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HomeMy WebLinkAbout13-2082 For Prothonotary Use Only: s.upremeCourt-off' Pennsylvania Cou M F! Pleas oet nd Cola nly Docket No. u ` . OF � The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the Alin and service ofplea!AMs or other papers as required by law or rules of court. Commencement of Action: S. 0 Complaint 13 Writ of Summons ❑ Petition ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name:M&T Bank Lead Defendant's Name:Pamela Hostetler,Administratrix of The Estate of Sean T." Pearlman,Deceased Mortgagor and Real Owner Are there money damages requested? ❑ Yes 0 No Dollar Amount Requested: ❑within arbitration limits 0 (check one) ❑outside arbitration limits N I Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJAppeal? ❑ Yes 0 No I A Name of Plaintiff/Appellant's Attorney:McCabe, Weisberg and Conway,P.C. ❑ Check here if you have no attorney(a Self-Represented [Pro Se[ Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. 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 1 ❑ Department of Transportation ❑ Premises Liability(does not include ❑ Statutory Appeal:Other S mass tort) E ❑Slander/Libel/Defamation ❑Employment Dispute: ❑ Other: Discrimination C ❑Employment Dispute:Other ❑Zoning Board T ❑Other I I 0 0 t er N MASS TORT ❑Asbestos ❑Tobacco 1 11 ❑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 Disput ❑Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑Mortgage Foreclosure:Commercial ❑Quo Warranto ❑Dental ❑Partition ❑Replevin ❑Legal ❑Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: Updated 1/1/2011 0 THE PRO T ONG TAt�"' 1013 APR 17 Ptg 1: /3 CUMBERLAND COUNTY PENNS YLV COUNTY McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D. CONWAY,ESQUIRE-ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank Cumberland County 80 Holtz Drive Cheektowaga,NY 14225 Court of Common Pleas V. p?D0 Number l3— Pamela Hostetler,Administratrix of The Estate of Sean Pearlman, Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,PA 17319 COMPLAINT IN MORTGAGE FORECLOSURE 0:0)t3 { CQ 3a File#67122 Page I NOTICE AVISO You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted quiere against the claims set forth in the following pages, you defendersedeestasdemandasex-puestasenlaspaginas must take action within twenty (20) days after this siguientes, usted tiene veinte (20) dias de plazo al partir complaint and notice are served, by entering a written de ]a fecha de la demanda y la notificacion. Hace falta appearance personally or by attorney and filing in asentar una comparencia escrita o en persona o con un writing with the court your defenses or objections to the abogado y entregar a la corte en forma escrita sus claims set forth against you. You are warned that if you defensas o sus objeciones a las demandas en contra de fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la judgment may be entered against you by the court corte tomara medidas y puede continuar la demanda en without further notice for any money claimed in the contra suya sin previo aviso o notificacion. Ademas, la complaint or for any other claim or relief requested by corte puede decidir a favor del demandante y requiere the plaintiff. You may lose money or property or other que usted cumpla con todas las provisioner de esta rights important to you. demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT USTED LE DEBE TOMAR ESTE PAPEL A HAVE A LAWYER, GO TO OR TELEPHONE THE SUABOGADOINMEDIATAMENTE.SIUSTEDNO OFFICE SET FORTH BELOW. THIS OFFICE CAN TIENE A UN ABOGADO, VA A O TELEFONEA LA PROVIDE YOU WITH INFORMATION ABOUT OFICINA EXPUSO ABAJO. ESTA OFICINA LO HIRING A LAWYER. PUEDE PROPORCIONAR CON INFORMATION IF YOU CANNOT AFFORD TO HIRE A ACERCA DE EMPLEAR A UN ABOGADO. LAWYER, THIS OFFICE MAY BE ABLE TO SI USTED NO PUEDE PROPORCIONAR PROVIDE YOU WITH INFORMATION ABOUT PARA EMPLEAR UN ABOGADO, ESTA OFICINA AGENCIESTHATMAYOFFERLEGALSERVICES PUEDE SER CAPAZ DE PROPORCIONARLO CON TO ELIGIBLE PERSONS AT A REDUCED FEE OR INFORMACION ACERCA DE LAS AGENCIAS NO FEE. QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN Cumberland County Bar Association HONORARIO REDUCIDO NI NINGUN 32 South Bedford Street HONORARIO. Carlisle,PA 17013 (800)990-9108 Cumberland County Bar Association 32 South Bedford Street Carlisle,PA 17013 (800)990-9108 File#67122 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T Bank, duly organized and doing business at the above-captioned address. 2. The Defendant is'Pamela Hostetler,Administratrix ofThe Estate of Sean Pearlman,Deceased Mortgagor and Real Owner of the.mortgaged property hereinafter described,and his/her last-known address is 100 Old Quaker Road,Etters,PA 17319. 3. On May 25, 2007, Sean Pearlman made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems,Inc.,as Nominee for Fulton bank which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1994, Page 1400, such Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa.R. C. P. 4. On October 5,2011,the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems,Inc.,as Nominee for Fulton bank to Bank of America,N.A.,Successor by Merger to BAC Home Loans Servicing,LP f/k/a Countrywide Home Loans Servicing LP,by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Instrument Number 201129159, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C.P. 5. On January 20,2012,the aforesaid mortgage was thereafter assigned by Bank of America, N.A.to M&T Bank,Plaintiff herein,by Assignment of Mortgage,recorded in the Office of the Recorder of Cumberland County in Instrument Number 201209309, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C.P. 6. On August 20, 2012, Sean Pearlman departed this life. Letters of Administration were granted unto Pamela Hostetler,Administratrix of the Estate of Sean Pearlman,Deceased Mortgagor and Real Owner. 