HomeMy WebLinkAbout13-2111 Supreme Court#of Pennsylvania
Court,`4-,4 mo-n"Tleas For Prothonotary Use Only: /J
i.
CWWCover
)SMeet Docket No: J .
CUMBERLAND County
The information collected on this form is used solely for court administration purposes. This fibrin does not
supplement or replace the filing and service ofpleadings or otherpapers as reguil•ed by law or rules of court.
Commencement of Action:
S Complaint 0 Writ of Summons F1 Petition
Q Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
PNC Bank, National Association Paul Blackburn a/k/a Paul G. Blackburn; et al
T Dollar Amount Requested: 0 within arbitration limits
I Are money damages requested? 0 Yes No (check one) Qoutside arbitration limits
O
N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? Yes El No
A Name of Plaintiff/Appellant's Attorney:
0 Check here if you have no attorney(are a Self-Represented Ulm 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
Q Intentional Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution Debt Collection:Credit Card Board of Assessment
Motor Vehicle [-, Debt Collection: Other —+ Board of Elections
Nuisance Dept.of Transportation
0 Premises Liability Statutory Appeal:Other
S Product Liability(does not include
mass tort) Q Employment Dispute:
E Q Slander/Libel/Defamation Discrimination
C Other: EJ Employment Dispute:Other ❑ Zoning Board
Other:
T
E] Other:
O MASS TORT
El Asbestos
N [:] Tobacco
E] Toxic Tort-DES
E] Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste El Ejectment M Common Law/Statutory Arbitration
0 Other: 0 Eminent Domain/Condemnation 0 Declaratory Judgment
B 0 Ground Rent [3 Mandamus
E] Landlord/Tenant Dispute E:]Non-Domestic Relations
[E Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 13 Quo Warranto
Q Dental ❑ Partition ED Replevin
rl Legal E] Quiet Title El Other:
Medical f-1 Other:
Other Professional:
Updated 1/1/2011
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN,ESQUIRE-ID#04302
STUART WINNEG,ESQUIRE -ID#45362
LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 C:)
SHERRI J.BRAUNSTEIN,ESQUIRE -ID#90675
SALVATORE CAROLLO,ESQUIRE- ID#311050
M c .
HARRY B.REESE,ESQUIRE -113#310501
ELIZABETH L.WASSALL,ESQUIRE -ID#77788
'-0 C)
KATHERINE E.KNOWLTON,ESQUIRE -ID#311713
JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 7>
NICOLE B.LABLETTA,ESQUIRE—H)#202194 a5
C= 'I
DAVID NEEREN,ESQUIRE-ID#204252
JORDAN DAVID,ESQUIRE-ID#311968
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400 2leadinas@udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
C/O PNC Bank,N.A. CIVIL DIVISION
3232 Newmark Drive CUMBERLAND County
Miamisburg,OH 45342
)W
Plaintiff NO. 13— C-
V.
PAUL BLACKBURN AIK/A PAUL G.
BLACKBURN
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
TARA BLACKBURN A/K/A TARA A.
BLACKBURN
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
LI)l9p6d
99
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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y
entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor
del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800) 990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the
creditor to whom the debt is owed is as named in the attached document. Unless you notify
us within 30 days after receipt of this Notice and the attached document that the validity of
the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If
you do notify us in writing of a dispute within the 30 day period, we will obtain verification
of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute
the debt, it is not an admission of liability on your part. Also, upon your written request
within the 30 day period, we will provide you with the name and address of the original
creditor if different from the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease
collection of your debt, or any disputed portion of it, until we obtain the information that
is required and mail it to you. Once we have mailed to you the required information, we
will then continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document
is an attempt to collect a debt,and any information obtained will be used for that purpose.
UDREN LAW OFFICES,P.C.
/s/Mark J.Udren,Esquire
Woodcrest Corporate Center
111 Woodcrest Road,Suite 200
Cherry Hill,NJ 08003-3620
(856) 669-5400
1. Plaintiff is PNC Bank, National Association . Plaintiff is the legal holder of the
Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of
record, is the legal holder of the Mortgage by virtue of being successor in interest to
the current mortgagee of record, or is the legal holder of the Mortgage by virtue of
Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of
Assignment of Mortgage, it is by the following Assignments of Mortgage, all of
which have either been recorded or Plaintiff is in the process of formalizing the actual
Assignment of Mortgage in Plaintiff s favor:
Assignor: N/A
Assignee: N/A
Date of Assignment:N/A
Recorded Date: N/A
Book/Instrument#:N/A
Page: N/A
2. Upon information and belief Defendant(s)and/or their predecessor:
Paul Blackburn a/k/a Paul G.Blackburn and Tara Blackburn a/k/a Tara A.
Blackburn
(hereinafter"Defendants"),are the owners of property located at 823 Anthony Drive,
(Hampden Township),Mechanicsburg,PA 17050,by virtue of Deed dated
02/14/2008 and recorded 02/21/2008 in Official Records Book Instrument#
200805073 at Page n/a of the Public Records of Cumberland County, Pennsylvania
(hereinafter the 'Property").
3. On 02/14/2008 ,Defendant(s) and/or their predecessor:
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN AND TARA
BLACKBURN A/K/A TARA A.BLACKBURN
promised to pay to the order of National City Mortgage a Division of National
City Bank,the principal sum of $279,110.00 payable with interest thereon
provided in the Note.
4. By Mortgage dated 02/14/2008 ,Defendant(s) and/or their predecessor:
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN AND TARA
BLACKBURN A/K/A TARA A.BLACKBURN
to secure the Note, mortgaged to National City Mortgage a Division of National
City Bank, the Property which is the subject of this action. The Mortgage was
recorded on 02/21/2008 in Official Records Book Instrument#200805074 at Page
n/a. Said Mortgage is incorporated herein by referenced in accordance with
Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto
and made a part hereof.
5. Said mortgage is in default in that the payment due 03/01/2012, and all subsequent
payments have not been made, and by its terms,upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage,together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand,the Defendant(s)continues to fail or refused to comply with the terms of
the Mortgage as follows:
(a) By failing or refusing to pay the installments of principal and interest when due in
the amounts indicated below;
(b) By failing or refusing to pay other charges,if any,indicated below.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $263,066.07
Accumulated Interest $16,997.15
Accumulated Late Charges $495.30
Escrow Deficit/(Reserve) $4,782.92
Grand Total $285,341.44
The above figures are calculated to 03/07/2013:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 5.87500 %. The per diem interest accruing
on this debt is $42.3400 and that sum should be added to the above date and each day after the
above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at$82.55.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of
the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of
Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached
hereto as Exhibit"A"
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of$285,341.44 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDREN LAW_PFFICES, P.C.
BY. Mark-T. Udren, Esquire
PA ID 04302
VERIFICATION
I, DON F.PenrftWn , as an Authorized Signer of the Plaintiff, PNC
Bank, National Association , do hereby verify that I am authorized to and do make this
verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are
true and correct to the best of my information and belief. I understand that false statements
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: 3-al- ,20 13 �' .J
Name: DOn to F.Psnnington
Title: Authorized Signer
Company: PNC Bank,National Association
MJU#: 12041104 CASE#: 12041104-12
02-28-'13 09;45 FROM-ABLE ABSTRACTS T-753 P0013/0017 F-440
EXMMIT ",A,"
ALL THAT CERTAIN tract or parcel of land with the improvements thereon erected situate,lying and being in
the Township of Hampden, in -the County of Cumberland and Commonwealth of Pennsylvanla, more
particularly described as follows,to wit.
BEGINNING at a point on the Southwestern side of Anthony Drive(formerly Margaret Road) at the dividing
line between Lots 42 and 43 of the hereinafter mentioned Plan;thence by said dividing line,South fifty-nine(59)
degrees three(03) minutes forty-seven (47) seconds West, one hundred nicety-six and twenty-eight hundredths
(196.28)feet to a point at the dividing line between Lot 42 and Lot 53 of the Plan;thence by said dividing line and
the line of Lot 54, North twenty-eight (28) degrees twenty-six(26) minutes twenty-four (24) seconds'West,one
hundred fifty-one and twenty-seven hundredths(151.27) feet to a point an the southern side of Anthony Drive;
thence by the southern side of Anthony Drive by an.are curving to the right, having a radius of one hundred
forty(140)feet an are distance of sixty-seven and seventeen hundredths(67.17)feet to a point;thence continuing
along the southern side of Anthony Drive,North eighty-nine(89)degrees three(03)minutes six(06)seconds East,
sixty-one and seven tenths(61.7)feet to a point; thence continuing along the southern side of Anthony Drive by
an arc curving to the right,having a radius of oce hundred fifty(150)feet an are distance of one hundred twenty-
eight and seventy-one hundredths(128,71)feet to a point at the dividing line between Lots 42 and 43,the place of
BEGINNING. BEING ALL OF Lot No. 42 on Final Plan No. 2, Section Il,Deimler Manor, recorded in Plan
Book 33,Page 10,Cumberland County records.
