $81.12 SO ANSWERS, May 02, 2013 RbNW R ANDERSON, SHERIFF (0 CountySuito Sheriff,Teleosoff,Inc. FILED-OFFiCE OF THE PROTHONOTARY 213 Jig 13 �; 10+ 24 PHELAN HALLINAN, LLP Attorney for Plaintiff Jonathan Lobb, Esq., Id. No.312174COMOERLAND COUNTY 1617 JFK Boulevard, Suite 1400 PENNSYLVANIA One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS KAREN E. TURNER CIVIL DIVISION A/K/A KAREN E. WEEKLEY CHARLES E.WEEKLEY,JR No. 13-1792-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against KAREN E. TURNER A/K/A KAREN E. WEEKLEY and CHARLES E. WEEKLEY,JR,Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $222,389.29 TOTAL $222,389.29 I hereby certify that (1)the Defendants'last known addresses are 7 RAILROAD AVE, NEWVILLE,PA 17241-1513,4 SUBDIVISION ROAD, NEWVILLE, PA 17241-8602, and 21 BIG SPRING TER,NEWVILLE, PA 17241-9129, and (2)that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date t Jo than fJbb, Esq., Id. No.3121.74 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. •' ati DATE: rxs#264578 PROTHONOTARY CL S 16-151111 a 264578 ClL,# /31)')66 2topgIWs �N AU, ()V1(CC PHELAN HALLINAN, LLP Attorney for Plaintiff Jonathan Lobb, Esq., Id. No.3121.74 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE,INC. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS KAREN E. TURNER CIVIL DIVISION A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY,JR No. 13-1792-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) KAREN E. TURNER A/K/A KAREN E. WEEKLEY and CHARLES E. WEEKLEY, JR are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant KAREN E. TURNER A/K/A KAREN E. WEEKLEY is over 18 years of age and resides at 7 RAILROAD AVE, NEWVILLE, PA 17241-1513 and 4 SUBDIVISION ROAD, NEWVILLE, PA 17241-8602. (c) that defendant CHARLES E. WEEKLEY, JR is over 18 years of age and resides at 21 BIG SPRING TER, NEWVILLE,PA 17241-9129 and 4 SUBDIVISION ROAD, NEWVILLE, PA 17241-8602. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to uunsworn falsification to authorities. Date (40 Z _&"�L Ph 6(n Hallinan,LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 264578 Department of Defense Manpower Data Center Results as of:Jun-12-2013 12:30:23 } SCRA 3.0 Sttaniss Report Pursuant to Sm- icemem'f Civil Relief,pct. Last Name: TURNER First Name: KAREN Middle Name: E Active Duty Status As Of: Jun-12-2013 On Active Duly On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duly Start Date Active Duty End Date Stalus Service Component NA NA NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA - No NA This response reflects whether the individual of his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as oft Jun-12.2013 01:07:32 SCRA 3.0 rrrt,'j r}` f staws RCP l� Pursuant tD Servieemem�Civil,Relief Act, 1u 3'k l� Last Name: WEEKLEY First Name: KAREN Middle Name: E Active Duty Status As 4f: Jun-12-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date � v K Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No - - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA NA jNo NA o This response reflects whether the indiJidual or hisfier unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty_ HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL, Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of:Jun-12-2013 12:30:25 SCRA 3.0 Status deport Pursuant to Scriceme mbm Civil l i of Act Last Name: WEEKLEY First Name: CHARLES Middle Name: E Active Duty Status As Of: Jun-12-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date � r t . Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA r _' NA ''.. � :No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date t The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA NA *�.. _ No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. )6� A. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 (Rule of Civil Procedure No. 236) - Revised SUNTRUST MORTGAGE,INC. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS KAREN E. TURNER A/K/A KAREN E. CIVIL DIVISION WEEKLEY , CHARLES E. WEEKLEY,JR No. 13-1792-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on la Bt- If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 264578 SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. KAREN E.TURNER A/K/A KAREN E.WEEKLEY NO. 13-1792-CIVIL CHARLES E.WEEKLEY,JR Defendant(s) CUMBERLAND COUNTY TO: KAREN E.TURNER A/K/A KAREN E.WEEKLEY 7 RAILROAD AVE NEWVILL.E,PA 17241-1513 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE AISLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE; PA 17013 (717)249-3166 By. J icn Lobb,Esq.,Id.No.312174 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#264578 fl 1 SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. KAREN E.TURNER A/K/A KAREN E. WEEKLEY NO. 13-1792-CIVIL CHARLES E.WEEKLEY.JR Defendant(s) CUMBERLAND COUNTY TO: KAREN E.TURNER A/K/A KAREN E. WEEKLEY 4 SUBDIVISION ROAD NEWVILLE,PA 17241-3602 DATE OF NOTICE: f THIS FIRM IS A DEBT COLLECTOR ATTI3MPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 � j 249-3166 By: J athan Lobb,Esq.,Id. No.312174 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1.400 One Penn Center Plaza Philadelphia,PA 19103 PHS#264578 ,I SUNTRUST MORTGAGE,INC. ► COURT OF COMMON PLEAS V. Plaintiff CIVIL DIVISION KAREN E.TURNER A/K/A KAREN E. WEEKLEY NO. 1 3-1792-CIVIL CHARLES E. WEEKLEY,JR Defendant(s) CUMBERLAND COUNTY TO: CHARLES E. WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA.]7241-9129 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEIV1PTIi`IG TO COLLECT A DEBT. T-141S NO`1'IC>- IS SENT TO YOU IN AN ATTEMPT TO COi.,LECT THE INDEBTEDNF.,SS RF1=r121;I 1J 1�j HEREIN, AND ANY INFORMATION OBTAINED I ItGM l.'OU 11�.lLIj 13 USED.NO]2 'TII/�`I` PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN 1.3ANKRt,l1'TCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT .53E CONSTRU D TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENF RC ;PROPERTY. N I OF LIEN AGAINST IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILEL7 TO EN'I. iR A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIIj-'.IN V�1RiTING WfTII T14E COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET Fb`RTH AGAINST YOU: .UNLESS YQU ACT WITHIN TEN DAYS.F.ROM THE DATE OF THIS NOTICE,A JUDGMENT MAY 13E ENTERED AGAINST YOU WITHOUT A HEARING AND YOU.MA Y' LOSE YOUR PROPERTY OR QT.