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 640-12 Geneva Drive, Upper Allen Township,Mechanicsburg,Pennsylvania 17055. 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due March 1, 2012 and each month thereafter are due and unpaid, and by the terms of said File#67122 Page 3 mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following amounts are due on the mortgage: Principal Balance $ 70,427.50 Interest through April 30, 2013 $ 5,704.43 (Plus$12.54 per diem thereafter) Late Charges $ 312.26 Attorney's Fee $ 1,650.00 Escrow Advance $ 1,385.86 Property Inspection Fees $ 70.00 Prior Foreclosure Fees $ 1,577.50 GRAND TOTAL $ 81,127.55 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated priorto sale,reasonable and actually incurred attorney's fees will be charged in accordance with the reduction. provisions of Act 6, if applicable. 10. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13,et seq.,commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. 11. Plaintiff does not hold the named Defendant personally liable on this cause of action and releases them from any personal liability. This action is being brought to foreclose his/her interest in the aforesaid real estate only. File#67122 Page 4 v WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of$81,127.55, together with interest at the rate of$12.54 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE,WEISBERG AND CONWAY,P.C. BY: [ ]TERkENC McCABE,ESQUIRE [ ] MARC S. ISBERG,ESQUIRE [ ] EDWARD D. CONWAY,ESQUIRE []'MARGARET GAIRO,ESQUIRE [ ] ANDREW L.MARKOWITZ,ESQUIRE [ ] HEIDI R. SPIVAK,ESQUIRE [ ]MARISA J.COHEN,ESQUIRE [ ]KEVIN T.MCQUAIL,ESQUIRE [ ] CHRISTINE L. GRAHAM,ESQUIRE [ ]BRIAN T.LAMANNA,ESQUIRE [ ]JOSEPH F.RIGA,ESQUIRE [ ] JOSEPH I. FOLEY,ESQUIRE [ ] CELINE P. DERKRIKORIAN, ESQUIRE Attorneys for Plaintiff File#67122 Page 5 VERIFICATION O Jeffrey Fisher CU(I`�"+ G04 1,C. y hereby states that he/she of Bayview Loan Servicing, LLC, as attorney in fact for M&T Bank, the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsifications to authorities. /� rey \Fishi1er fiJOC k cmrd ty( Date:�-ra A p2�13 Bayview Gbain Servicing,LLC,as attorney in fact for M&T Bank,the Plaintiff M&T Bank v.Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner File#67122 Page 6 FORM 1. M&T.Bank IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, VENNSYLVANI0 vs. rrnc M- ^^�^ :;0 -Orn Pamela.Hostetler,Administratrix of The:Estate of �W d civil Sean Pearlman, Deceased Mortgagor and.Real Owner Defendant as -0 cs- �n 3 x5 xo �rn NOTICE OF RESIDENTIAL MORTGAGE FORECLO 4 HE-< 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 a lawyer,you must take the following steps to be eligible for a conciliation conference.First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.THIS PROGRAM IS FREE. Respectfully submitted: 4/[03 h A k "" Date [Signatur of Counsel for Plaintiff] 67122 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/PRI MARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 0 No 0 Listing date: Price$ Realtor Name: Realtor Phone: Borrower Occupied? Yes 0 No 0 Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: of people on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 ~ ^ ^ ^ If yes,provide names,location uf court,case number 6tattorney: Assets Value Home: $ Other Real Estate: Retirement Funds: Investments: $ Checking: $ Savings: Other: $ Automobile#I: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles,boats,motorcycles): Model Year: Amount owed: Value: Monthly Income Name of 2 3 Additional Income Description(not wuges): ]. 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 n,Mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuellrepairs Other prop.payment Install.Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses ~ Amount Available for Monthly Mortgage Payments Based on Income 6tExpenses: Have you been working with u Housing Counseling Agency? Yes ONoO lf yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 mm Email: Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes 0 No 0 If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes 0 No 0 If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: VWe, 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. ]/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation(hardship letter) Listing agreement(if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY J Ronny R Anderson C. Sheriff ry ; n. , Jody S Smith 2013 y t 0 pjq Chief Deputy CUMBERLAND Richard Al Stewart f����ya� Solicitor ,r. �'� �� 1A M&T Bank Case Number vs. Pamela Hostetler 2013-2082 SHERIFF'S RETURN OF SERVICE 04/18/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Hostetler, but was the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/25/2013 08:50 AM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure XjEW y the Sheriff of York County I ., personally, at 100 Old Quaker Road, Etter, 19. Richard P. Keuerleber, S entr, Return of Service attached to and made part of the within record. 05/02/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Hostetler, but was the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice o Resident Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 640-12 Geneva Drive, Upper Allen, Mechanicsburg, PA 17055. Deputies were advised by a neighbor that the defendant no longer lives there but rents the property out. 05/03/2013 08:29 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint i Mort age Foreclosure by handing a true copy to a person representing themselves to b who accepted as' P a gra a for Occupant at 640-12 Geneva Dri Upper Allen, Mechanicsburg, PA 17055. SON KINSLER, DEPUTY SHERIFF COST: $75.60 SO ANSWERS, May 06, 2013 RbNO R ANDERSON, SHERIFF irt1^ a '•h� :',OSON, ?.,. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy,Administration M&T BANK Case Number vs. PAMELA HOSTETLER,ADMINISTRATRIX OF THE ESTATE OF SEAN PERLMAN, 13-2082 CIVIL DECEASED MORT(et al.) SHERIFF'S RETURN OF SERVICE 04/25/2013 08:50 AM-DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: PAMELA HOSTETLER AT 100 OLD QUAKER ROAD, ETTER, PA 17319. X. O D STAA L, DEPUTY SHERIFF COST: $38.26 SO ERS, / ,/April 30, 2013 RICHARD P KELMRLEBER, SHERIFF CC MMONWMLTH OF PENNSYLVANIA notarial seai LSh�ella E,Cook,Notary Public JtY Of York,York County mmission Feb,1 2017 EMBEk,PEN'W"WANIA AgSOCUTION OF NOTARIES -- ----- ------------------------------------------------------ NOTARY Affirmed and subscribed to before me this 30TH day of APRIL 2013 ? (c)CountySu(te Sheriff,Teleosoft,Inc. � r McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 W MARISA J.COHEN,ESQUIRE-ID#87830 "G co KEVIN T.MCQUAIL,ESQUIRE-ID#307169 rn ~t7 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 ` BRIAN T.LAMANNA,ESQUIRE-ID#310321 Yom= ANN E. SWARTZ,ESQUIRE-ID#201926 ,, JOSEPH F.RIGA,ESQUIRE-ID#57716 n JOSEPH I.FOLEY,ESQUIRE-ID#314675 s r: CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 p �a 123 South Broad Street,Suite 1400 - cr %o Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Pamela Hostetler,Administratrix of The Estate of Sean Pearlman, Deceased Mortgagor and Real Owner, in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure,and assess damages as follows: Principal $ 8.1,127.55 Interest from 05/01/13 to 05/29/13 $ 363.66 Total $ 81,491.21 McCABE IS ER C10 NWAY,P.C. BY. [ ] Tegorce J.McCab , sq. [ ] Marc S. Weisberg,Esq. [ ]E ward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. 1� [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. ejut 6/6,50 ,C t1 [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. !7� [ Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. (�� tto eys for Plaintiff �" "1 C lvo h ce (Iq �e a AND NOW,this day of U14 ,2013,Judgment is entered in favor ofPlaintiff,M&T BANK, and against Defendant,Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner,in rem only and not in personam,and damages are assessed'.n the amount of$81,491.21,plus interest and costs. BY THE PR HO R r McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Pamela Hostetler, Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner, is not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C. App. §501, et seg.;and that the Defendant,Pamela Hostetler,Administratrix of The Estate of Sean Pearlman, Deceased Mortgagor and Real Owner,is over eighteen(18)years of age,and resides as follows: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,Pennsylvania 17319 Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 McCA SBE DC AY,P.C. SWORN AND SUBSCRIBED B BEFORE ME THIS �O.DAY [ ] ence J.McCabe [ ]Marc S. Weisberg,Esq. [ dward D. Co y,Esq. [ ]Margaret Gairo,Esq. OF 2013 [ ]Andrew L. arkowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. NpSf PE Ns ANIA [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. NOTARIAL SEAL Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Chelsea Anne Nixon-Notary Public A-t-lorneys for Plaintiff City of Philadelphia,Philadelphia County MY COMMISSION EXPIRES JULY 21,2015 Department of Defense Manpower Data Center Results as of:May-29-201307:56:16 SCRA 3.0 Status Report A. } Pursuant to Sery cemembers Civil Relief fact. Last Name: HOSTETLER First Name: PAMELA Middle Name: Active Duty Status As Of: May-29-2013 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 A - ••ti L � I +� �• .may i t Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - , ( Nom F' NA This response reflects where the individual left active duty status within 3,67 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 Dale Status Service Component NA NA .� ,� a -No NA This response reflects whether the individual or his/her unit has received earty 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,NOAH,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 1 ' • Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: F3H2E140X07EA70 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendant are: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,Pennsylvania 17319 Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 McCAB EI a RG CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS DAY [ ]'36Kcnce J.M e,Esq. [ ]Marc S. Weisberg,Esq. [ Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF M 2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T. LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. oseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. 'orneys for Plaintiff rnMMnijwEALTH QE PENNSYLVANIA NDTARIAL SEAL Chelsea Anne Nixon-Notary Public City of Philadelphia,Philadelphia County MY COMMISSION EXPIRES JULY 21,2015 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". McCA ER >G�A�NWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS�DAY [ ] T ence J.Mc abe,Esq. [ ]Marc S.Weisberg,Esq. [ dward D. Conway,Esq. [ ]Margaret Gairo,Esq. OF ,2013 ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUBLIC ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. CnMMnNWFALTH OF PENNSYLVANIA Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. l N O T',�fi i A L SEAL Attorneys for Plaintiff l Chelsea Anne Nixon-Notary Public City of Philadelphia,Philadelphia Courtty MY COMMISSION EXPIRES JULY 21,2015 r VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsification to authorities. MCCABE SB RG WAY,P.C. BY: i /~ [ ] Terre J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. [ ]E and D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. Y ttJoseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. orneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 17013 Curt Long Prothonotary May 16, 2013 To: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,Pennsylvania 17319 and Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 M&T BANK Cumberland County Vs. Court of Common Pleas Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Number 13-2082 Sean Pearlman NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA sUYo. AL NO TOMAR LA AGAINSTYOU WITHOUT A HEARING AND YOUMAY LOSE YOUR PROPERTY ACCION DEBIDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE'.. IF YOU COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO 1'0 OR TELEPHONE THE OFFICE SET FORTH SENTENMA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTFS. HIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORDTO HIRE A LAWYER,THIS OFFICE MAYBE ABLE INMEDIATAMENTE. S1 USTED NO TIF.NF. A IIN ABOGADO, VA A O • TO PROVIDE YOU WITH INFORMATION ABOUTAGENCIES THATMAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO, ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. CiinJborland Cotm�ty 3ar,A . )ciation South 11 d AFd Street Car�sl 'en ;ylvania 17 3 (no)990-9 fs n!tGcA1�E, EISB)�I�.G A ,r.c _ BY: [ ]Terrence J.-McCi -9s'ls [, ] Maf"c S. Weisberg,Esquire [ ]Edward D.Co�I�,Eire ( ]Margaret Gairo,Esquire [ ]Andrew L. Efkowit/,Esquire ]Heidi R.Spivak,Esquire [ }Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L. Graham, Esquire Brian'T.LaManna,Esquire [ ] Ann E.Swartz, Esquire [oq-Joseph F.Riga, Esquire [ ] Joseph I. Foley,Esquire Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,Pennsylvania 17319 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment ? _ Judgment in Replevin /_f Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(215)790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and,Real Owner 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-2082 Civil Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding . as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(2151790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 13-2082 CIVIL Civil Term 3 M&T BANK rn CO V. AMOUNT DUE: $81,491.21 N =' D cn o Pamela Hostetler,Administratrix of The Estate of INTEREST: from 05/30/13 r— Sean Pearlman,Deceased Mortgagor and Real Owner $1,313.20 at$13.40 n = C �3 ATTY'S COMM.: © c C= COSTS: __j � TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s) 640-12 Geneva Drive,Mechanicsburg Pennsylvania 17055 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 1 t3 BY: [ ] Terrence J. cCabe,Esq. [ ] Marc S. Weisberg,Esq. Edward D.Conway,Esq. [<Margaret Gairo,Esq. Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. Q [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [ ]Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. 6 [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. b?• , I t Attorneys for Plaintiff J Print Name: « < _ Firm: MCCABE, WEISBERG AND CONWAY ? �a Address:123 S.Broad Street, Suite 1400 3 v I Philadelphia,PA 19109 Attorney for:Plaintiff C'v Telephone: (215)790 1010 Sb GL Supreme Court ID No. LEGAL DESCRIPTION ALL THAT CERTAIN dwelling unit situated in Sunguild Condominium, Upper Allen Township, Cumberland County, Pennsylvania, designated as Unit No. I080-12, in the Declaration and Mdaration Plan of Sunguild Condominium, dated December 6, 1979 and November 29, 1979 respectively, recorded December 12, 1979 in Cumberland County Misc. Book 249, page 784 and Plan Book 37, page 23 respectively, Amendment to the Declaration and Declaration Plans of Sunguild Condominium both dated February 28, 1986,both recorded March 31, 1986, in Cumberland County Misc. Book 315, page 804 and Plan Book 49, page 129, respectively; and Second Amendment to Declaration of Sunguild Condominium dated May. 25, 1988, recorded June 8, 1988, in Cumberland County Misc. Book .350, page 753 under the provisions of the ').nit Property Act of the Commonwealth otPennsylvania(Act of July 3, 1963,P.L:No. 196). TOGETHER with all right of title and interest of, in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans,as amended from time to time. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successor and assigns,by the acceptance of the deed,covenant and agree to pay such charges for the maintenance of, repairs to,replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Executive Board in accordance with the Unit Property Act of Pennsylvania; and further, covenant and agree that the unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that,except insofar as Sections 705 and 706 of said Unit Property Act and of applicable Sections of the Uniform Condominium Act, may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owner thereof. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successor and assigns, by acceptance of this deed, acknowledge that this conveyance is subject in every respect to the Declaration, the Declaration Plan, Code of Regulations and all amendments thereto; and the grantee further acknowledges that each and every provision of the foregoing is essential to the best interest and for the benefit of all unit owners therein. Grantee and all owners of the units in said condominium covenant and agree, as a covenant running,with the land,to abide by each and every provision of said documents. The Grantee, for and on behalf of the Grantee,acknowledge that the Grantee has received, no lather than fifteen (15) days prior to this conveyance, a full and complete Public Offering Statement for Sunguild Condominium and,therefore,waive any and all rights under Section 3406(c)of the Uniform Condominium Act,as amended. 