BEING THE SAME premises which Susan D.Dupree by Deed bearing date the 14th day of February,2008 and
about to be herewith recorded in the Office of the Recorder of Deeds In and for the County of Cumberland,
Pennsylvania,granted and conveyed unto Paul G.)Blackburn and Tara A-Blackburn,husband and wife.
UNDER AND SUBJECT TO conditions and restrictions which now appear of record.
PARCEL#10-17-1037-042
,�.:, 7196 91308 9111 8967 0802
� • *
. � �1 � Attention= Collection Department � . �
MORTGAGE" (B6—Y'M01-01-5)
3232 Newmark Drive
Miamisburg, OH 45342
TARA BIACKBURJ
823 ANTHONY DR
RECHANICSBURG, PA 17050
Please find enclosed the ACT 91 NOTICE
for Loan Number: 0005829623
This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you
have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if
the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National
Association will only exercise its rights against the property itself, and is not attempting to collect the
discharged debt from you personally.
Exhibit A
DR673
—...nom,..�n•nnn T7 OnI,O"7 GC,C
Date: 1!17/2013
ACT 91 NOTICE
TAKE ACTION TO SANE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached ages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM LREMAP)
may be able to help to save your home. This Notice explains how the program works.
To see if HE" can help,you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. {Persons with unpaired
hearing can call(717)780-1869).
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area.The local bar association may be able to help you find a lawyer.
LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDE1'IIR SU HIPOTECA.
HOMEOWNER'S NAME(S): PAUL BLACKBURN
TARA BLACKBURN
PROPERTY ADDRESS: 823 ANTHONY DR
MECHANICSBURG,PA 17050
LOAN ACCT.NO.: 0005829623
ORIGINAL LENDER: N/A
CURRENT LENDER/SERVICER:PNC Mortgage
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY 11E ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• W YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30)days from the date of this Notice (plus three (3)days for mailing). During that time you
must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33)-DAYS OF THE DATE OF THIS
NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT",EXPL.UNS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES—If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names,addresses and telephone numbers of designated consumer credit counseling agencies for the county
in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting.Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth Iater in this
Notice (see following pages for specific information about the nature of your default.)You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign
and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA
and received within thirty(30)days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PAFA WITHIN 30 DAYS OF THAT MEETING,THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LAT>:
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUF
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BI
AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.The Pennsylvania Housing Finance Agency has sixty(60)
days to snake a decision after it receives your application. During that tune, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE
FOLLOWING PART OF THUS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(Tf you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at:
823 ANTHONY DR
MECHANICSBURG,PA 17050
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:From 3/1/2012 through 4/1/2012 at$2,170.83 per month,From 5/1/2012 through 111/2013
at$2,145.28 per month
Monthly Payments Accrued: $23,649.18
Late Charges Accrued: $330.20
Non-Sufficient Funds: $0.00
Fax Fees: $0.00
Property Inspections: $72.00
Speedpay Fees: $0.00
TOTAL AMOUNT PAST DUE: $24,051.38
HOW TO CURE TI3E DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $24,051.38, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and
sent to:
PNC Mortgage,A Division of PNC Bank,NA
Attention: Collections Center
3232 Newmark Drive
Miamisburg,OH 45342
IF YOU DO NOT CURE THE DEFAULT—If you do not cure the default within THIRTY(30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY(30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off
the mortgage debt.If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins
legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorneys fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY(30)DAY period,you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES --The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE—If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri zt to cure the default and
prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then
past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure
sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any
other requirements under the mortgage.Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice.A notice
of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the
default will increase the longer you wait. You may find out at any time exactly what the required payment or action
will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: PNC Mortgage
Address: 3232 Newmark Drive
Miamisburg,OH 45342
Phone Number: (800)523-8654
Fax Number: (855)288-3974
Contact Person: Collections Center
E-Mail Address: LossMitigation @pncmortgage.com
EFFECT OF SHERIFF'S SALE—You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it.If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any tine.
ASSUMPTION OF MORTGAGE --You_may or X may not (CHECK ONE) sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO 14AVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDTI' COUNSELING AGENCIES SERVING YOUR COUNTY
I EMAP Consumer Credit Counseling Agencies
Cumberland County
Advantage Credit Counseling PHFA
Service/CCCS of Western PA 211 North Front Street
2000 Lingiestown Road Harrisburg,PA 17110
Harrisburg,PA 17102 717-780-3940 800-342-2397
888-511-2227
Community Action Commission of Advantage Credit Counseling
Capital Region Service/CCCS of Western PA
1514 Derry Street 2000 Linglestown Road
Harrisburg,PA 17104 Harrisburg,PA 17102
717-232-9757 888-511-2227
Housing Alliance of York/Y Housing Community Action Commission of
Resources Capital Region
290 West Market Street 1514 Derry Street
York,PA 17401 Harrisburg,PA 17104
717-855-2752 717-232-9757
Maranatha Housing Alliance of York/Y Housing
43 Philadelphia Avenue Resources
Waynesboro,PA 17268 290 West Market Street
717-762-3285 York,PA 17401
717-855-2752
PA Interfaith Community Programs Inc Maranatha
40 E High Street 43 Philadelphia Avenue
Gettysburg,PA 17325 Waynesboro,PA 17268
717-334-1518 717-762-3285
PNCAttention: Collection Department
MORTGAGE`" (B6-Ymo7-o1-5) -• 4 .
3232 Newmark Drive 7Z.1b 9Q�$ •
Miamisburg, OH 45342 4j�� 8967 177g6
� r
r . r
PAUL BLACKBURN
823 ANTIIONY DR
MECHANICSBURG, PA 17050
Please find enclosed the ACT 91 NOTICE
for Loan Number: 0005829623
This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you
have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if
the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National
Association will only exercise its rights against the property itself, and is not attempting to collect the
discharged debt from you personally.
DR672
A Division of PNC Bank,National Association T1 937-910-1200 T2 800-822-5626
3232 Newmark Dr Miamisburg OH 45342 P.O Box 1820 Dayton OH 45401-1820
Date: 1/17/2013
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM(HEMAP)
may be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help,you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency
.
The name,address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any questions,you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): PAUL BLACKBURN
TARA BLACKBURN
PROPERTY ADDRESS: 823 ANTHONY DR
MECHANICSBURG,PA 17050
LOAN ACCT.NO.: 0005829623
ORIGINAL LENDER: N/A
CURRENT LENDERISERVICER:PNC Mortgage
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE --Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty(30)days from the date of this Notice (plus three (3) days for mailing). During that time you
must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN TIMTY-THREE (331 DAYS OF THE DATE OF TEEIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES—If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county
in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting.Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE—Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign
and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA
and received within thirty(30)days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE_ IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETfNG, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE
STOPPED.
AGENCY ACTION—Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act.The Pennsylvania Housing Finance Agency has sixty(60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
(lousing Finance Agency of its decision on your application.
NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date).
NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at:
823 ANTHONY DR
MECHANICSBURG,PA 17050
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
Amounts are now past due:From 3/1/2012 through 4/1/2012 at$2,170.83 per month,From 5/1/2012 through Ill/2013
at$2,145.28 per month
Monthly Payments Accrued: $23,649.18
Late Charges Accrued: $330.20
Non-Sufficient Funds: $0.00
Fax Fees: $0.00
Property Inspections: $72.00
Speedpay Fees: $0.00
TOTAL AMOUNT PAST DUE: $24,051.38
HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $24,051.38, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and
sent to:
PNC Mortgage, A Division of PNC Bank,NA
Attention: Collections Center
3232 Newmark Drive
Miamisburg, OH 45342
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30)DAYS of the date of
this Notice, the lender intends to exercise its riehts to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON—The mortgaged property will be sold by the Sheriff to pay off
the mortgage debt. If the tender refers your case to its attorneys,but you cure the delinquency before the lender begins
legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
T IRTY(30)DAY period,you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE --If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then
past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure
sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any
other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice.A notice
of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the
default will increase the longer you wait. You may find out at any time exactly what the required payment or action
will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: PNC Mortgage
Address: 3232 Newmark Drive
Miamisburg,OH 45342
Phone Number: (800)523-8654
Fax Number: (855)288-3974
Contact Person: Collections Center
E-Mail Address: LossMitigation@pncmortgage.com
EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE --You_ may or X may not (CHECK ONE) sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
HEMAP Consumer Credit Counseling Agencies
Cumberland County
Advantage Credit Counseling PHFA
Service/CCCS of Western PA 211 North Front Street
2000 Linglestown Road Harrisburg,PA 17110
Harrisburg,PA 17102 717-780-3940 800-342-2397
888-511-2227
Community Action Commission of Advantage Credit Counseling
Capital Region Service/CCCS of Western PA
1514 Derry Street 2000 Linglestown Road
Harrisburg,PA 17104 Harrisburg,PA 17102
717-232-9757 888-511-2227
Housing Alliance of York/Y Housing Community Action Commission of
Resources Capital Region
290 West Market Street 1514 Derry Street
York,PA 17401 Harrisburg,PA 17104
717-855-2752 717-232-9757
Maranatha Housing Alliance of York/Y Housing
43 Philadelphia Avenue Resources
Waynesboro,PA 17268 290 West Market Street
717-762-3285 York,PA 17401
717-855-2752
PA Interfaith Community Programs Inc Maranatha
40 B High Street 43 Philadelphia Avenue
Gettysburg,PA 17325 Waynesboro,PA 17268
717-334-1518 717-762-3285
FORM 1
: IN THE-COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA ='
Plain iff(s) '
NC ink. -NCO I:p
rn. .,
vs. 1Gc�C '�!