[ IaR IMPORTANT RIGHTS. YOU SHOULD CAKE THIS PAPI*R TO YOUR LAWYFn AT ONCE )F YOU DO NOT HAVE A 1:A.WYIIi ; GO TO OR TELEPHONE THE OFF SE7' T©ItTf1 I3FLOW. THIS OFFICE CAN PROVIDI 1`Ui)GV!!'1°I.1NI OI2MA'.I'l'ON.AI30U7 H.lI2INC A,I�AF R, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse 1 Courthouse Square ASSOCIATION CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 /x(717)249-3166 By: �{✓'' Jon- 1z.a.Lobb,Esq.,Id.No.312174 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 191.03 PHS 4 264578 SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS V. Plaintiff CIVIL DIVISION KAREN E.TURNER AIKIA KAREN E WEEKLFY NO. 13-1792-CIVIL CHARLES E, WEEKL EY.JR. Defendant(s) CUMBERLAND COUNTY TO: CHARLES E.WEEKLEY,JR 4 SUBDIVISION ROAD NEWVILLE,PA 17241-8602 DATE OI+NOTICE: / THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WL] ESS REFERRED TO WI L]IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, LI-BE USED FOR THAT THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE ATTEMPT TO COLLECT A DEBT, BU CONSTRUED TO BE AN PROPERTY. T ONLY AS ENFORCEMENT OF LIEN AGAINST IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT'T'EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED IMPORTANT RIGHTS. AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 WH H INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse 1 Courthouse Square ASSOCIATION Carlisle,PA 17013 CUMBERLAND COUNTY COURTHOUSE (717)240-6195 2 LIBERTY AVENUE CARLISLE,PA 17013 xz— k�7)249-3166 By: .., .I laii Lobb,Esq.,Id.No.312174 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#264578 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 13-1792-CIVIL KAREN E.TURNER A/K/A KAREN E.WEEKLEY CHARLES E.WEEKLEY,JR Defendant(s) CUMBERLAND COUNTY To the Prothonotary: CD Issue writ of execution in the above matter: _4 l Amount Due G $222,389.29 �rr, r" Interest from 06/14/2013 to Date of Sale $6,361.44 ` --k�' ($36.56 per diem) e�d 0 CD1� TOTAL $228,750.73 0orney llinan,LLP Brushwood,Esq.,Id.No.310592 for Pl aintiff Note: Please attach description of property. PH#758411 } g a aDq � � a )C.Wa9 S77�d - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SUNTRUST MORTGAGE,INC. Plaintiff V. KAREN E.TURNER A/K/A KAREN E.WEEKLEY CHARLES E.WEEKLEY,JR Defendant(s) PRAECIPE FOR WRIT OF EXECUTION 7"Ia"oreclosure) � File ? -- Address where papers may be served: Ph an Hal inan, P KAREN E.TURNER A/K/A KAREN E.WEEKLEY M thew Bru ood,Esq.,Id.No.310592 7 RAILROAD AVE Attorney for Plaintiff NEWVILLE,PA 17241-1513 CHARLES E.WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA 17241-9129 LEGAL DESCRIPTION A-L-L—T41-AT-C-ER-'AIN-tr-act of land-situate-in-Upper-Nhf-hn-'ownship;Cumberland-County; Pennsylvania,being more fully described as follows: BEGINNING at a point on T-397 at a railroad spike,thence along said roadway North 63 degrees 48 minutes 50 seconds East 400.00 feet to a railroad spike;thence South 26 degrees 11 minutes 10 seconds East 500.00 feet to an iron pin; thence South 63 degrees 48 minutes 50 seconds West 400 feet to an iron pin;thence North 26 degrees 11 minutes 10 seconds West 500.00 feet to a railroad spike,the place of BEGINNING. SAID tract of land being comprised of Lots 20A, 20B and 21 on certain subdivision plans and surveys developed by Carl D.Burk, Registered Surveyor,dated May 16, 1979 and being recorded in Cumberland County Plan Book 37,Page 132. It is the intention of the grantor and grantees that these former separate tracts shall be considered to be one integrated lot for the purpose of the erection of a single family residence.There shall be no further development of any of the tracts separately identified in said surveys or subdivisions and the grantor and grantees agree that the Doctrine of Merger of Estates and Land applies to this conveyance. SUBJECT,NEVERTHELESS,to an easement granted by grantor to The United Telephone Company. Said easement being set forth in a certain survey done by Thomas Michael Englerth for United Telephone Company.Said survey conducted on June 8, 1992. TITLE TO SAID PREMISES IS VESTED IN Charles E.Weekley,Jr., adult man and Karen E. Turner, adult woman,joint tenants with the right of survivorship,by Deed from Matthew L. Cunningham and Karyn L. Cunningham, h/w, dated 04/29/2004,recorded 05/04/2004 in Book 262, Page 4139. PREMISES BEING: 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 PARCEL NO.44-06-0035-002. PHELAN HALLINAN, LLP s F I L E {.,l t �'I L�_ ` ,H ; ROT¢j O N O TA R' i Attorneys for Plaintiff Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 2013 JUL 31 AM 10: 28 One Penn Center Plaza Philadelphia, PA 19103 CUMBERLAND D COUNTY matthew.brushwood @phelanhallinan.com PENNSYLVANIA 215-563-7000 SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 13-1792-CIVIL KAREN E. TURNER A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY,JR Defendant(s) CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied (X) the premises is vacant ( ) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin,Doc No 11-1197,41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. ' #PnHa an,LLP hwoo d,Esq.,Id.No.310592 laintiff [L 1- SUNTRUST MORTGAGE, INCP flit F 0 0N 0 Wr '- COURT OF COMMON PLEAS Plaintiff -1313 jut, 31 wi 10*' 11 V. CUMIBERLAND COUNT� CIVIL DIVISION P E f4-J S Y LV[\h I A NO.: 13-1792-CIVIL KAREN E.TURNER A/K/A KAREN E.WEEKLEY CHARLES E. WEEKLEY,JR Defendant(s) CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 SUNTRUST MORTGAGE,INC.,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 4 SUBDIVISION ROAD, NEWVILLE,PA 17241-8602. I Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) KAREN E.TURNER A/K/A KAREN E. 7 RAILROAD AVE,NEWVILLE,PA 17241-1513 WEEKLEY CHARLES E.WEEKLEY,JR 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 1 Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) KAREN E.TURNER A/K/A KAREN E. 7 RAILROAD AVE WEEKLEY NEWVILLE,PA 17241-1513 CHARLES E.WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA 17241-9129 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) Bureau of Compliance Department 280946 Harrisburg,PA 17128-0946 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG,PA 17055 MEMBERS 1ST FEDERAL CREDIT UNION 1228 EUCLID AVENUE C/o SUITE 400 CLEVELAND,OH 44115 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be PH#758411 1" reasonably ascertained,please indicate) 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. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 4 SUBDIVISION ROAD NEWVILLE,PA 17241-8602 KAREN E.TURNER C/O MICHELLE L. ABOM&KUTULAKIS,LLP SOMMER,ESQ. 2 WEST HIGH STREET CARLISLE,PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle,PA 17013 Commonwealth of Pennsylvania P.O.Box 2675 Department of Welfare Harrisburg,PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh,PA 15222 U.S.Department of Justice 228 Walnut Street,Suite 220 U.S.Attorney for the Middle District of PA PO Box 11754 Federal Building Harrisburg,PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsificati4rfor Date: ZhLl� By l. an,LLP rushwood,Esq.,Id.No.310592 At Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 PH#758411 p 0-1 H 0 N10 TA R`f SUNTRUST MORTGAGE,INC Jul COURT OF COMMON PLEAS 28 cU�BE,�dSYL`�A�i�A AND TPlaintiff CIVIL DIVISION VS. NO.: 13-1792-CIVIL KAREN E.TURNER A/K/A KAREN E.WEEKLEY CHARLES E. WEEKLEY,JR CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: KAREN E.TURNER A/K/A KAREN E. KAREN E.TURNER A/K/A KAREN E. WEEKLEY WEEKLEY 7 RAILROAD AVE CHARLES E.WEEKLEY,JR NEWVILLE,PA 17241-1513 4 SUBDIVISION ROAD NEWVILLE,PA 17241-8602 CHARLES E.WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA 17241-9129 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real estate)at 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 is scheduled to be sold at the Sheriff's Sale on 12/04/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$222,389.29 obtained by SUNTRUST MORTGAGE,INC.