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055. BEING the same premises which SOVERIGN BANK S/B/M TO YORK FEDERAL SAVINGS AND LOAN ASSOCIATION by deed dated March 30,2007 and recorded June 1,2007 in the office of the Recorder in and for Cumberland County in Deed Book 280,Page 1202,granted and conveyed to Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner,in fee. TAX MAP PARCEL NUMBER: 42-24-0792-041A-U64012 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D. CONWAY,ESQUIRE -'ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 r_ CD ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 c i HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 moo c._ KEVIN T.McQUAIL,ESQUIRE-ID#307169M CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 C)I JOSEPH F.RIGA,ESQUIRE-ID#57716 o i= JOSEPH I.FOLEY,ESQUIRE-ID#314675 — r� 123 South Broad Street,Suite 1400 C•' ' Philadelphia,Pennsylvania 19109 — - (215)790-1010 M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 13-2082 CIVIL Pamela Hostetler,Administratrix of The Estate of Sean Pearlman, Deceased Mortgagor and Real Owner Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. I. Name and address of Owner or Reputed Owner Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 2. Name and address of Defendant in the judgment: Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 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 M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 4. Name and address of the last recorded holder of every mortgage of record: Name Address M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Sunguild Condominiums 1076 Lancaster Boulevard Apartment 1 Mechanicsburg,Pennsylvania 17055-4491 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building ' Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Western District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 171.08-1754 and U.S. Post Office and Courthouse 700 Grant Street, Suite 400 Pittsburgh,PA 15219 United States of America c/o U.S. Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: nor, June 4,2013 [ ] Terrence J Mc abe,Esq. ( ] Marc S.Weisberg,Esq. DATE [ ]Edward D.Conway,Esq. (/f Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. ( ]Brian T.LaManna,Esq. [ ]Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I. Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 1761.6 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 CD MARISA J. COHEN,ESQUIRE-ID#87830 c -� KEVIN T. McQUAIL,ESQUIRE-ID#307169 w CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 MCD C BRIAN T.LaMANNA,ESQUIRE-ID#310321 rn ANN E. SWARTZ,ESQUIRE-ID#201926 Z75r— n C°c-n C) JOSEPH F.RIGA,ESQUIRE-ID#57716 ��— --`c:) CD JOSEPH I.FOLEY,ESQUIRE-ID#314675 7>c-) 123 South Broad Street,Suite 1400 o CD Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW M&T BANK COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Number 13-2082 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner 100 Old Quaker Road Etters,Pennsylvania 17319 Your house(real estate)at 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$81,491.21 obtained by M&T BANK against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to M&T BANK the back payments, late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway,P.C.,Esquire"at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 1701.3 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN dwelling unit situated in Sunguild Condominium, Upper Allen Township, Cumberland County, Pennsylvania, designated as Unit No. 1080-12, in the Declaration and Declaration Plan of Sunguild Condominium, dated December 6, 1979 and November 29, 1979 respectively, recorded December 12, 1979 in Cumberland County Misc. Book 249, page 784 and Plan Book 37, page 23 respectively, Amendment to the Declaration and Declaration Plans of Sunguild Condominium both dated February 28, 1986,both recorded March 31, 1986, in Cumberland County Misc. Book 315, page 804 and Plan Book 49, page 129, respectively; and Second Amendment to Declaration of Sunguild Condominium dated May 25, 1988, recorded June 8, 1988, in Cumberland County Misc. Book 350, page 753 under the provisions of the Unit Property Act of the Commonwealth of Pennsylvania(Act of July 3, 1963,P.L'.No. 196). TOGETHER with all right of title and interest of, in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans,as amended from time to time. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successors and assigns,by the acceptancee of the deed,covenant and agree to pay such charges for the maintenance of,repairs to, replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Executive Board in accordance with the Unit Property Act of Pennsylvania; and further, covenant and agree that the unit conveyed by this deed shall be subject to a charge for-all amounts so assessed and that,except insofar as Sections 705 and 706 of said Unit Property Act and of applicable Sections of the Uniform Condominium Act, may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owner thereof. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successors and assigns, by acceptance of this deed, acknowledge that this conveyance is subject in every respect to the Declaration, the Declaration Plan, Code of Regulations and all amendrments thereto; and the grantee further acknowledges that each and every provision of the foregoing is essential to the best interest and for the benefit of all unit owners therein. Grantee and all owners of the units in said condominium covenant and agree, as a covenant running with the land,to abide by each and every provision of said docurnents. The Grantee-, for and on behalf of the Grantee, acknowledge that the Grantee has received, no lather than fifteen (15) days prior to this conveyancc, a full and complete Public Offering Statement for Sunguild Condominium and,therefore,waive any and all rights under Section 3446(c)of the Uniform Condominium Act,as amended. 