cr
to
GrGCLCrt1o' Defendant(s) a l Civil Gam'
5>c_)
NOTICE OF RESIDEN'T'IAL MORTGAGE FORECLO§ R 5->'
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 Iegal 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 TI-I.E
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
AV � �Mark 1. Udren, Esquire
PA ID 04302
Date [Signature of Counsel for Plaintiff}
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMERIPRIMARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
Citv: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
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 Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
.......... ........... ................................................................. .............. ..................... .............
If yes,provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $
Savings: $
Other:
Automobile#1: Model: Year:
Amount owed: Value:
Automobile 42: Model: Year:
Amount owed: Value:
Other transportation.(automobiles. boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
Additional Income Description(not wages):
I monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mo rtgage Food
2" Mort ga-e Utilities
Car 92 Condo/Neigh. Fees
Auto Insurance M.ed.(not covered)
Auto fuel/repairs Other prop.p ayment
Install.Loan Payment Cable TV
Child Support!Aiim. Spending Money
Day/Child Care/Twit. -Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income& Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes,;please provide the following information:
Counseling Agency
Counselor:
Phone(Office): Fax:
.. ................................. ...................................... .................
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP)assistance?
Yes❑ No 7
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes❑ No ❑
If yes.please indicate the status of those negotiations:
Please provide the following information, if know,regarding your lender or Lender's loan
servicing company:
Lender's Contact(Name)- Phone:
Servicing Company(Name):
Contact: Phone:
AUTHORIZATION
I/We, authorize the above
named to use/refer this information to my I.ender/serviccer for the sole
purpose of evaluating my financial situation for possible mortgage options. I,/We
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co^BorroNver Si(NJYrlµitTlTe S_/ate
Please forward this document along with the following information to lender and
lender's counsel:
V Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
V Copy of a current utili"y bill
V Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
3
FORM 3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY_. PENNSYLVANIA
�APlaintiff(s)
vs
C k k Ca_vk Cr-
Defendant(s) CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated . 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as .follows:
I. Defendant is the owner of the real property which is the subject o:f�this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
�. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion.Program" and has taken all of the steps required.in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
UDREN LAW OFFICES,P.C. ATTORNEY FOR'PLAINTIFF
BY. MARK J. UDREN,ESQUIRE-ID#04302
STUART WINNEG, ESQUIRE - ID#45362
LORRAINE GAZZARA DOYLE,ESQUIRE -ID#34576
SHERRI J. BRAUNSTEIN, ESQUIRE -ID#90675
SALVATORE CAROLLO,ESQUIRE -ID#311050
HARRY B. REESE, ESQUIRE - ID#310501
ELIZABETH L.WASSALL,ESQUIRE -ID#77788 C=
KATHERINE E. KNOWLTON,ESQUIRE -ID#311713
JOHN ERIC KISHBAUGH, ESQUIRE -ID#33078 =M -0
=:;o
NICOLE B. LABLETTA,ESQUIRE -ID#202194
C)
DAVID NEEREN,ESQUIRE -ID#204252
JORDAN DAVID,ESQUIRE - ID#311968 >C-)
=,C)
CD
WOODCREST CORPORATE CENTER
3C::
III WOODCREST ROAD, SUITE 200 '
CHERRY HILL,NJ 08003-3620
856-669-5400
Pleadings@udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
3232 Newmark Drive,Miamisburg,OH 45342 CIVIL DIVISION
Plaintiff CUMBERLAND County
NO. — C7�1 f l.il U
Paul Blackburn a/k/a Paul G Blackburn
823 Anthony Drive
Mechanicsburg,PA 17050,
Tara Blackburn a/k/a Tara A.Blackburn
823 Anthony Drive
Mechanicsburg,PA 17050
Defendant(s)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY.
Kindly enter the appearance of the following counsel: Mark J.Udren,Esquire; Stuart Winneg,Esquire;Lorraine
Gazzara Doyle,Esquire;Sherri J.Braunstein,Esquire;Harry B.Reese,Esquire; Salvatore Carollo,Esquire;
Elizabeth L.Wassall,Esquire;Katherine E Knowlton,Esquire,and John Eric Kishbaugh,Esquire;Nicole B.
LaBletta,Esquire;David Neeren,Esquire;Jordan David,Esquire on behalf of the Plaintiff, in the above-
captioned matter.
UDREN LAW OFFICES,P.C.
Mark 3. Udren, EsquirO.
BY PA 10 ()4302
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION c E2 !fl°
Cumberland County � =--n
V. M r-"
PAUL BLACKBURN A/K/A PAUL G.
BLACKBURN; TARA BLACKBURN NO. 13-2111 Civil r—D
A/K/A TARA A. BLACKBURN; et al '5 n c�-_
v r,
=o ;
Defendant(s) .
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint on the above-captioned matter.
DATE: Q130
UDREN LAW
B
Attorneys for Pl intiff
David Neeren, Esquire
PA ID 204252
OLY4
Cy- ff �/�s�
P�4 �)07 S(Y S
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ('� c D-0f ?�
Sheriff DF I .�1 i (} >,
Jody S Smith [
Chief Deputy ` ` — �` $
>
Richard W Stewart " "'` CUMBERLAND COON I"Y
Solicitor OFF tC CA T1<$4gr,'rr P ?q t�S Y L A H!A
PNC Bank National Association
Case Number
vs.
Tara Blackburn (et al.) 2013-2111
SHERIFF'S RETURN OF SERVICE
04/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Tara Blackburn, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 823 Anthony Drive,
Hampden Township, Mechanicsburg, PA 17050. Residence is vacant and the Mechanicsburg Postmaster
has been unable to provide a forwarding adress as of-this date.
04/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Paul Blackburn, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 823 Anthony Drive,
Hampden Township, Mechanicsburg, PA 17050. Residence is vacant and the Mechanicsburg Postmaster
has been unable to provide a forwarding adress as of this date.
SHERIFF COST: $65.30 SO ANSWERS,
May 17, 2013 RbNW R ANDERSON, SHERIFF
(c)CountyS.uite Sheriff,Toleosoft,Inc.
����������o�� ����Ud��� ��� CUMBERLAND ����UU��TY '
SHERIFF'S~" ~~"OFFICE ~~~~^~^~~~~^ --- - --- - - -' '
Ronny R Anderson
Sheriff �� TF E pii 0T�����-»�`/
- '
Jody SSm� °�h
Smith "8/� UUQ -� �� �� �R
Chief Deputy
^ —�- ~~'` ~ ^ //.�- +"
Richard VVStewart ~`��'�v� MlAH| A0 CDUNTy
Sn�x�r m��wpn���� p����y;VA �/ � �
pNC Bank National Association Case Number
vs. | 2013'2111
Tara Blackburn (et al.) �
SHERIFF'S RETURN OF SERVICE
05/15/2013 Sheriff Ronny RAnderson, being duly sworn according to law, states hamade diligent search and inquiry
for the within named Defendant to wit:Tara Blackburn, but was unable to locate the Defendant in the
Sheriff's bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according tolaw.
05/15/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Paul Blackburn, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
05/17/2013 Ronny R Anderson, Sheriff, being duly sworn according ho law, states he made diligent search and inquiry
for the within named Defendant to wit: Paul Blackburn, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 425 Lamp Post Lane,
Hampden Township, Camp Hill, PA 17011. Current residents advised that the defendants used to rent
the property from them but no longer live there.
05/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant towit: Tara Blackburn, but was unable to locate the Defendant in.his
bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
DiveroionPnognamondComp|aintinyNortgageFonao|oauveau''NotFound^ot425LempPootLona.