(the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale,you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments,late charges,costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will .have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10)days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800) 990-9108 r � s- SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-1792-CIVIL SUNTRUST MORTGAGE,INC. V. KAREN.E. TURNER A/K/A KAREN E.WEEKLEY CHARLES E.WEEKLEY,JR owner(s) of property situate in the UPPER MIFFLIN TOWNSHIP, CUMBERLAND County, Pennsylvania, being 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 Parcel No.44-06-0035-002. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $222,389.29 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania,being more fully described as follows: BEGINNING at a point on T-397 at a railroad spike,thence along said roadway North 63 degrees 48 minutes 50 seconds East 400.00 feet to a railroad spike;thence South 26 degrees 11 minutes 10 seconds East 500.00 feet to an iron pin;thence South 63 degrees 48 minutes 50 seconds West 400 feet to an iron pin;thence North 26 degrees 11 minutes 10 seconds West 500.00 feet to a railroad spike,the place of BEGINNING. SAID tract of land being comprised of Lots 20A, 20B and 21 on certain subdivision plans and surveys developed by Carl D. Burk,Registered Surveyor, dated May 16, 1979 and being recorded in Cumberland County Plan Book 37,Page 132.It is the intention of the grantor and grantees that these former separate tracts shall be considered to be one integrated lot for the purpose of the erection of a single family residence.There shall be no further development of any of the tracts separately identified in said surveys or subdivisions and the grantor and grantees agree that the Doctrine of Merger of Estates and Land applies to this conveyance. SUBJECT,NEVERTHELESS,to an easement granted by grantor to The United Telephone Company. Said easement being set forth in a certain survey done by Thomas Michael Englerth for United Telephone Company. Said survey conducted on June 8, 1992. TITLE TO SAID PREMISES IS VESTED IN Charles E. Weekley, Jr., adult man and Karen E. Turner, adult woman,joint tenants with the right of survivorship, by Deed from Matthew L. Cunningham and Karyn L. Cunningham, h/w, dated 04/29/2004, recorded 05/04/2004 in Book 262, Page 4139. PREMISES BEING: 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 PARCEL NO. 44-06-0035-002. IA WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1792 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due SUNTRUST MORTGAGE,INC.Plaintiff(s) From KAREN E. TURNER A/K/A KAREN E.WEEKLEY,CHARLES E.WEEKLEY,JR. (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: $222,389.29 L.L.: $.50 Interest FROM 6/14/2013 TO DATE OF SALE($36.56 PER DIEM)-$6,361.44 Atty's Comm: Due Prothy: $2.25 Atty Paid: $229.87 Other Costs: Plaintiff Paid: Date: 7/31/13 David . Buell,.Prothonotary (Seal) By: r Deputy , REQUESTING PARTY: Name: MATTHEW BRUSHWOOD,ESQUIRE Address: PHELAN HALLINAN,LLP 1617 JFK BLVD.,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for:PLAINTIFF Telephone:215-563-7000 Supreme Court ID No.310592 AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY C-- SUNTRUST MORTGAGE,INC. CA) r!�- PH#758411 - 7 rte- �� DEFENDANT SERVICE TEAM/lxh f� -r' KAREN E.TURNER A/K/A KAREN E.WEEKLEY COURT NO.: 13-1792-CIVIL CHARLES E.WEEKLEY,JR L� SERVE KAREN E.TURNER A/K/A KAREN E.WEEKLEY AT: TYPE OF ACTION 7 RAILROAD AVE XX Notice of Sheriff's Sale y j NEWVILLE,PA 17241-1513 SALE DATE: December 4,2013 t* **DIVORCED-One cannot accept service for the other** SERVED Served and made known to KAREN E. TURNER A/K/A KAREN E. WEEKLEY, Defendant on the ( day of J9Deiendant,at o'clock M.,at 3'" AV;VU in the manner described below: Jersonally served. Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age `S Height �i Weight (36 RaceDMI V Sex-F—Other I, APGUU�* f*.) , a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unswom falsification to authorities. DATE: NAME: PRINTED NAME: hJfkWN�- TITLE: q406%1 S- m(A-51Z NOT SERVED On the da of 20_,at o'clock_.M.,1, a competent adult hereby state that�endant N F ND because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 a PHELAN HALLINAN LLP 2 • r �� y � Attorney for Plaintiff SEP 214 A One Penn Center Plaza <:'��� la: 24 1617 K Suite 1400 rE_,tti� SrD �oLNPhi adelP hia, PA 19103 � Hi1 �-�,, justin.kobeski @phelanhallinan.com 215-563-7000 • SUNTRUST MORTGAGE, INC. • CUMBERLAND COUNTY Plaintiff • COURT OF COMMON PLEAS v. • CIVIL DIVISION KAREN E. TURNER NO. 13-1792-CIVIL • A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY, JR Defendants MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan, LLP,petitions this Honorable Court for an Order directing service of the Notice of Sale upon the above-captioned Defendant, CHARLES E. WEEKLEY, JR, by certified mail and regular mail to CHARLES E. WEEKLEY, JR at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 and posting 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 and publication pursuant to PA.R.C.P. 3129.2 (D) and in support thereof avers the following: 1. A Sheriffs Sale of the mortgaged property involved herein has been scheduled for December 4, 2013. 2. Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 3129.2 requires that the Defendant be served with a notification of Sheriffs Sale at least thirty (30) days prior to the scheduled sale date. I 3. Attempts to serve Defendant, CHARLES E. WEEKLEY, JR, with the Notice of Sale at the mortgaged premises, 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". No service made as the property is vacant. 4. Attempts to serve Defendant, CHARLES E. WEEKLEY, JR, with the Notice of Sale at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". No service was made as there was no esponse from the Defendant. 5. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". 6. Plaintiff contacted the Prothontary's Office and as of September 3, 2013, no Judge has previously entered a ruling in this case. 7. In accordance with CUMBERLAND County Local Rule 208.3(9), Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendant on September 13, 2013 and requested Defendant's concurrence. Plaintiff did not receive any written response from the Defendant. A true and correct copy of Plaintiffs September 13, 2013 letter and postmarked certificate of mailing pursuant to Local Rule 208.3(9) attached hereto, made part hereof, and marked Exhibit "C". 