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055. BEING the same premises which SOVERIGN BANK S/B/M TO YORK FEDERAL SAVINGS AND LOAN ASSOCIATION by deed dated March 30,2007 and recorded June 1,2007 in the office of the Recorder in and for Cumberland County in Deed Book 280,Page 1202,granted and conveyed to Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner, in fee. TAX MAP PARCEL NUMBER: 42-24-0792-041A-U64012 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2082 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due M&T BANK Plaintiff(s) From PAMELA HOSTETLER,ADMINISTRATRIX OF THE ESTATE OF SEAN PEARLMAN, DECEASED MORTGAGOR AND REAL OWNER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $81,491.21 L.L.:$.50 Interest FROM 5/30/13-$1,313.20 AT$13.40 Atty's Comm: Due Prothy: $2.25 Atty Paid: $224.35 Other Costs: Plaintiff Paid: Date: 6/5/13 David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name:MARGARET GAIRO,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone:215 7790-1010 Supreme Court ID No.34419 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE - ID#34687 MARGARET GAIRO, ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ, ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 ' c KEVIN T. MCQUAIL,ESQUIRE- ID# 307169 -off Z3 CHRISTINE L. GRAHAM, ESQUIRE-ID#309480 M c r-- BRIAN T. LAMANNA,ESQUIRE-ID#310321 tom- ' _ ANN E. SWARTZ,ESQUIRE-ID#201926 r—z: ---qcJ JOSEPH F.RIGA,ESQUIRE-ID# 57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675c� CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-2082 CIVIL Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 25th day of July, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBE CONWAY, BEFO ME THI�DAY BY; [ ]Terrence J.McC e,Esquire [ ] arc S.Weisberg,Esquire OF ,2013 [ ]Edward D.Conway,Esquire [ argaret Gairo,Esquire JTAndrew L.Markowitz,Esquire [ Heidi R. Spivak,Esquire ] J Marisa J. Cohen,Esquire Kevin T.McQuail,Esquire [ ]Christine L. Graham,Esquire ]Brian T.LaManna,Esquire NOTARY PUB [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire LIBN3aiobafa OF P N YLY Joseph I.Foley,Esquire [ ]Celine P.Der Krikorian,Esquire �3 E A L Attorneys for Plaintiff public ePh �ia County a,0RES JAN.12,2414 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID# 307169 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID# 57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-2082 CIVIL Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 2. Name and address of Defendant in the judgment: Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: File#67122 Page 1 Name Address Plaintiff herein M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 4. Name and address of the last recorded holder of every mortgage of record: It Name Address Plaintiff herein M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 5. Name and address of every other person who has any record lien on the property: Name Address None None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Sunguild Condominiums 1076 Lancaster Boulevard Apartment 1 Mechanicsburg,Pennsylvania 17055-4491 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 81h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 File 967122 Page 2 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 .Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service • Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S. Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#67122 Page 3 I verify that the statements made in this.Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. July 25,2013 McCABE,WEISBERG AND CONWAY, DATE BY: [ ] Terrence J.McCabe,Esquire [ ] arc S.Weisberg,Esquire [ ],Edward D. Conway,Esquire [ argaret Gairo,Esquire Andrew L.Markowitz,Esquire [ Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire ( ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re:M&T BANK v.Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner. et al. Cumberland County;Number: 13-2082 CIVIL File 467122 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 , ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Pamela Hostetler,Administratrix of The Estate of Sean Number 13-2082 CIVIL Pearlman,Deceased Mortgagor and Real Owner Defendant DATE:July 25,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner PROPERTY: 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055 IMPROVEMENTS: Condominium JUDGMENT AMOUNT: $81,491.21 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WEARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Check type of mail or service: Y" ~ U.S.POSTAGE>>ATNEY BOWES Name and Address of Sender ❑Certified ❑Recorded Delivery(International) McCabe,Weisberg and Conway,P.C. o COD ❑Registered / �� 113 S.lffr o d St.,S W to 2080 0 Delivery Confirmation O Return Receipt for Merchandise Philadelphia,PA 19109 0 Express Mail 0 signatureCon6rmation _-- ATTN:K.Keller-67122 0Insured _ ZIP 19109 $ 019,200 02 IVY Line Article Numeer �e 0001377494 JUL 25 2013 sc s F« F 1 M&T BANK M&T Bank Plaintiff 80 Holtz Drive Cheektowaga,NY 14225 V. Pamela Hostetler, Administratrix of The Estate of Sean Pearlman, Deceased Mortgagor and Real Owner Defendant 2 Sunguild Condominiums 1076 Lancaster Boulevard Apartment 1 _ Mechanicsburg,Pennsylvania 17055-4491 x ' 3 Tenants/Occupants 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 4 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania Inheritance Tax Office 5 110 North 81h Street Suite#204 Philadelphia,PA 19107 6 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor,Strawberry Square Department#280601 Harrisburg,PA 17128 7 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O.Box 8486 Harrisburg,PA 17105-8486 f 8 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 9 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 10 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg,PA 17128-1230 ATTN: Sheriffs Sales 11 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 12 Domestic Relations Cumberland County P.O.Box 320 Carlisle,PA 17013 13 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 14 Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 15 United States of America c/o Atty General of the United States U.S.Dept.of Justice,Rm 4400 950 Pennsylvania Avenue,NW Washington,DC 20530 a.