Hampden Township, Camp Hill, PA17O11. Current residents advised that the defendants used torent
the property from them but no.longer live there.
05/28/2013 03:45 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Paul Blackburn, personally, at
The Dauphin County Sheriffs Office at 101 Market Street, Room 104, Harrisburg, PA 17101. Jack
Lotwick, Sheriff, Return of Service attached to and made part of the within record.
05/28/2013 03:45 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Tara Blackburn, personally, at
The Dauphin County Sheriffs Office at 101 Market Street, Room 104, Harrisburg, PA 17101. Jack
Lotwick, Sheriff, Return of Service attached to and made part of the within record.
SHERIFF COST: $111.05 SO ANSWERS,
June O4. 2O13 RbmmrR ANDERSON, SHERIFF
wCountySuite Shedtf,Tele=�Inc.
,. a4
' � `` `j
Shelley Ruhl Jack Duignan
Real Esta e Deputy Chief Deputy
Matthew L. Owens Michael W. Rinehart
Solicitor Assistant Chief Deputy
Dauphin County
101 Market Street
Harrisburg,Pennsylvania 17101-2079
ph:(717)780-6590 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK,NATIONAL ASSOCIATION
VS
County of Dauphin TARA BLACKBURN
Sheriffs Return
No. 2013-T-1557
OTHER COUNTY NO. 2013-2111
And now: MAY 28, 2013 at 3:45:00 PM served the within REINSTATED COMPLAINT IN
MORTGAGE FORECLOSURE upon TARA BLACKBURN by personally handing to TARA
BLACKBURN 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE
FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY
SHERIFF'S OFFICE, 101 MARKET STREET, ROOM 104 HARRISBURG PA 17101
DEFENDANT VERIFIED GOOD ADDRESS: 2077-D RALEIGH ROAD, HUMMELSTOWN, PA
17036.
Sworn and subscribed to So Answers,
before me this 30TH day of May, 2013 Q i �
Sheriff of Dauphin County, Pa.
By OW",
COMMONWEALTH OF PENNSYLVANIA Deputy Sher ff
NOTARIAL SEAL Deputy: MEGAN TRITT
Karen M.Hoffman,Notary Public
City of Harrisburg,Dauphin County Sheriffs Costs: $68.5 5/20/2013
M Commission Expires August 17,2014
Shelleyy Ruhl Jack Duignan
Real Estal'e Deputy Chief Deputy
Matthew L. Owens
Michael W. Rinehart
Solicitor Assistant Chief Deputy
Dauphin County
101 Market Street
Harrisburg,Pennsylvania 17101-2079
ph:{717}780-6590 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK,NATIONAL ASSOCIATION
VS
County of Dauphin TARA BLACKBURN
Sheriff s Return
No. 2013-T-1557
OTHER COUNTY NO. 2013-2111
And now: MAY 24, 2013 at 3:45:00 PM served the within REINSTATED COMPLAINT IN
MORTGAGE FORECLOSURE upon PAUL BLACKBURN by personally handing to PAUL
BLACKBURN 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE
FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY
SHERIFF'S OFFICE, 101 MARKET STREET, ROOM 104 HARRISBURG PA 17101
DEFENDANT VERIFIED GOOD ADDRESS: 2077-D RALEIGH ROAD, HUMMELSTOWN, PA
17036.
Sworn and subscribed to So Answers,
before me this 30TH day of May, 2013 QAlc
Sheriff of Dauphin County, Pa.
By
COMMONWEALTH OF PENNSYLVANIA Deputy Sheriff
NOTARIAL SEAL Deputy:NAN A MILLER
Karen M.Hoffman,Notary Public
City of Harrisburg,Dauphin county Sheriffs Costs: $68.5 5/20/2013
M Commission Expires August 17,2014
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
lep adin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
3232 Newmark Drive. CIVIL DIVISION
Miamisburg,OH 45342 Cumberland County
Plaintiff
V. MORTGAGE FORECLOSURE
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN,PA 17036 NO. 13-2111 Civil - Za ,
co are*
rri C==
TARA BLACKBURN A/K/A TARA A.BLACKBURN � -
2077D RALEIGH ROAD -<'P, cc
HUMMELSTOWN,PA 17036 X2, CD
Defendant(s) 3>c°- :.G:.:-
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the Defendant(s),PAUL BLACKBURN A/K/A
PAUL G.BLACKBURN; TARA BLACKBURN A/K/A TARA A.BLACKBURN; for failure to file an Answer to
Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and
assess Plaintiffs damages as follows:
FROM TO
Unpaid Principal Balance $263,066.07
Interest Per Complaint $16,997.15
Additional Interest 03/08/2013 07/30/2013 $6,139.30
Late Charges Per Complaint $495.30
Additional Late Charges 03/08/2013 07/30/2013 $412.75
Escrow Per Complaint $4,782.92
Grand Total $291,893.49
I hereby certify that(1)the addresses of the Plaintiff and Defendant are as shown above,and(2)that notice has been
given in accordance with Rule 237.1, a copy of which is attached hereto.
UD TAF .C.
RRY S.,REESE, ESQUI RE
BY310501
Att
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: g1S 2 o 1,
PROTHY
$16- 50
MJU#: 12041104 CASE#: 12041104-12 S"3 793
q` IX 7
/Yo f(' e-
IIJDREN LAW OFFICES,P.C. ATTORNEY FOR PLAIN'T'IFF
BY: MARK J.UDREN,ESQUIRE-ID#04302
STUART WINNEG,ESQUIRE-ID#45362
LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576
SHERRI J.BRAUNSTEIN,ESQUIRE - ID#90675
SALVATORE CAROLLO,ESQUIRE-ID#311050
HARRY B.REESE,ESQUIRE-ID#310501
ELIZABETH L.WASSALL,ESQUIRE-ID#77788
KATHERINE E. KNOWLTON,ESQUIRE-ID#311713
JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078
NICOLE B.LABLETTA,ESQUIRE—ID#202194
DAVID NEEREN,ESQUIRE-ID#204252
JORDAN DAVID,ESQUIRE-ID#311968 cY
WOODCREST CORPORATE CENTER
C
111 WOODCREST ROAD,SUITE 200 .�
CHERRY HILL NJ 08003-3620
856-669-5400 leadin s @udren.coni
PNC Bank,National Association —� COURT OF COMMON PLEAS ,��
C/O PNC Bank,N.A. CIVIL DIVISION y ,
3232 Newmark Drive CUMBERLAND County ' r7�
YAamisburg,OH 45342
C-5
Plaintiff NO.
V.
PAUL BLACKBURN A/K/A PAUL G.
BLACKBURN
823 ANTHONY DRIVE j
MECHANICSBURG,PA 17050 !I
TARA BLACKBURN A/K/A TARA A. f
BLACKBURN
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money .claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
of 'Iffe ,
art
Real l�le Ruhl Jack Duignan
PAY ' Chief Deputy
Matthew L. Owens Michael W. Rinehart
Solicitor Assistant Chief Deputy
Dauphin County
101 Market street
Harrisburg,Pennsylvania 17101-2079
ph:(717)780-6590 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK,NATIONAL ASSOCIATION
VS
County of Dauphin TARA BLACKBURN
Sheriffs Return
No.2013-T-1557
OTHER COUNTY NO. 2013-2111
And now: MAY 28,2013 at 3:45:00 PM served the within REINSTATED COMPLAINT IN
MORTGAGE FORECLOSURE upon TARA BLACKBURN by personally handing to TARA
BLACKBURN 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE
FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY
SHERIFF'S OFFICE, 101 MARKET STREET,ROOM 104 HARRISBURG PA 17101
DEFENDANT VERIFIED GOOD ADDRESS:2077-D RALEIGH ROAD,HUMMELSTOWN,PA
17036.
Sworn and subscribed to So Answers,
before me this 30TH day of May,2013
Sheriff of Dauphin County,Pa.
X !�` By
COMMONWEALTH OF PENNSYLVANIA Deputy Sher ff
NOTARIAL SfiAL Deputy: MEGAN TRITT
Karen M.Hoffman,Notary Public
City of Harrisburg,Dauphin County Sheriffs Costs: $68.5 5/20/2013
M y Commission Expires August 17 2014
Real Eek Ruhl Jack Duignan
PAY ' Chief Deputy
Matthew L. Owens 'B Michael W. Rinehart
Solicitor Assistant Chief Deputy
Dauphin County
101 Market Street
Harrisburg,Pennsylvania 17101-2079
ph:(717)780.659.0 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania PNC BANK,NATIONAL ASSOCIATION
VS
County of Dauphin TARA BLACKBURN
Sheriff s Return
No.2013-T-1557
OTHER COUNTY NO. 2013-2111
And now: MAY 24, 2013 at 3:45:00 PM served the within REINSTATED COMPLAINT IN
MORTGAGE FORECLOSURE upon PAUL BLACKBURN by personally handing to PAUL
BLACKBURN 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE
FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY
SHERIFF'S OFFICE, 101 MARKET STREET, ROOM 104 HARRISBURG PA 17101
DEFENDANT VERIFIED GOOD ADDRESS: 2077-D RALEIGH ROAD, HU'MMELSTOWN, PA
17036.