8. Plaintiff submits that it has made a good faith effort to locate the Defendant, CHARLES E. WEEKLEY, JR, but has been unable to do so. a WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale upon Defendant in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to CHARLES E. WEEKLEY, JR at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 and posting 4 SUBDIVISION ROAD, NEWVILLE, PA 17241-8602 and by publication. Phelan Hallinan, LLP DATE: a 113 23 By: 4,r Justin FV obes i, Esquire Bar I 1 No: 200392 Atto ey for Plaintiff PHELAN HALLINAN, LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 justin.kobeski@phelanhallinan.com 215-563-7000 • SUNTRUST MORTGAGE, INC. • CUMBERLAND COUNTY Plaintiff • COURT OF COMMON PLEAS • v. • CIVIL DIVISION • KAREN E. TURNER NO. 13-1792-CIVIL • A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY, JR Defendants PLAINTIFF'S MEMORANDUM OF LAW Pursuant to Pennsylvania Rule of Civil Procedure Rule 3129.2, it is necessary in a foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the Sale of the mortgaged premises. Specifically, Pa.R.C.P. Rule 3129.2(c)provides in applicable part as follows: The written notice shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the notice shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402(a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court. Because the whereabouts of Defendant, CHARLES E. WEEKLEY, JR, are unknown, a reasonable investigation of his/her last known address was made in accordance with Pa.R.C.P. 430(a). Pennsylvania Rule of Civil Procedure Rule 430(a)provides as follows: (a) If service cannot be made under the applicable rule the Plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A sheriff's return of"not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa.Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a"good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and(3) examinations of local telephone directories, voter registration records, local tax records and motor vehicle records. As indicated by the of return of service, hereto as Exhibit "A", the process server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked as Exhibit "B". WHEREFORE, Plaintiff respectfully requests the allowance of service of the Notice of Sale upon Defendant in accordance with Pa.R.C.P. Rule 430 by certified and regular mail to CHARLES E. WEEKLEY, JR at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 and posting 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 and by publication pursuant to PA.R.C.P. 3129.2. Phelan Hal Man, Li DATE: ct 1 25113 By: Jus in . obeski, Esq., Id. No.200392 Atto ey for Plaintiff • ' PHELAN HALLINAN,LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 justin.kobeski@phelanhallinan.com 215-563-7000 SUNTRUST MORTGAGE, INC. . • CUMBERLAND COUNTY Plaintiff • COURT OF COMMON PLEAS • • v. CIVIL DIVISION • • KAREN E. TURNER • NO. 13-1792-CIVIL A/K/A KAREN E. WEEKLEY . CHARLES E. WEEKLEY, JR Defendants CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the foregoing Motion for Service of Notice of Sale Pursuant to Special Order of Court, Proposed Order, Memorandum of Law, Certification of Service and Exhibits in the above captioned matter were sent by first class mail, postage prepaid to the following interested parties on the date indicated below. KAREN E. TURNER 7 RAILROAD AVE NEWVILLE, PA 17241-1513 CHARLES E. WEEKLEY, JR 21 BIG SPRING TER NEWVILLE, PA 17241-9129 CHARLES E. WEEKLEY, JR 4 SUBDIVISION ROAD NEWVILLE, PA 17241-8602 Phelan Hallinan, LLP DATE: q)23) 13 By: Justin . Kobeski, Esq., Id. No.200392 Atto ey for Plaintiff • . . . . . • . . .. 4 •• 1. ETHzLJT ... , ' AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY SUNTRUST MORTGAGE,INC. PH#758411 DEFENDANT SERVICE TEAM/Ixh KAREN E.TURNER A/K/A KAREN E.WEEKLEY COURT NO.:13-1792-CIVIL CHARLES E.WEEKLEY,JR SERVE CHARLES E.WEEKLEY,JR AT: TYPE OF ACTION 4 SUBDIVISION ROAD XX Notice of Sheriff's Sale NEWVILLE,PA 17241-8602 SALE DATE: December 4,2013 **DIVORCED-One cannot accept service for the other** SERVED Served and made known to CHARLES E.WEEKLEY,JR,Defendant on the_day of ,20_,at o'clock_.M.,at ,in the manner described below: _Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Height Weight Race Sex Other I. ,a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE:_..__........................__.....__-........._ W...r.. .......__ _.......... Nor SERVED, On the 1f2' day of, ; ,2013 at J" ` o'clock,F M I ret''J,,a competent adult hereby state hat Defendant i I 'reeause: Vacant ',Does Not Exist Moved Does Not Reside(Not Vacant) No Answer on at at !_Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY; !I ^ ' PRINTED NAME: iw'�o!t ..... ,._ ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY , SUNTRUST MORTGAGE,INC. PH#758411 DEFENDANT SERVICE TEAM/lxh KAREN E.TURNER AJK/A KAREN E.WEEKLEY COURT NO.:13-1792-CIVIL CHARLES E.WEEKLEY,JR SERVE CHARLES E.WEEKLEY,JR AT: TYPE OF ACTION 21 BIG SPRING TER XX Notice of Sheriff's Sale NEWVILLE,PA 17241-9129 SALE DATE: December 4,2013 **DIVORCED-One cannot accept service for the other** SERVED Served and made known to CHARLES E.WEEKLEY,JR,Defendant on the day of ,20 ,at ,o'clock .M.,at ,in the manner described below: Defendant personally served. _Adult family member with whom Defendant(s)reside(s), Relationship is . _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Height Weight Race Sex Other ,,,,, I, ,a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S.Sec.4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE: (� l NOT SERVED On the l 1 day of 1`�vST 20(3'',at j0o'elock ,M I, ,kiv U VC EVK competent adult hereby state that Defendant NOT FOUND because: Vacant _Does Not Exist to ed _Does Not Reside(Not Vacant) 'TTo Answer on al �} at 7'-1 Service Refused 12. ` i Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification ioto authorities. BY:-' „- `�Q yC,—"" PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 • Process Server Check List If Service Is Made : Spouses Names if Applicable Wife : Husband:_„„_„ „ Divorced: Yes ( No ( No Service Made 1 . Vacant : Yes ( No ( X ) 2 . Is there a name on the mailbox? Is it the defendants? 3 . Neighbor Contact : Yes ( No ( Left side : Right Side : ts.C-11S"1101----S-Pin PCTelv19111,11- tAALL kr-oUvi9 (1(3/4 4 . For Sale Sign: Yes ( No ( Realtor Name : Company Name : Phone Number: 5 . Car in Drive Way Yes ( No Plate Number: xrt P661.34442--W6N Chi froi, 3 t2-0 -UN& tAic-141' T De 2rr k-tduKe. NvicslAt6)(1-- *ID octet/Q:0.T (..31/4/C-;- Thcze , • • cF � ' C� =fir 99 .kt• AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 758411 Attorney Firm: Phelan Hallinan,L.I..P Subject: Karen E.Turner&Charles E.Weekley Jr. Property Address: 4 Subdivision Road,Newville,PA 17241 Possible Mailing Address: (Karen E.Turner)30 Parsonage Street,Newville,PA 17241 (Karen E.Turner)7 Railroad Avenue,Newville,PA 17241 (Charles E. Weekley Jr.)21 Big Spring Terrace,Newville,PA 17241 I.CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Karen E.Turner-xxx-xx-8709 Charles E.Weekley Jr.-xxx-xx-2244 B. EMPLOYMENT SEARCH Karen E.Turner&Charles E.Weekley Jr.-A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Karen E.Turner reside(s)at:30 Parsonage Street,Newville, PA 1.7241 &Charles E.Weekley Jr.reside(s)at:21 Big Spring Terrace,Newville,PA 17241. II.INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases,which indicated that Karen E.Turner reside(s) at:30 Parsonage Street,Newville,1'A 17241,however had no listing for Charles E.Weekley Jr.On 08-23-13 our office made a telephone call to the subject's phone number(717)776-5985 and received the following information:not in service. B. On 08-23-13 our office made a telephone call to a possible phone number of the subject(s)(717) 776-9282 and received the following information:not in service.On 08-23-13 our office made several telephone calls to a possible phone number of the subject(s)(717)440-4424 and received the following information:answering machine.On 08-23-13 our office made a telephone call to a possible phone number of the subject(s) (717)776-3212 and received the following information: spoke with an unidentified female who could not confirm the whereabouts of the subjects. 