��>♦d (� 16 United States of America c/o Atty General of the United States U.S.Dept.of Justice,Rm 5111 o N 950 Pennsylvania Avenue,NW Washington,DC 20530 '��� `; �o`y Total Number of Pieces Listed by Sender 16 - r , s McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY, ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID# 307169 r CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 o �{ BRIAN T.LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ, ESQUIRE-ID#201926 r ri JOSEPH F. RIGA,ESQUIRE-ID# 57716 -�D' JOSEPH I.FOLEY, ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN, ESQUIRE-ID#313673 �c`� -o c.. 123 South Broad Street, Suite 1400 r' : C:)r Philadelphia,Pennsylvania 19109 y � 215 790-1010 M&T BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-2082 CIVIL Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 2nd day of August,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBERG AND ONWAY,P.C. BEFORE ME THIS DAY Y: [ ] T rren J.McCabe,Esquire [ arc S. eisberg,Esquire OF 01.3 [ ] dward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire J Marisa J. Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire NOTAR PUBLIC [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire COMQtONWfflALTHCF`lt'K"%I6YLV ]Joseph I.Foley,Esquire [ ]Celi.ne P. DerKrikorian,Esquire NOTARIAL SEA77. orneys for Plaintiff VICTORIA V.SHEGAI,Nok City of Philadelphia,Phily fS ;on �sise^C^try , McCABE, WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 1.7616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID# 87830 KEVIN T. MCQUAIL, ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ, ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID# 5771.6 JOSEPH I.FOLEY,ESQUIRE-ID#314675 . . CELINE P. DERKRIKORIAN,ESQUIRE- ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-2082 CIVIL Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 2. Name and address of Defendant in the judgment: Name Address Pamela Hostetler,Administratrix of 100 Old Quaker Road The Estate of Sean Pearlman, Etters,Pennsylvania 17319 Deceased Mortgagor and Real Owner 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: File 467122 Page 1 Name Address Plaintiff herein M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein M&T Bank 80 Holtz Drive Cheektowaga,NY 14225 5. Name and address of every other person who has any record lien on the property: Name Address None Upper Allen Township 100 Gettysburg Pike Mechanicsburg,PA 17055 Feiner Stephen PO BOX 840 Nauman Smith Shissler&HAII Harrisburg,PA 17108 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Sunguild Condominiums 1.000 North Prince Street Association Lancaster PA 17603 Ellen Goodman 777 Township Line Rd Stark&Stark c/o Sunguild Yardley PA 19607 Condominiums Sunguild Condominiums 1076 Lancaster Boulevard Apartment I Mechanicsburg,Pennsylvania 17055-4491 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 640-12 Geneva Drive Mechanicsburg,Pennsylvania 17055 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard File#67122 Page 2 Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste. 220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S. Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address File#67122 Page 3 None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. August 2,2013 McCABE,WEI BERG AND CONWAY,P.C. DATE BY: [ ] Terrence .McCabe,Esquire [ arc S.Wei erg,Esquire [ ] Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T. LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire [ ]Joseph L Foley,Esquire [ ] Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re: M&T BANK v.Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner. et al. Cumberland County;Number: 13-2082 CIVIL File 1!67122 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -1D#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-1D#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T BANK COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Pamela Hostetler,Administratrix of The Estate of Sean Number 13-2082 CIVIL Pearlman,Deceased Mortgagor and Real Owner Defendant DATE:August 2,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Pamela Hostetler,Administratrix of The Estate of Sean Pearlman,Deceased Mortgagor and Real Owner PROPERTY:640-12 Geneva Drive,Mechanicsburg,Pennsylvania 17055 IMPROVEMENTS: Condominium JUDGMENT AMOUNT:$81,491.21 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. r a• A CD e eD CD 2 CD w b� m @ C 4 m y �cr � OoW� go 5'Ctl $o ��U�a bx• Y � c� mcooCDZ (D a� --a of) r•*4rA ►OZOil C ❑00000 O �� a�-t c (== � �= = = a-<C n o9 fb e0 O Rp y Z C. y'Q y -, A .s a S O y�� a. roso ac A ti c°o g ►-�`o'z'3 a'ti o ro°'.:ego � a � v a E. of DD oo eD •° n o .Z � _ s C i D ov .f O � A 4 IT7 > � Qo N wA W - O 0 W O (mlr SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ( 1 1 1 Chief Deputy i `r t )( , '> Y��pp Richard W Stewart Jt F :: , Lr-. D uL Solicitor OFF FCE OF THE SHERIFF PEN N S _VA N`8 t P. M&T Bank Case Number vs. 2013-2082 Pamela Hostetler Admin. of The Estate of Sean Pearlman SHERIFF'S RETURN OF SERVICE 06/10/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: Pamela Hostetler, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/01/2013 07:28 PM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 640-12 Geneva Drive, Upper Allen -Township, Mechanicsburg, PA 17055, Cumberland County. 07/12/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of York County upon Pamela Hostetler, personally, at 100 Old Quaker Road, Etter, PA 17319. So Answers:Tyler Stepanchick, Deputy, Sheriff. 