Sworn and subscribed to So Answers,
before me this 30TH day of May,2013 eAe' --
Sheriff of Dauphin County, Pa.
By- " tg i&
COMMONWEALTH OF PENNSYLVANIA Deputy Sheriff
NOTARIAL SEAL Deputy:NAN A MILLER
Karen M.Hoffman,Notary Public
City of Harrisburg.Dauphin County Sheriffs Costs: $68.5 5/20/2013
M Y Commission Expires Au t 17.2014
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
Paul Blackburn a/k/a Paul G.Blackburn,
Tara Blackburn a/k/a Tara A.Blackburn MORTGAGE FORECLOSURE
Defendants) NO. 13-2111 Civil
TO: Paul Blackburn alk/a Paul G.Blackburn
2077D Raleigh Road
Hummelstown,PA 17036
Date of Notice: June 24,2013
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAVMR REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
NOTIFICACION rA PORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ(10)DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS
DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA,CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGU R ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
NOTICE:PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
UDREN LAW OFFICES,PC.
BY:
Attorney for Plaintiff
Nic0le LaBlefta
Woodcrest Corporate Center I A ID 2021 94 oA
111 Wooderest Road,Suite 200
Cherry Hill,New Jersey 08003-3620
MJU#: 12041104 CASE#: 12041104-12
UDREN LAW OFTICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY RML,NJ 08003-3620
856-569-5400
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
Paul Blackburn a/k/a Paul G.Blackburn,
Tara Blackburn a/k/a Tara A.Blackburn MORTGAGE FORECLOSURE
Defendant(s) NO. 13-2111 Civil
TO: Tara Blackburn a/k/a Tara A.Blackburn
2077D Raleigh Road
Hummelstown,PA 17036
Date of Notice: ,Tune 24,2013
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9105
NOTIFICACION IM[PORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUlRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ(10)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA,SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS
DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
MWEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO,VAYA EN PERSONA O LLAN E POR TELEFONO A LA OFICINA,CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17413
(800)990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE..
UDREN LAW OFFICES,PC.
BY:
ttoraey for Piiinififf
Nicole LaBlena Es l :4qlAkl
Waodcrest Corporate Center
PA ID 2 111 Woodcrest Road,Suite 200
Chevy Hill,New Jersey 08003-3620
MJU#: 12041104 CASE#: 12041104-12
• a
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings@udren.com
COURT OF COMMON PLEAS
PNC Bank,National Association CIVIL-DIVISION
Plaintiff Cumberland County
V. zz; -
MORTGAGE FORECLOSURE rrl
PAUL BLACKBURN A/K/A PAUL G. �
BLACKBURN,TARA BLACKBURN A/K/A
TARA A.BLACKBURN,
NO. 13-2111 Civil
Defendant(s) °
AFFIDAVIT OF NON-MILITARY SERVICE
UNDER Pa.R.C.P 76
THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data
Center for the Defendant(s),that the Defendant(s),PAUL BLACKBURN A/K/A PAUL G.
BLACKBURN,TARA BLACKBURN A/K/A TARA A.BLACKBURN,who/each of whom is over
18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act.
The Military Status Report(s)is/are attached hereto as Exhibit "A".
The Affiant lacks sufficient information to be able to determine whether any other Defendants in
this action are in active military service because Plaintiff cannot provide date(s)of birth and/or Social
Security number(s) for said Defendant(s)to enable a search.
This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
Dated: July 30,2013
Attoldey Plainti
HARRY.B.- ESE, ESQUIRE
PA ID 310501
MJU#: 12041104 CASE#: 12041104-12
Department of Defense Manpower Data Center Results as of:Aug-07-2013 0928:19
SCRA 3.0
6 Status Report
Pursuant to Savicemembers Civil Relief Act
11"
Last Name: BLACKBURN
First Name: PAUL
Middle Name: G
Active Duty Status As Of: Aug-07-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA NA
This response reflects the individuals'.ctiv.di:4 status based o'n Ge A.0;;o Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA NA
I
This response reflects Where the individual left active 44%tatus�vvfthir;U7 ttay.preceding the Active Duty Status Date
N�'I —I I
�i �� I — ��V,�� -
The Member or HistHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status =:=Service Component
NA 0 NA
This response reflects whether fhe individual or his/her unit has received er'.4,notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
A
Ohl
Mary M,Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
a
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 USG 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:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. 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: V4A7H930402CX20
Department of Defense Manpower Data Center Results as of:Jul-30-2013 08:24:08
SCRA 3.0
�a f
status RD1'I:
t
"
Pursuant to Servicememben Civil Relief Act
Last Name: BLACKBURN
First Name: TARA
Middle Name: A_
Active Duty Status As Of: Jul-30-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA s — ..t� N NA
This response reflects the indvdividuatV active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA t �.At NA " `.'Ty\ " i j'.. ^.No �t �4:.4 NA
-f.
This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or HWHer Unit Was Notified of a Future Cali-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA *,NR t '+.� E. ...r'/ ,�No � NA
This response reflects whether the individual or hislher unit has received e8rly notification to report for active duty
�x
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Y691 A �" w
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
I
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•hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. 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 Carps 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: 53Q81D3E7039M60
I
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadin-gs@udren.com
PNC Bank, National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
Paul Blackburn a/k/a Paul G. Blackburn MORTGAGE FORECLOSURE
Tara Blackburn a/k/a Tara A. Blackburn
Defendant(s) NO. 13-2111 Civil -c.—.'. _
rn c=
PRAECIPE TO ISSUE WRIT OF EXECUTION ='' '
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
T� r"3
Amount due
$291,893.49
Interest From 7/31/2013 $ 2,794.44
to Date of Sale December 4,2013
Ongoing Per Diem of$42.34
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
3 O C 13 UDREN LAW OFFICES,P
III • qs
BY
' D 3• (7,5 Atto y f&/Plaintiff
/ O HARRY.:B.:_REE , ESQUIRE
�D PA It) 10501
MJU#• 12041104 CA E#: 12041104-12
�` o2ur" lie o,
poor
/ssC.,P o/
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County C=
Paul Blackburn a/k/a Paul G. Blackburn MORTGAGE FORECLOSURE
Tara Blackburn a/k/a Tara A. Blackburn c E"
-< co _C
Defendants
� � NO. 13-2111 Civil (Z)-_
CERTIFICATE OF ACT 91
I hereby state that as the attorney for the Plaintiff in the above-captioned matter:
Act 91 procedures have been fulfilled
[� Premises is not subject to the provisions of Act 91
as this is an FHA insured mortgage
This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
UDREN LAW OFFICES, P.C.
BY:
Atto r n '
HARRY S....R E, ESQUIRE
PA` 310501
URREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
j WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v Cumberland County
John Matthew Hyams
Charles J. DeHart,III MORTGAGE FORECLOSURE
Paul Blackburn a/k/a Paul G.Blackburn
Tara Blackburn a/k/a Tara A. Blackburn
Defendant(s) NO. 13-2111 Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
PNC Bank,National Association ,Plaintiff in the above action,by its undersigned attorney, upon information
and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed,
the following information concerning the real property located at:
823 Anthony Drive,Mechanicsburg, PA 17050
1. Name and address of Owner(s) or reputed Owner(s): 3:
rn
Paul Blackburn a/k/a Paul G. Blackburn'
2077D Raleigh Road U) C:� '
Hummelstown, PA 17036- s
Tara Blackburn a/k/a Tara A. Blackburn = cvC;
2077D Raleigh Road
Hummelstown,PA 17036
2. Name and address of Defendant(s) in the judgment:
Paul Blackburn a/k/a Paul G. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
Tara Blackburn a/k/a Tara A. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders-None
4. Name and address of the last recorded holder of every mortgage of record:
PNC Bank,National Association
3232 Newmark Drive
Miamisburg, OH 45342
i
Sr Mortgage Holders - None
Susquehanna Valley FCU
3850 Hartzdale Drive
Camp Hill,PA 17011
5:Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Real Estate Tax Depa tment
1 Courthouse Square
Carlisle, PA 17013
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA,Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
i
Tenants/Occupants
823 Anthony Drive
Mechanicsburg, PA 17050
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:
Federal Tax Lien Holders -None
Condo/Homeowners Association-None
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED: UDREN LAW OFF CES, P.C.