111.INQUIRY OF NEIGHBORS On 08-23-13 our office made several phone calls in an attempt to contact Jason L.Carpenter(717) 776-6138,5 Subdivision Road,Newville,PA 17241:no answer. On 08-23-13 our office made a phone call in an attempt to contact Autumn Langley(717)776-5715, 12 Subdivision Road,Newville,PA 17241:not in service. On 08-23-1.3 our office made several phone calls in an attempt to contact Ruth K.Wiser(717)776- 3752,24 Subdivision Road,Newville,PA 17241:no answer. On 08-23-13 our office made several phone calls in an attempt to contact Elaine Fry(717)776-7511, 28 Parsonage Street,Newville,PA 17241:no answer. On 08-23-13 our office made several phone calls in an attempt to contact Tricia M Ries(717)776- 3550,24 Parsonage Street,New ville,PA 17241:answering machine. On 08-23-13 our office made several phone calls in an attempt to contact David F.Rand(717)776- 3509,38 Parsonage Street,Newville,PA 17241:answering machine. On 08-23-13 our office made several phone calls in an attempt to contact Yvonne M.Gates(717) 776-9185,20 Big Spring Terrace,Newville,PA 17241:answering machine. On 08-23-13 our office made several phone calls in an attempt to contact Cecile Y.Eppley(717)776- 4931,27 Big Spring Terrace,Newville,PA 17241:no answer. On 08-23-13 our office made several phone calls in an attempt to contact Beverly A.Kinsey(717) 776-6672,32 Big Spring Terrace,Newville,PA 17241:no answer. On 08-23-13 our office made a phone call in an attempt to contact Michael L.Stauffer(717)776- 4666,5 Railroad Avenue,Newville,PA 17241:not in service. Using our white pages database our office was unable to locate any additional neighbors for 7 Railroad Avenue,Newville,PA 17241. IV.ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 08-23-13 we reviewed the National Address database and found the following information: Karen E.Turner-30 Parsonage Street,Newville,PA 17241 &Charles E.Weekley Jr.-21 Big Spring Terrace,Newville,PA 17241. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors,the following is a possible mailing address:(Karen E.Turner)30 Parsonage Street,Newville,PA 17241 &7 Railroad Avenue,Newville,PA 17241 and(Charles E. Weekley Jr.)21 Big Spring Terrace,Newville,PA 17241. V.OTHER INQUIRIES A. DEATH RECORDS As of 08-23-13 Vital Records and all public databases have no death record on file for Karen E. Turner&Charles E.Weekley Jr.. VI.ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Karen E.Turner-1971 Charles E.Weekley Jr.-1973 B. A.K.A. Karen E. Butts;Karen E.Weekley *Our accessible databases have been checked and cross-referenced for the above named individual(s). *Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. Sec.4904 relating to unsworn falsifica ? n to authorities. The above information is obtained from available public records and we are only liable for the cost of the affidavit. EXHIBIT "C " Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail lily.hainey @,phelanhallinan.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania September 13, 2013 CHARLES E. WEEKLEY, JR 4 SUBDIVISION ROAD NEWVILLE, PA 17241-8602 RE: SUNTRUST MORTGAGE, INC. v. KAREN E. TURNER and CHARLES E. WEEKLEY, JR Premises Address: 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 CUMBERLAND County,No. 13-1792-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by September 20, 2013. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yours, LILY HAINEY,Legal Assistant for Phelan Hallinan,LLP 758411 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail lily.hainey@phelanhallinan.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania September 13, 2013 CHARLES E. WEEKLEY, JR 21 BIG SPRING TER NEWVILLE, PA 17241-9129 RE: SUNTRUST MORTGAGE, INC. v. KAREN E. TURNER and CHARLES E. WEEKLEY, JR Premises Address: 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 CUMBERLAND County,No. 13-1792-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by September 20, 2013. Should you have any further questions or concerns, please do not hesitate to contact me. Othewise, please be guided accordingly. Ver '1ru1 yours,/ LI HAINEY,Legal Assista't ft 'helan Hallinan, LLP 758411 O h III (4.41: Name and Phelan Hainan,LLP} Address 1617 JFK Boulevard,Suite 1400 Of Sender ne Penn Canter Plaza F.,- Philadelphia,PA 19103 LXII i �' Line Article Number Name of Addresses,Street,and Post Otliee Address Postage (II ° m 1 **** CHARLES E.WEEKLEY,JR 50.45 '`—s 4 SUBDIVISION ROAD m �;i G. NEWVILLE,PA 17241-8602 2 *a** CHARLES E.WEEKLEY,JR . . $0.45 te4 1 21 BIG SPRING TER ,t=; NEWVILLE,PA 17241-9139 vs'/ ,€i **** $0.45 s'%" { a:".Y Vie' RE:KAREN E.TURNER A/K/A KAREN L WEEKLEY(CUMBERLAND)TEAM 4 PH#758411/1021 $1.35 Page 1of1 Teml Member of Taw Number utPiaca Poawaer.Pa llama et The AA dxemmia of valve is required os.0 donate and Nwsaimd re/Awed owl.The maximum indemnity payable I'feca Deed br 9eadm Received at Pot Office Receiving Employee) teethe romrwraior ofeareaoliebledoamals elides Expos Mail doormat Ise imwne is 530.000 pm piece=time w aliens of5300000 pat amemenee.The ma xim oaiodca.by payable asEyxew Mal mer dmdieete 5500. The mammal iadaa{7 mite is SUMO ter meowed mak sew with opened ieewaeee.Sec Poamuc Mao Manus 5900S913 mid 5921trite 'mnofeevonme • ***CONCURRENCE LETTER ****a LXH 1 1 758411 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, INC. CIVIL DIVISION Plaintiff NO. 13-1792-CIVIL , V. rn r KAREN E. TURNER Z:��__' --V � , A/K/A KAREN E. WEEKLEY -C"< ` ' CHARLES E. WEEKLEY, JR `-' -r' r X C) Defendants ORDER AND NOW,this day of �'Ro f' / , 2013, after consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is permitted on Defendant CHARLES E. WEEKLEY, JR by: REGULAR MAIL TO CHARLES E. WEEKLEY, JR at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 Service by / mail is complete upon the date of mailing V CERTIFIED MAIL TO CHARLES E. WEEKLEY, JR at 21 BIG SPRING TER,NEWVILLE, PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE, PA 17241-8602 / Service by mail is complete upon the date of mailing v POSTING 4 SUBDIVISION ROAD,NEWVILLE, PA 17241- 8602 PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). Ls L BY T COURT- J. zf PH# 758411 • ( ,r• r S:''i ii Phelan Hallinan,LLP Attorney For Plaintiff' I3g'if ' i8 $ 9: 5C 1617 JFK Boulevard,Suite 1400 ^,r.;,1 B r R L r ND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE,INC. • Court of Common Pleas Plaintiff • Civil Division vs • • CUMBERLAND County KAREN E. TURNER A/K/A KAREN E. WEEKLEY No. 13-1792-CIVIL CHARLES E.WEEKLEY,JR Defendant PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P.,2352 TO THE PROTHONOTARY: Kindly substitute FANNIE MAE("FEDERAL NATIONAL MORTGAGE ASSOCIATION") as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: FANNIE MAE("FEDERAL NATIONAL MORTGAGE ASSOCIATION")is the current holder of the mortgage by virtue of that certain Assignment of Mortgage, which Assignment was recorded on 10/16/2013 in Instrument No. 201333857 of the Recorder of Deeds Office in and for CUMBERLAND County. Kindly amend the information on the docket accordingly. 