09/04/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Terrance Mcabe on behalf of Federal Home Loan Mortgage Corp, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,518.49 SO ANSWERS, September 30, 2013 RONR ANDERSON, SHERIFF L/ 9) pee/ ` S �o� ce9. a 997gj {c}CountySuite Sheriff:Teleosoft:Inc. LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2013-2082 Civil Term except insofar as Sections 705 and. 706 of said Unit Property Act and of M&T BANK applicable Sections of the Uniform Condominium Act, may relieve a vs. subsequent unit owner of liability f PAMELA HOSTETLER ADMIN. OF prior unpaid assessments, this cov- THE ESTATE OF SEAN PEARLMAN enant shall run with and bind the Atty.:Terrance McCabe land or unit hereby conveyed and alt ALL THAT CERTAIN dwelling unit subsequent owner thereof. situated in Sunguild Condominium, THE GRANTEE,for and on behalf Upper Allen Township, Cumberland of the Grantee and the Grantee heirs, County,Pennsylvania,designated as personal representatives,successors Unit No. 1080-12,in the Declaration and assigns, by acceptance of this and Declaration Plan of Sunguild deed, acknowledge that this con- Condominium, dated December 6. veyance is subject in every respect 1979 and November 29, 1919 respec- to the Declaration, the Declaration lively, recorded December 12, 1979 Plan, Code of Regulations and all in Cumberland County Misc. Book amendments thereto;and the grantee 249,page 784 and Plan Book 37,page f acknowledges that each and every 23 respectively, Amendment to the provision of the foregoing is essential Declaration and Declaration Plans of to the best interest and for the benefit Sunguild Condominium both dated of all unit owners therein. Grantee February 2; 1986, both recorded and all owners of the units in said March 31, 1986, in Cumberland condominium covenant and agree,as County Misc,Book 315,page 804 and a covenant running with the land,to Plan Book 49,page 129,respectively; abide by each and every provision of and Second Amendment to Declara- said documents, lion of Sunguild Condominium dated The Grantee, for and on behalf May 25,1988,recorded June 8, 1988, of the Grantee, acknowledge that in Cumberland County Misc. Book the Grantee has received, no later 350, page 753 under the provisions Than fifteen (15) days prior to this of the Unit Property Act of the Corn- conveyance,a full and complete Pub- monwealth of Pennsylvania (Act of lie Offering Statement for Sunguild July 3, 1963,P.L: No. 196). Condon and, therefore, waive any TOGETHER with all right of title and all rights under Section 3406(c) and interest of in and to the Coin- of the Uniform Condominium Act, mon Elements as more fully set as amended. forth in the aforesaid Declaration of 640-12 Geneva Drive,Mechanics- Condominium and Declaration Plans, burg,Pennsylvania 17055. as amended from time to time, THE BEING the same premises which GRANTEE, for and on behalf of the SOVERIGN BANK s/b/m TO YORK Grantee and the Grantee's heirs, FEDERAL SAVINGS AND LOAN AS- personal representatives,successors SOCIATION by deed dated March and assigns,by the acceptance of the 30,2007 and recorded June 1,2007 deed,covenant and agree to pay such in the office of the Recorder in and charges for the maintenance of, re- for Cumberland County in Deed pairs to,replacement of and expenses Book 280, Page 1202, granted and in connection with the Common Ele- conveyed to Pamela Hostetler, Ad- ments as may be assessed from time ministratrix of The Estate of Sean to time by the Executive Board in Pearlman, Deceased Mortgagor and accordance with the Unit Property Act Real Owner,in fee. of Pennsylvania and further,covenant TAX MAP PARCEL NUMBER: 42- and agree that the unit conveyed by 24-0792-041A-U64012. this deed shall be subject to a charge for all amounts so assessed and that, 63 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa,Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 9 day of August, 2013 Notary NOi10 JAL S(:AL DFis',`7 tf�N A COLLINS tJotary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 ; The Patriot-News Co.1900 Patriot Drive patriot*xews Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 13-2082 CIA Term This ad ran on the date(s) shown below: M&T BANK , 07/28/13 P ELA HOSTLER ADM . e OF THE ESTATE OF SEAN . 3 08/04/13 PEARLMAN Any: Terrance Mccabe o 08/11/13 - i ALL THAT CERTAIN dwelling unit (P1/7\ - situated in Sunguild Condominium,Upper Allen Township, Cumberland County, Pennsylvania,designated as Unit No.1080- 12,in the Declaration and Declaration Plan Sworn to a; ubscribed be ore - 23 day of August, 2013 A.D. of Sunguild Condominium,dated December 6.1979 and November 29,1919 respectively, f , recorded December 12,1979 in Cumberland \ County Misc.Book 249,page 784 and Plan I \ Book 37,page 23 respectively,Amendment ' • - •U b l is to the Declaration and Declaration Plans of Sunguild Condominium both dated February 2; 1986,both recorded March 31,1986,in Cumberland County Misc,Book 315,page 804 and Plan Book 49,page 129,respectively; and Second Amendment to Declaration L f�h1P�a iv1NEALTFf J P�=J 113.YLVAhlT,4 of Sunguild Condominium dated May 25, PJotarlai S.ea 1988,recorded June 8,1988 in Cumberland lioiiy Lynn Warfel,Notary Put,Eic County Misc.Boo page 3 under the Washington Tw r,Daup"�iri t.ounty: provisions of the Unit Property Act of the tire,s i n Expires Dec 12 '010 Commonwealth of Pennsylvania(Act of July P`�F+ kR t'e!l SYL lA?Vi,4 AV�SeifIA?r�)N 01 i'i/JTARIc"5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Home Loan Mortgage Corp is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 5th day of June, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2082, at the suit of M& T Bank against Pamela Hostetler, Admrx of the Estate of Sean Pearlman is duly recorded as Instrument Number 201333632. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this (77- day of (51t , A.D. c)© a A` -Recorder of Deeds fee^+Cumberland County,Carlisle,PA ';y;rsr�it"aic;i Eaires the Fast Monday of Jan.2014