BY:
Atto e f'r nti
HARRY.-IL,:RE. E, ESQUIRE
MJU#: 12041104 CASE#: 12041104-12 PA I 10501
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION C-!; r ,
V. Cumberland County
M
PAUL BLACKBURN A/K/A PAUL G. MORTGAGE FORECLOSURE-`
BLACKBURN, --<TARA BLACKBURN ' :)
C�'� cro �? a
A/K/A TARA A. BLACKBURN r
Defendants NO. 13-2111 Civil )>e1 '
C--;
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY s
TO: Paul Blackburn a/k/a Paul G. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
Your house(real estate) at 823 Anthony Drive,Mechanicsburg,PA 17050 is scheduled to be
sold at the Sheriffs Sale on December 4,2013 at 10:00am at the Cumberland County
Courthouse,Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013, to enforce the
court judgment of$291,893.49, obtained by Plaintiff above(the mortgagee) against you. If the
sale is postponed, the property will be relisted for the Next Available Sale.
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 cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable
attorney's fees. To find out how much you must pay,you may call:(856)669-5400.
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 notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after 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 distribution is wrong)are filed with the Sheriff within ten(10)days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses,or ways of getting your home back,if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ALL THAT CERAIN TRACT OR PARCEL OF LAND WITH THE IMPROVEMENTS THEREON
ERECTED SITUATE, LYING AND BEING IN THE TOWNSHIP OF HAMPDEN, IN THE COUTY OF
CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY
DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE SOUTHWESTERN SIDE OF ANTHONY DRIVE (FORMERLY
MARGARET ROAD) AT THE DIVIDING LINE BETWEEN LOTS 42 AND 43 OF THE HEREINAFTER
MENTIONED PLAN; THENCE BY SAID DIVIDING LINE, SOUTH FIFTY-NINE (59) DEGREES THREE
(03) MINUTES FORTY-SEVEN (47) SECONDS WEST, ONE HUNDRED NINETY-SIX AND TWENTY-
EIGHT HUNDREDTHS (196.28) FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOT 42 AND
LOT 53 OF THE PLAN; THENCE BY SAID DIVIDING LINE AND THE LINE OF LOT 54,NORTH
TWENTY-EIGHT (28) DEGREES TWENTY-SIX (26) MINUTES TWENTY-FOUR (24) SECONDS WEST,
ONE HUNDRED FIFTY-ONE AND TWENTY-SEVEN HUNDREDTHS (151.27) FEET TO A POINT ON
THE SOUTHERN SIDE OF ANTHONY DRIVE; THENCE BY THE SOUTHERN SIDE OF ANTHONY
DRIVE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF ONE HUNDRED FORTY (140)
FEET AN ARC DISTANCE OF SIXTY-SEVEN AND SEVENTEEN HUNDREDTHS (67.17) FEET TO A
POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF ANTHONY DRIVE,NORTH
EIGHTY-NINE (89) DEGREES THREE (03) MINUTES SIX (06) SECONDS EAST, SIXTY-ONE AND
SEVEN TENTHS (61.7) FEET TO A POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF
ANTHONY DRIVE BY AN ARC CURVING TO THE RIGHT, HAVING A RADIUS OF ONE HUNDRED
FIFTY (150) FEET AN ARC DISTANCE OF ONE HUNDRED TWENTY-EIGHT AND SEVENTY-ONE
HUNDREDTHS (128.71) FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS 42 AND 43,
THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 42 ON FINAL PLAN NO. 2, SECTION II,
DEIMLER MANOR, RECORDED IN PLAN BOOK 33, PAGE 10, CUMBERLAND COUNTY RECORDS.
BEING THE SAME PREMISES WHICH SUSAN D. DUPREE BY DEED BEARING DATE THE 14TH DAY
OF FEBRUARY, 2008 AND ABOUT TO BE HEREWITH RECORDED IN THE OFFICE OF THE
RECORDER OF DEEDS IN AND FOR THE COUNTY OF CUMBERLAND, PENNSYLVANIA,
GRANTED AND CONVEYED UNTO PAUL G. BLACKBURN AND TARA A. BLACKBURN, HUSBAND
AND WIFE
UNDER AND SUBJECT TO CONDITIONS AND RESTRICTIONS WHICH NOW APPEAR OF RECORD.
PARCEL# 10-17-1037-042
BEING KNOWN AS: 823 ANTHONY DRIVE,MECHANICSBURG, PA 17050
PROPERTY ID NO.: 10-17-1037-042
TITLE TO SAID PREMISES IS VESTED IN PUAL G.BLACKBURN AND TARA A. BLACKBURN,
HUSBAND AND WIFE BY DEED FROM SUSAN D. DUPREE, SINGLE INDIVIDUAL DATED
02/14/2008 RECORDED 02/21/2008 IN DEED BOOK INSTRUMENT# 200805073.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 2013-2111 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due PNC Bank,National Association Plaintiff(s)
From Paul Blackburn a/k/a Paul G.Blackburn,Tara Blackburn a/k/a Tara A.Blackburn
(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 gamisliee(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 fi-om 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 be/she has been added as a
garnishee and is enjoined as above stated.
Amount Due:$291,893.49 L.L.:$30
Interest From 7/31/201.3 to Date of Sale December 4,2013-Ongoing Per Diem of$42.34 to actual
date of sale including if sale is held at a later date — fol,794,
Atty's Comm: Due Protby:$2.25
Arty Paid:$337.75 Other Costs-,
Plaintiff Paid:
Date:8/8/2013
David D.Buell,Prothon ta
(Seal)
Deputy
REQUESTING PARTY:
Name:Harry B.Reese,Esquire
Address:Udren,Law'Offices,P.C.
Wooderest Corporate Center
111 Wooderest Road,Suite 200
Cherry Hill,NJ 08003-3620
Attorney for:Plaintiff
Telephone: 856-669-5400
Supreme Court ID No.310501
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff Cumberland County
v.
PAUL BLACKBURN A/K/A PAUL G. NO. 13-2111 Civil
BLACKBURN; r
TARA BLACKBURN A/K/A TARA A. y '
BLACKBURN; et al -c�
Defendant(s) ''
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date: I 11-13
UDREN LAW OFFICES,P.C.
BY:
Attorney for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA ID 311050
. '
, Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s)
-!„`� APS International, Ltd.
vs.
Paul Blackburn aka Paul G.Blackburn,et.al..Defendant(s) 1-800-328-7171
(NTER`ATIU•'VAL APS International Plaza
F r 7800 Glenroy Road
\\.., &am v •'/ Minneapolis.MN 55439-3122
APS File#: 125680-0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES --Tara Blackburn,aka Tara A.Blackburn
Ms.Henn'Crommarty Court Case No.Cumberland Co 13-2111 Civil
it t Woodcrest Rd.,Ste.200
Cherry Hill.NJ 08003-3620
Customer Filc: N12041104-12
_ _ _
County of AAA n\Ct`:VII /
Name of Server: a (e__„. }- S 1,I C.l' / y . undersigned,being duly sworn,deposes and says
that at all times mentioned herein.s/he was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Tara Blackburn,aka Tara A.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates/Time/Address Attempted: 823 Anthony Drive.Mechanicsburg,PA 17050
Reason for Non-Service:
Dates/Time/Address Attempted: 'O 1Y/ /3 /1-: 2 p: S V rill
Reason for Non-Service: 140An( 1..7. tI G cc rL 4-
Dates/rime/Address Attempted:
Reason for Non-Service:.
Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury , iiii an• .worn to before 1.e i
th he foregoing is true nd correct.
a . y of/i� 4 r
� t f t
('lam' SG�° le NIL iv ��R/alli l t
Signature of Server o •Public (Commissi•n x.Tres)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M,Michelle Guyton,Notary Public
Carlisle Boro,Cumberland County
viiivZ Commission Dykes July 9,2016
PENNSYLVANIA ASSOCIATION OF NOTARIES
Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s) -� APS International, Ltd.
vs. `
Paul Blackburn aka Paul G.Blackburn.et.al..Defendant(s) • 1-800-328-7171
INTER`ATIU!'4L APS International Plaza
'` 7800 Glenroy Road
Minneapolis,MN 55439-3122
APS File it: 125680-0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES —Paul Blackburn,aka Paul G.Blackburn
Ms.Henni Crommartv Court Case No.Cumberland Co 13-2111 Civil
I11 Woodcrest Rd.,Ste.200
Cherry Hill.NJ 08003-3620
i I
Customer File: N12041104-12
_ — — — — — — — — — —
o f: ■ •! ss.