1 / Date: 1\114 13 By: Meredith Wooters,Esq.,Id. No.307207 Attorney for Plaintiff PH#758411 041 %, 'q 3 qf acgaW • Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE,INC. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County KAREN E. TURNER A/K/A KAREN E.WEEKLEY No. 13-1792-CIVIL CHARLES E.WEEKLEY,JR Defendant PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION"), located 14523 SW MILLIKAN WAY SUfI'E 200 BEAVERTON, OR 97005 Date: (l )r`4/!3 PHELAN HALLINAN,LLP By: Meredith Wooters,Esq., Id.No.307207 Attorney for Plaintiff PH#758411 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATIION"). Date: (� ' {113 PHELAN HALLINAN,L P By: L :_..�; Meredith Wooters,Esq., Id. No.307207 Attorney for Plaintiff PH#758411 Phelan Hallinan, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE,INC. Court of Common Pleas Plaintiff Civil Division v. CUMBERLAND County KAREN E. TURNER, A/K/A KAREN E. No. 13-1792-CIVIL WEEKLEY CHARLES E.WEEKLEY,JR Defendant PH#758411 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe to mark judgment to FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: KAREN E.TURNER A/K/A KAREN E.WEEKLEY 7 RAILROAD AVE NEWVILLE,PA 17241-1513 CHARLES E.WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA 17241-9129 Date: t j JI 3 PHELAN HALLINAN, L P By: r� Meredith Wooters,Esq.,Id.No.307207 Attorney for Plaintiff ;'E €f R.O NONUJ TAi • PHELAN HALLINAN,LLP 4-Attorney for Plaintiff • Adam H.Davis,Esq.,Id.No.20303 tiN ERLAytiD CCIUNTY 1617 JFK Boulevard,Suite 1400 PENNSYLVANIA a9A. One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA • FANNIE MAE("FEDERAL NATIONAL CUMBERLAND COUNTY MORTGAGE ASSOCIATION") Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION KAREN E.TURNER A/K/A KAREN E.WEEKLEY No.: 13-1792-CIVIL CHARLES E.WEEKLEY,JR Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa.R.C.P. 3129.2(c)on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A". Adam H.Davis,Esq.,Id.No.203034 f ! Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH#758411 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE • COURT OF COMMON PLEAS ASSOCIATION") • Plaintiff CIVIL DIVISION • v. NO.: 13-1792-CIVIL KAREN E. TURNER A/K/A KAREN E. WEEKLEY • CHARLES E.WEEKLEY,JR • CUMBERLAND COUNTY Defendant(s) • AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 • •• • • FANNIE MAE("FEDERAL NATIONAL MORTGAGE ASSOCIATION"),Plaintiff in the above action,by the • undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) KAREN E.TURNER A/K/A KAREN E. 7 RAILROAD AVE,NEWVILLE,PA 17241-1513 WEEKLEY CHARLES E.WEEKLEY,JR 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) KAREN E.TURNER A/K/A KAREN E. 7 RAILROAD AVE WEEKLEY NEWVILLE,PA 17241-1513 CHARLES E.WEEKLEY,JR 21 BIG SPRING TER NEWVILLE,PA 17241-9129 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) BUREAU OF COMPLIANCE DEPARTMENT 280946 HARRISBURG,PA 17128-0946 COMMONWEALTH OF PA BUREAU OF P.O.BOX 281230 COMPLIANCE HARRISBURG,PA 17128-1230 COMMONWEALTH OF PA DEPT.OF P.O.BOX 280948 REVENUE BUREAU OF COMPLIANCE HARRISBURG,PA 17128-0948 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG,PA 17055 PH#758411 ■ MEMBERS 1ST FEDERAL CREDIT UNION 1228 EUCLID AVENUE C/O SUITE 400 CLEVELAND,OH 44115 • • 5. Name and address of every other person who has any record lien on the property: • Name Address(if address cannot be reasonably ascertained,please indicate) • None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be • • • • reasonably ascertained,please indicate) • None. • 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 4 SUBDIVISION ROAD NEWVILLE,PA 17241-8602 KAREN E.TURNER C/O MICHELLE L. ABOM&KUTULAKIS,LLP SOMMER,ESQ. 2 WEST HIGH STREET CARLISLE,PA 17013 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: /7/791(3 By: &`'a401440' /V48( //7 Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 PH#758411 -a w S. a oo Li, oo. a c I 0 * * § tt CD 0 . _ ooct000 cr 0 », x ttlelttici.p .cci F. f i G al}/ .1, �� � � 0 E w. 4 7. pp E vs u 2 i .e as m 0 4 A a 1 E 1 n I .r I lo w22gn et tt$ ,4,r K.g• Vi 0 •flIti a qt a cif o i k 3 Z 111 ry:�I . • i.F 8 qaq Q ,!'��r O uQi�",,.,.. t 6. Je a ns 1" • ,c\ b A''T.dli a�,T.^ { � rl+ +"ice c*- � eOVJES j ` � (.44,4„,e—,„ ,„:"._ „� , t4�• ,f t 2 19103 $ 002.400 ..... 02 1rr i .. '`�,. s ,,,• 0001381 191 N0V 04 2013 A Y Q h Name and Phelan Hallinan,LLP N. Address 1617 JFK Boulevard.Suite 1400 III O Of Sender One Penn Center Plata `� �I w Philadelphia,PA 19103 LXH „ °_' Lino Article Number Name of Addresses,Street,and Post Office Address Postage tI m�; 1 "*"• CHARLES E.WEEKLEY,JR $1.45 • 7F �� • 4 SUBDIVISION ROAD �:3 NOO° NEWVILLE,PA 17241-8602 2 ""•' CHARLES E.WEEKLEY,.1R • $0.45 • 4 -P'4 21 BIG SPRING TER :� .,�,, • NEWVILLE,PA 17241-9129 . 3 • ♦ai+ $0.45 r. ak • *1• •ii.'— r RE:KAREN E-TURNER A/KIA KAREN E.WEEKLEY(CUMBERLAND) TEAM 4 PH t/758411f1021 51.35 Page l of 1. Towl Nurzberof TotalNunba of Peaces Nemirow.Pat(Nita of The full dectartion of alue is required on all donate and a:tcn rtimal c aced roil.The naxi ume iedesoity payable Pieces Lind by Sends Receivedar foes Ofrce Reece.*Empleyeel for the recmwua an ofrwrxjotubledoewte t,seder Loess Mel dameed romortruman incertce u 370,490 ea ptaaesatjaa to a tkali 4(5500.000 tax oeamaou.Tea naairuuat iakala*y payable aa Fspaoa Me'neaat.e,4:x it WOO. TM marvnto,iMmniy payable is S9f JIM per set*+rvt mail,,end with ryiwad iaa!ae. Sr r7nnea•e.M aO Mr.& al R900S913 old S92t fee li sa*naofcowepe._ _ ,.- ***CONCURRENCE LETTER **+**LXH 758411 • PHELAN HALLINAN, LLP Attorney for Plaintiff 2J:3 DEC -2 Ail 9: 1617 JFK Boulevard, Suite 1400 r• One Penn Center Plaza n ,.,t B E R L A N D COUNTY Philadelphia, PA 191034 Y �� ' 215-563-7000 SUNTRUST MORTGAGE, INC. • CUMBERLAND COUNTY Plaintiff • COURT OF COMMON PLEAS vs. • CIVIL DIVISION KAREN E. TURNER • NO. 13-1792-CIVIL A/K/A KAREN E. WEEKLEY • CHARLES E. WEEKLEY, JR Defendants AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P.,404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail,return receipt requested,to CHARLES E. WEEKLEY, JR on OCTOBER 7,2013 in accordance with the Order of Court dated SEPTEBER 26, 2013. The property was posted on OCTOBER 10, 2013. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. 1 Phelan Hallinan, LLP DATE: l By: VA'' Meredith Wooters, Esq., _d. No.307207 Attorney for Plaintiff , ` . a • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SUNTRUST MORTGAGE,INC. .• • . CIVIL DIVISION Plaintiff .• • . NO. 13-1792-CIVIL 2 o -r) v. � z-1-Co) rn KAREN E.TURNER � + A/K/A KAREN E.WEEKLEY I—�c -4a CHARLES E.WEEKLEY,JR son tc d Defendants . so ORDER -.