Countyof: •<LAm • is,I11 //_
Name of Server: ( t I- $L'1.0 IC) .undersigned, being duly sworn,deposes and says
that at all times mentioned herein,s/he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul BIackburn,aka Paul G.Blackburn
and after due and diligent efforts. was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
batemdAddreu Attempted:, 823 Anthony Drive,Mechanicsburg,PA 17050
Reason for Non-Service: /�[/
Dates/Time/Address Attempted:, /0 ` ( 1�3 /2 : em
Reason for Non-Service: Eofr t ' a' U c c, o#'
Dates/i'ime/Address Attempted:.
Reason for Non-Service:
I Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Sub ribe• . • w• o bef•re me this /
th a foregoing is a and correct. 4 jy o ��� ^, 20/3
� i W
ignatttre of Server No., 1416-. c (Commission Ex. res)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M.Michelle Guyton,Notary Public
Carlisle Boro,Cumberland County
16
M Commission Expires ,OF NOTARIES
MEMBER,PENNSYLVANIA ASSOCIATION
��r Service of Process by
Sit Bank,National Association,et.al.,Plaintiff(s) ---
vs. / .� APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) ' 1-800-328-7171
/N9EBTiNT1C►!1`AL APS International Plaza
\ r` 7800 Glenroy Road
\___ Minneapolis,MN 55439-3122
APS File#: 125367-0001
-_ _AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
1 UDREN LAW OFFICES --Paul Blackburn,aka Paul G. Blackburn
Ms.Henni Crommarty Court Case No.Cumberland Co 13-2111 Civil
111 Woodcrest Rd..Ste.200
Cherry Hill,NJ 08003-3620
jCustomer File: N12041104-12
State of: �.►1� s. - - - - - - - - -County of:Miiitniga . L_
Name of Server: it t 5 .,° It , undersigned, being duly sworn,deposes and says
that at all times mentioned herein /he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul Blackburn,aka Paul G.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Datesll ime/Address Attempted: 2077D Raleigh Road,Hummelstown,PA 17036 /�
Reason for Non-Service: 4/2u/l3 //.3o AM d )V a45 i✓1." O AC5O r-
Dates/Cime/Address Attempted: c //1.3 A�1 .Spph t we ff'yLs i�`,r C.W � C-6 A f/`M
/
Reason for Non-Service. C V l lea/Jt 1 p F JorC J/ 17d 14 ),/7L 6 vt,- /8 ((J I'e)Cn cc
Dates/fime/AddressAttempted: CA 5.a I/s'1 ' S/3040 LA,i it ,'t^inor C%L, / A
Reason forNon-Service: Co rCititt.1- 0 Ue0- 'L, c5e od io @ Ill II,c)e/cc
ri Based upon the above stated facts, Affiant believes t •efend.nt is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury . abed . , sworn t• b-for me this
tha he foregoi g is true and correct.
IlMit ,3 ..e x,20 / -'.
nature of Server ���A"
I1 Not.• . �c ommissi' Expire -
APS International, Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M.Michelle Guyton,Notary Public
Carlisle Boro,Cumberland County
My Commission Expires July 9,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
PNC Bank,National Association,et.al.,Plaintiff(s) Service of Process by
vs. / .., APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s)
L_ 1-800-328-7171
IEY7'£R%XFIO 4L APS International Plaza
r 7800 Glenroy Road
- Minneapolis,MN 55439-3122
APS File fl: 125367-0001
____ _ _ _ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES --Tara Blackburn,aka Tara A. Blackburn
I Ms.Henni Crommartv Court Case No.Cumberland Co 13-2111 Civil
I 1 1 Woodcrest Rd.,Ste.200
Cherry Hill.NJ 08003-3620
Customer File: N12041104-12
State of: �.! 1 s - - - - - - - - —
County of: tte,• a.,a_ / /
Name of Server: ('�,,� 4 �1' L to . undersigned, being duly sworn,deposes and says
that at all times mentioned herein, s�was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of SherIff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Tara Blackburn,aka Tara A. Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates/I ime/Address Attempted: 2077D Raleigh Road,Hummelstown�,(PA 17036
Reason for Non-Service:'7/7_L) 1/.3o I4!h Po lAAS we-f- P 66.0
Dates/Time/Address Attempted:9 4/3 'is 1.5 AA SpALC.( t'Ul l itn.r c_ f'J) ('�h1"/rw1
1 ,�• / i •�
Reason for Non-Service: 14r4 Nf GS ire)4S CO A�)tre Sc, / /0 Ad.,11- t .'e'' to P re„Si den c C
Dales/Time/Address attempted: 9 123 1 3 S: IS elk S ictA•d 1,..)t‘
,..)tj�I'�+ �1i1 O�• 1"t
Reason for Non-Service: Co"' re�t t.)tn.1-' 0 iX r t t 4.5 f •h is P ✓t' Ne3e", e
I-1 Based upon the above stated facts,Affiant✓believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subset'•-: and errs to •efore me this
th e foregoing is trw•and correct. /4,2 d• of ; ,20 I,
e
Signature of Server `, Pub ��A mmis i:' �rpt er s)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
M.Michelle Guyton,Notary Public
Carlisle Boro,Cumberland County
My Commission Expires July 9,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
Service of Process by
PNC Bank.National Association,et.al.,Mint IRO —�.
+s. • ,pt APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) _ice . 1-800_32&,7171
IN I F'RNATH►V,}L APS International Plata
I - 7800 Glenroy Road
`NM r - Minneapolis,MN 55439-3122
APS File to: 126589.0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES —Paul Blackburn,aka Paul G.Blackburn
Ms.Henri Crommartv
Court Case No.Cumberland Co 13-2111 Civil
111 Woodcrest Rd.,Ste.200
Cherry Hill.NJ 08003-3620 i
Customer File: N12041104-12
State of: )ss.
County of: t .�.,yt :J Q ,
Name of Server: mit undersigned. being duly sworn.deposes and says
that at all times mentioned herein to was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul Blackburn,aka Paul G.Blackburn
u
and after due and diligent efforts,was unable to effect service. .—_
Attempts: The following is a list of the attempts made to effect service:
Dotes/Time/Address Attempted: 425 Lamp Post Lane,Camp Hill.PA 17011
Reason for lion Servkr: /)j
Dates/Time/Address Attempted. ��,�ZS1/3 /I /LAM
Reason for ton-Senire:. c. Poo t /IIt 4'`— t-Ynr�f �+.�^t 1 e P�.'i't �1'��l s itco r C3 '7[r,/�_her.(
Dates/Time/Address Attempted- 11.6 PC LA TGrs le tac4I✓M Ci pro t`4ri4rn{y .. A�toe.f ( Su! (J6G`r
rt cJ
Reason for lion-Service:. /1b N4 vC r^1.04 1,-4)1'D G.-`)t3+"c .s 5
Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this
that the foregoing is true and correc � "1d.y of, , . , 2d3
Signature of Server Natal •ommission t xpit-est
APS International,Ltd.
PNC Bank.National Association.et al„Plainliff(s)
vs. Service of Process by
Paul Blackburn aka Paul G.Blackburn,et.al..Defendants) APS International, Ltd.
_ 1-800-328-7171
INTERNATiovAL APS International Plaza
7800 Gleam Road•'
Minneapolis.MN
Po 55434-3122
APS File#: 126569.0001
— AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
+ Service of Process on:
LIDREN LAW OFFICES I —Tara Blackburn,aka Tara A.Blackburn
Ms,Henri Crommarty Court Case No.Cumberland Co 13-2111 Civil
1 I 1 Wooderest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
Customer Fib.: N12041104-12
State of:
County or:C,L'(ti.thr'kilo( )
Name of Server: a (c_� SS .undersigned. being duly sworn.deposes and says
that at all times mentioned herein, the was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as
Notice of Sheriffs Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Tara Blackburn,aka Tara A.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates/TimetAddress Attempted:.
425 Lamp Post Lane,Camp Hill.PA 17011
Reason for Non•Srrvirc:
Datestrime/Address Attempted: 1 1 /i.r1/ i
y r T • Orate w / ..I f Cia rr oi,
Reason for Nantirs'rrvire: � •f� J 1
Dates/Time/Address Attempted:, 1"a Y"ei` Tc r� I Ccf.hi ri_ t//t- o?S % 4 i 1 tr S/h /L"8✓,[ )O
,/� J ti / r j ✓
Reason for Non-Service- [Jb CS ytet t 11 e•Ue s e'Ws.rcj rf 4 S
- Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this f
that the foregoin. is true :nd correct. it day of 1 '�,' ),t' •
20 K�
r
r
Signature of Server Notary Public (Commission Expires)
APS International, Ltd.
,y I L.,11:.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION ..,; •
CUMBERLAND County
v.