< ' ' -c AND NOW,this .12`4k- day otaJ,ck_ ,2013,after consideration of Plaintiff's Motion for Se - • • • - •- . • H Court,it is hereby: ORDERED that pursuant to Pa.R.C.P.430(a),service of the Notice of Sale is permitted on Defendant CHARLES E.WEEKLEY,JR by: ✓ REGULAR MAIL TO CHARLES E.WEEKLEY,JR at 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 Service by / mail is complete upon the date of mailing v CERTIFIED MAIL TO CHARLES E. WEEKLEY,JR at 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 and 4 UBDIVISION ROAD,NEWVILLE,PA 17241-8602 Service by mail is complete upon the date of mailing POSTING 4 SUBDIVISION ROAD,NEWVILLE,PA 17241- 8602 PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2(D). BY THE COURT: // /s/ J. PH#758411 • aand Puff LAN HALI.MAN&SC EG a °' ess Oats'.1 ap`C der at Siberia/in,suite 1400 , miler Philadelphia,PA 19103 I ins Ankle Namc of Admessee:Swat,and Post UAfos.Ad s Postage * 8 Number .. . . ;� I - 1 •••• CHARLESE:WEEKLEY.. .. ; 21 SIG SPRING TER , NEWVILLE,PA 17241-9129 a�c n 2 4*** CHARLES E WEEKLEY JR+1 . . Nc$ 4 SU8D1V1SItt4AD r NEWVILLE,PA 17241=9802 - Is,"',,3 •4** i1 _ r: {t 4, K 4 w** -r � 5 6 **** 7.. **** y.:a F y ,,..f.t..*,:''. , . Awe tR- ... 10 **a♦ �, i1 .**•S _ 12 ***e 13 14 15 • RE CHARLES E.W'EEKLEY,1R ,^ , PHS#758411 CUMBERLAND nal Nomura Teed NumberefPiroes Postmaster,Per(Name or Receiving ..:4r:,::...:1', ace)Liated by4eadcr Racal:a d at Post lNtia' Employee) /:� µ ' x r• UCERTIFICATE OF.MAILING-NOS ,.f, :., .F3 :i d.;`i. ide#1020 ,,,;>+A. 1101 I 11 7178 2417 6099 0147 0630 SPL/758411 CHARLES E. WEEKLEY, JR 21 BIG SPRING TER NEWVILLE, PA 17241-9129 --fold here(regular) --fold here(6x9) --fold here(regular) UNITED STATES POSTAL SERVICE. Date Produced: 10/21/2013 PHELAN HALLINAN & SCHMIEG: The following is the delivery information for Certified Mail."' item number 7178 2417 6099 0147 0630. Our records indicate that this item was delivered on 10/19/2013 at 11:05 a.m. in NEWVILLE, PA 17241. The scanned image of the recipient information is provided below. Signature of Recipient : CL4L,c-\09 Address of Recipient : Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 146893 er -_ ��.. �.�y.,.-.° �. •' - - wil G-... X a..a _ Kr... A ,_.x. -....::"i.M°.. ...°°_. .. �,. t�.t -:a`° a.__ ry -., `:an,a_ s - r—�+�,.�_�.�_ .a USPS.com®-USPS TrackingTM Page 1 of 2 *English Customer Service USPS Mobile Registerl Sign In IGUSPSCOM* Search USPS.com or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions Customer Service> USPS Tracking TM Have questions?Were here to help. Tracking Number:71782417609901470630 Scheduled Delivery Day:October 9,2013 Product & Tracking Information Available Options Postal Product: Features: Return Receipt Electronic First-Class Mail® Certified Mail Email Updates October 19,2013,11:05 Delivered NEWVILLE,PA 17241 am October 9,2013,11:26 Notice Left NEWVILLE,PA 17241 am October 9,2013,8:23 am Out for Delivery NEWVILLE,PA 17241 October 9,2013,8:13 am Sorting Complete NEVWILLE,PA 17241 October 9,2013,8:09 am Arrival at Unit NEWVILLE,PA 17241 October 9,2013 Depart USPS Sort HARRISBURG,PA 17107 Facility October 8,2013,10:05 Processed through HARRISBURG,PA 17107 pm USPS Sort Facility October 7,2013,11:03 Processed at USPS PHILADELPHIA,PA 19176 pm Origin Sort Facility October 7,2013 Depart USPS Sort PHILADELPHIA,PA 19176 Facility October 7,2013,6:53 pm OAccen rigipted Sort at Facilit LISPy S PHILADELPHIA,PA 19103 October 7,2013 Electronic Shipping Info Received Track Another Package What's your tracking(or receipt)number? Track It LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Privacy Policy> Government Services> About USPS Home> Business Customer Gateway■ Terms of Use, Buy Stamps&Shop■ Newsroom> Postal Inspectors FOIA> Print a Label with Postage> USPS Service Alerts> Inspector General> No FEAR Act EEO Data> Customer Service> Forms&Publications> Postal Explorer> https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901470630 10/24/2013 • 7178 2417 6099 0147 0647 SPL/758411 CHARLES E. WEEKLEY, JR 4 SUBDIVISION ROAD NEWVILLE, PA 17241-8602 --fold here(regular) --fold here(6x9) --fold here(regular) USPS.com® -USPS TrackingTM Page 1 of 2 •English Customer Service USPS Mobile Register!Sign In • arUSPS.COM Search USPS.corn or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions 12 Customer Service USPS Tracking TM Have qesti ns?We'reheretohelp. Tracking Number:71782417609901470647 Scheduled Delivery Day:October 9,2013 Product & Tracking Information Available Options Postal Product: Features: Return Receipt Electronic First-Class Mail® Certified Mail Email Updates October 17,2013,8:00 Delivered PHILADELPHIA,PA 19103 am October 16,2013,11:30 Available for Pickup PHILADELPHIA,PA 19103 am October 16,2013,12:24 Processed through PHILADELPHIA,PA 19176 am USPS Sort Facility October 15,2013,12:42 Processed through PHILADELPHIA,PA 19176 pm USPS Sort Facility October 14,2013,11:22 Processed through LANCASTER,PA 17604 am USPS Sort Facility October 12,2013 Depart USPS Sort LANCASTER,PA 17604 Facility October 11,2013,5:17 Processed through LANCASTER,PA 17604 pm USPS Sort Facility October 9,2013,8:40 am Addres Moved,s Left no W NEVILLE,PA 17241 October 9,2013,8:23 am Out for Delivery NEWVILLE,PA 17241 October 9,2013,8:13 am Sorting Complete NEWVILLE,PA 17241 October 9,2013,8:09 am Arrival at Unit NEVVVILLE,PA 17241 October 9,2013 Depart USPS Sort HARRISBURG,PA 17107 Facility October 8,2013,11:18 Processed through pm USPS Sort Facility HARRISBURG,PA 17107 October 7,2013 Depart USPS Sort PHILADELPHIA,PA 19176 Facility October 7,2013,8:08 pm Processed at USPS PHILADELPHIA,PA 19176 Origin Sort Facility October 7,2013,6:53 pm Accepted Sort at Facili USPty S PHILADELPHIA,PA 19103 O October 7,2013 Electronic Shipping Info Received https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901470647 10/24/2013 • • AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY SUNTRUST MORTGAGE,INC. PH#758411 DEFENDANT SERVICE TEAM/sol KAREN E.TURNER A/K/A KAREN E.WEEKLEY COURT NO.:13-1792-CIVIL CHARLES E.WEEKLEY,JR SERVE CHARLES E.WEEKLEY,JR AT: TYPE OF ACTION 4 SUBDIVISION ROAD XX Notice of Sheriff's Sale NEWVILLE,PA 17241-8602 SALE DATE:12/04/2013 ****PLEASE POST THE PROPERTY*** SERVED Served an made known to CHART., S F. ,_ RC Defendant on the b day of OCIZ 'r- ,20 13,at CiVelock, M.,at 4$UpI IVIClON ROAD,NEWV1LLE PA 17241-8602,in the manner described below: Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. XX.Other: POSTED THE PROPERTY Description: Age Height Weight Race Sex Other I, t '° IP ,a competent adult,hereby verify that I personally posted the property with a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec.4904 relating to unworn falsification to authorities. DATE: f t) ' NAME: p�� PRINTED NAME: i " "�-' "" TITLE: 1 - NOT SERVED On the day of ,20 ,at o'clock_ M.,I, ,a competent adult hereby state that Defendant NOT'OUND because: Vacant Does Not Exist r Moved _Does Not Reside(Not Vacant) No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallman,Esq.,Id.No.62695 Daniel G.Schmieg,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenne R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L Spivack,Esq.,Id.No.84439 Chrisovalante P.Pliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Allison F.Zuckerman,Esq.,Id.No.309519 Melissa I,Cantwell,Esq.,Id.No.308912 Mario I.Hanyon,Esq.,Id.No.203993 John M.Kolesmkc,Esq.,Id.No.308877 ;_ THE PROTHONOTARY PHELAN HALLINAN, LLP DEC ` � O. Attorney for Plaintiff OS 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 FANNIE MAE ("FEDERAL NATIONAL • MORTGAGE ASSOCIATION") • CUMBERLAND COUNTY COURT OF COMMON PLEAS • Plaintiff • CIVIL DIVISION • vs. • NO. 13-1792-CIVIL KAREN E. TURNER A/K/A KAREN E. WEEKLEY CHARLES E. WEEKLEY, JR Defendants AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail,return receipt requested,to CHARLES E. WEEKLEY, JR on OCTOBER 7,2013 in accordance with the Order of Court dated SEPTEMBER 26,2013. The property was posted on OCTOBER 10, 2013. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. Phelan Hallinan, LLP DATE: I a 4 13 By: l AAJVV / Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SUNTRUST MORTGAGE,INC. CIVIL DIVISION Plaintiff c? • NO. 13-1792-CIt V. �co Grp Tj -v .7%71 r . KAREN E.TURNER • - 2" a cJ A/K/A KAREN E.WEEKLEY E.WEEKLEY,JR o ==' Defendants �� ORDER r AND NOW,this '' day oS F_rr�`j 2013,after consideration of Plaintiff's Motion for S •% % I • 1.1 . •_ Los ., . Court,it is hereby: ORDERED that pursuant to Pa.R.C.P.430(a),service of the Notice of Sale is permitted on Defendant CHARLES E.WEEKLEY,JR by: ✓ REGULAR MAIL TO CHARLES E.WEEKLEY,JR at 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 Service by mail is complete upon the date of mailing ✓ CERTIFIED MAIL TO CHARLES E.WEEKLEY,JR at 21 BIG SPRING TER,NEWVILLE,PA 17241-9129 and 4 SUBDIVISION ROAD,NEWVILLE,PA 17241-8602 Service by mail is complete upon the date of mailing POSTING 4 SUBDIVISION ROAD,NEWVILLE,PA 17241- 8602 PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2(D). BY THE COURT: g ) J. PH#758411 0 4. cI co 2 n roa o. 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WEEKLEY, JR 4 SUBDIVISION ROAD NEWVILLE, PA 17241-8602 --fold here(regular) --fold here(6x9) --fold here(regular) USPS.com® - USPS TrackingTM Page 1 of 2 English Customer Service USPS Mobile Register I Sign In UP CC) Search USPS.com or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions US�+ P�+ �+ TM Customer Service> PS Tracking Have questions?Wereh ere tohelp. Tracking Number:71782417609901470647 Scheduled Delivery Day:October 9,2013 Product & Tracking Information Available Options Postal Product: Features: Return Receipt Electronic First-Class Mail° Certified Mail October 17,2013,8:00 Delivered PHILADELPHIA,PA 19103 am October 16,2013,11:30 Available for Pickup PHILADELPHIA,PA 19103 am October 16,2013,12:24 Processed through PHILADELPHIA,PA 19176 am USPS Sort Facility October 15,2013,12:42 Processed through PHILADELPHIA,PA 19176 pm USPS Sort Facility October 14,2013,11:22 Processed through LANCASTER,PA 17604 am USPS Sort Facility October 12,2013 Depart USPS Sort LANCASTER,PA 17604 Facility October 11,2013,5:17 Processed through LANCASTER,PA 17604 pm USPS Sort Facility October 9,2013,8:40 am Moved,Left no NEVWILLE,PA 17241 Address October 9,2013,8:23 am Out for Delivery NEVWILLE,PA 17241 October 9,2013,8:13 am Sorting Complete NEVWILLE,PA 17241 October 9,2013,8:09 am Arrival at Unit NEWVILLE,PA 17241 October 9,2013 Depart USPS Sort HARRISBURG,PA 17107 Facility October 8,2013,11:18 Processed through HARRISBURG,PA 17107 pm USPS Sort Facility October 7,2013 Depart USPS Sort PHILADELPHIA,PA 19176 Facility October 7,2013,8:08 pm Processed at USPS PHILADELPHIA,PA 19176 Origin Sort Facility October 7,2013,6:53 pm Accepted at USPS PHILADELPHIA,PA 19103 Origin Sort Facility October 7,2013 Electronic Shipping Info Received https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901470647 11/14/2013 • UNITED STATES �POSTAL SERVICE Date Produced: 10/21/2013 PHELAN HALLINAN & SCHMIEG: The following is the delivery information for Certified MailTM item number 7178 2417 6099 0147 0630. Our records indicate that this item was delivered on 10/19/2013 at 11:05 a.m. in NEWVILLE, PA 17241. The scanned image of the recipient information is provided below. Signature of Recipient •. cS)d CLGL_c\O- - Address of Recipient : Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representative. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 146893 • 7178 2417 6099 0147 0630 SPL/758411/1020 CHARLES E. WEEKLEY, JR 21 BIG SPRING TER NEWVILLE, PA 17241-9129 --fold here(regular) --fold here(6x9) --fold here(regular) USPS.com® - USPS TrackingTM Page 1 of 2 • • English Customer Service USPS Mobile Register I Sign In ✓sp> . Search USPS.com or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions TM Customer Service> USPS Tracking Have questions?Were here to help. Tracking Number:71782417609901470630 Scheduled Delivery Day:October 9,2013 Product & Tracking Information Available Options Postal Product: Features: Return Receipt Electronic First-Class Mail® Certified Mailry October 19,2013,11:05 Delivered NEWVILLE,PA 17241 am October 9,2013,11:26 Notice Left NEWVILLE,PA 17241 am October 9,2013,8:23 am Out for Delivery NEWVILLE,PA 17241 October 9,2013,8:13 am Sorting Complete NEWVILLE,PA 17241 October 9,2013,8:09 am Arrival at Unit NEWVILLE,PA 17241 October 9,2013 Depart USPS Sort HARRISBURG,PA 17107 Facility October 8,2013,10:05 Processed through HARRISBURG,PA 17107 pm USPS Sort Facility October 7,2013,11:03 Processed at USPS PHILADELPHIA,PA 19176 pm Origin Sort Facility October 7,2013 Depart USPS Sort PHILADELPHIA,PA 19176 Facility October 7,2013,6:53 pm Accepted at USPS PHILADELPHIA,PA 19103 Origin Sort Facility October 7,2013 Electronic Shipping Info Received Track Another Package What's your tracking(or receipt)number? Track It LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Privacy Policy Government Services> About USPS Home> Business Customer Gateway, Terms of Use, Buy Stamps&Shop; Newsroom r Postal Inspectors FOIA> Print a Label with Postage r USPS Service Alerts> Inspector General> No FEAR Act EEO Data: Customer Service r Forms&Publications, Postal Explorer r https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901470630 11/14/2013 • AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF - CUMBERLAND COUNTY SUNTRUST MORTGAGE,INC. PH#758411 DEFENDANT SERVICE TEAM/sal KAREN E.TURNER A/K/A KAREN E.WEEKLEY COURT NO.:13-1792-CIVIL CHARLES E.WEEKLEY,JR SERVE CHARLES E.WEEKLEY,JR AT: TYPE OF ACTION 4 SUBDIVISION ROAD XX Notice of Sheriff's Sale NEWVILLE,PA 17241-8602 SALE DATE:12/04/2013 ****PLEASE POST THE PROPERTY*** SERVED Served an made known to CHARLES E.WEEKLEY,JR,Defendant on the )0 day of � 20 13,at Opriclock M.,at 4 SUBDIVISION ROAD,NEWVILLE.PA 17241-8602,in the manner described below: _Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. —Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. XX Other: POSTED THE PROPERTY Description: Age Height Weight Race Sex Other I, C/t ,a competent adult,hereby verify that I personally posted the property with a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. V�G DATE:�� 2[X� NAME: -'-' tJ PRINTED NAME: t " " ' ier-i\J TITLE:`K S"e - NOT SERVED On the day of 20 ,at o'clock_.M.,I, ,a competent adult hereby state that Defendant NOT FOUND because: —Vacant _Does Not Exist Moved _Does Not Reside(Not Vacant) _No Answer on at ; at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallinan,Esq.,Id.No.62695 Daniel G.Schmieg,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Allison F.Zuckerman,Esq.,Id.No.309519 Melissa J.Cantwell,Esq.,Id.No.308912 Mario J.Hanyon,Esq.,Id.No.203993 John M.Kolesnik,Esq.,Id.No.308877