Paul Blackburn a/k/a Paul G. Blackburn;
Tara Blackburn a/k/a Tara A. Blackburn NO. 13-2111 Civil
Defendant(s)
MOTION FOR SPECIAL SERVICE PURSUANT
TO SPECIAL ORDER OF COURT
Plaintiff,by its counsel, moves this Honorable Court for an Order directing service of the
Notice of Sale upon Defendant(s):
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN, TARA BLACKBURN
A/K/A TARA A. BLACKBURN,
by regular mail and certified mail, and by posting the mortgaged premises and in support thereof
avers the following:
1. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
TARA BLACKBURN A/K/A TARA A. BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
A copy of the Return of Service is attached hereto as Exhibit"A".
2. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
823 ANTHONY DRIVE
MECHANICSBURG, PA 17050
TARA BLACKBURN A/K/A TARA A. BLACKBURN
823 ANTHONY DRIVE
MECHANICSBURG, PA 17050
A copy of the Return of Service is attached hereto as Exhibit`B".
3. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
425 LAMP POST LANE
CAMP HILL, PA 17011
TARA BLACKBURN A/K/A TARA A. BLACKBURN
425 LAMP POST LANE
CAMP HILL, PA 17011
A copy of the Return of Service is attached hereto as Exhibit"C".
4. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof
being attached hereto as Exhibit"D".
5. Said investigation was unable to determine an alternate address for said Defendant(s).
6. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"E".
7. The last known address of Defendant(s) is as set forth in the attached Exhibits.
WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter
an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph
1,by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
- -or Plaintiff
Jordan David, Esquire
PA ID#: 311968
Service of Process by
!NC Bank,National Association,et.al.,Plaintiff(s) APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) / _ 1-800-328-7171
rf4'l4;S.:`;A7.I().V4L APS International Plaza
\ 7800 Glenroy Road
.`u0144',, Minneapolis,MN 55439-3122
APS File N: 125367-0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Ir_ __ __. -_. _ -- — —_______I Service of Process on:
UDREN LAW OFFICES I —Paul Blackburn,aka Paul G.Blackburn
Ms.Henni Crommarty Court Case No.Cumberland Co 13-2111 Civil
II 1 Woodcrest Rd.,Ste.200 I
Cherry Hill,NJ 08003-3620 1
Customer File: N12041104-12
State of: t' Ir"') .4..11.-6:0 .., _ L__ •. —-- — — � _ _ _. _ _ _ _ _ � _ _ _ _ .. � _ _
County of:4L111rMa• '• *1
Name of Server: <Z , 3- ./alt ,undersigned,being duly sworn,deposes and says
that at all times mentioned herein re was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul Blackburn,aka Paul G.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates(TimdAddress Atteapted:_2077D Raleigh Road,Hummelstown,PA 17036
Reason for Non-Service: q/jab 3 T/i zo_A" _t;V An(ws,. el AZ501 r
Dates�gnetAddress Attempted: t/�3 it �3 Am .�foh t t�.rr fl a.;. •,.• C VD C8 at Li
f rM
Reason for Non-Service: et?t Ire SIFe)f( ( a c)rt s1 F16 ��1,,17; th eie�- /r$ t , /'tLee)em e
,p /at
DatestTime/Address Attempted: CA-7h3 i 5 /S I{s1 ' s ol.s w;it Vt'in o/ cL./i) '7
Reason for Non-Service- to — r[31 titJ O u1 r 4?.,, o`t a if / 111 st()t A c c
Based upon the above stated facts, Afant believes t• •e en.. t is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury • . abed : cm t• . fo me this
tha a foregoi g is true and correct_ ,; �{20 �f
75
,nature of Server Ilk' No e'��� "mmissi•' i -•
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal EXHIBIT A
14.Michelle Guyton,Notary Public
Carlisle Born,Clrnbedand County
My Concision Expires July 9,2016
oiment,Pere t'Lv rum ASSOCIATION OF NOTARIES
PNC Bank,National Association,et.al.,Plaintiff(%) Service of Process by
vs• ", APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) - • 4! _ 1-800_328_7171
t V 1 ERA11o!1`..1L APS International Plaza
7800 Gknroy Road
�` :"" '` Minneapolis,MN 55439-3122
APS File it: 123367-0001
r_ __ __�__ __ _ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES —Tara Blackburn,aka Tara A.Blackburn
Ms.Henni Crommartv Court Case No.Cumberland Co 13.2111 Clvil
It l Woodcrest Rd..Ste.200
Cherry Hill,NJ 08003-3620
Customer File: N12041104-12
County of: SIMite 4 41..S*
Name of Server: /�
rem. ,�i t;..L. ,undersigned,being duly sworn,deposes and says
that at all times mentioned herein, a was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Tara Blackburn,aka Tara A.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates/rime/Address Attempted: 2077D Raleigh Road,Hummelstown,PA 17036 /,•�
Reason for Non-Service:.(PICA //'30 A" MO J'+liS f+Jte &kir'
Dates/Thee/Address Attempted: /24/3/3 I is IS AP1 J p&.t i'Ij i IL 1ri/no v.- L.L t a/ t',a11,-,"
y� t
Reason for Noe-Service: /Art ,J't!t a' 1 CD,I� n, 1 e n 1 �o AAA AtaSt- I e 1€ ��tt J;1 jtn i c
Datesrrime/Addreu Attempted: 9! i3 l i 3, s is f� (.0 S l4•'4 d - ±��Jill(()1 l rO
Reese':for Non-Servke:,Co— f c w.c�en.l` O tXX r l tf GS e • ig a ,/'L`,i�C,Y,..e
0 Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subset:• < and •. .rn to ,-fore me this
th: e foregoing is tru and correct. /< ,: •f - 20 e,"
A ,�-
► 1'
Signature ofServer . i, • Pub ����mmi s pines)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
r Notarial seal 1
M.Michelle Guyon,Notary Public
Carlisle Born,Cumberland County
Conunlebn Btpins My 9,2016
Nom,PENNSYLVANIA ASSOCIATION OF NOTARIES
Service of Process by
P1VC teak,National Association,et.al..PlsiatIf!(I) ,;~ APS International,Ltd.
Paul Blackburn aka Paul G.Blackburn.et.al..Defendant(s) _ '_ ._1 1-80D-328-7171
i Nit.R ''''''`;i. APS International Plaza
C AL—,— - 7808 Gleamy Road
R."ti Minneapolis.W1 55438-3122
APS Fite S: 225650.10 1
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Servke of Proem en:
' UDREN LAW OFFICES —Paul Blackburn,aka Paul G.Blackburn
Ms.Heusi Cr inmartv `` Court Case No.Cumberland Co 13-2111 Civil
111 Woodcrost Rd..Ste.200
Cherry Hill,NJ 08003-3620
jCustomer Fite: N12041104-12
Slate of: u i.•A. w •� r. ' s&
County of: •as 1 a • •.5 // f
Name of Server: re& 1- S L tick I t) .undersigned being duly sworn.deposes and says
that at all times mentioned herein.s/he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul Blackburn,aka Paul G.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
DatesfIlmelAddrsss Atrrspted: 823 Anthony Drive,Mechanicsburg,PA 171/50
Reason for Non-Service: /1 /12
DatesR 1 imetAddress Attempted: to /Z' 3a PA
Reason for Noa-5e vicesl•6fts t i':r Or, C a r o
DntcrfflmdAddrw Attempted:, - _
Reason for Non-Service:
-.]Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Su. - • • . '. . .. ,. f• be . me this i n" , ,20 y
pigforegoing is a and correct. •l 'iy 0?6*nature of Server " w'!!ie` (Commission -)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Noeiat Seat
N
cede Bath Cumberland County
Oonvolseloa — _ 9 2016
Pgr015YLVN aA ASSOOMION OF towns
EXHIBIT B
Service of Process by
PP4C Bank,National Association.et.al.,Plaintiff(s) ��' .,, APS International, Ltd.
vs.
Paul Blackburn aka Paul G.Blackburn,et.al.,Detendant(s) • , , 1-800-328-7171
i ti i C aN AT I('':t t APS International Plant
7800 Gleamy Road
• ` „+ Minneapolis.MN 55439-3122
APS File I: 1256804)001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
uDREN Law OFFICES —Tara Blackburn,aka Tara A.Blackburn
Ms.Kenai Crorstnarty Court Case No Cumberland Co 13-2111 Civil
1 t t Woodereat Rd.,Ste.200
E Cherry Hill.NJ 82003-3620
Customer Fite: NI2011104-12 _ J
State of: "Isfaviia �ss,
County o 1
Name of Server: pe_A. - S 1 Gi"((y .undersigned,being duly sworn,deposes and says
that at all times mentioned herein,Sloe was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as;
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Tara Blackburn,aka Tara A.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
uateamardAddress Attempted: 823 Anthony Drive.Aleehanicsbnrg,PA 17050
Ressm for Non-Serrice /
Dates I lmolAddress Attempted: r O J 4/J 13 /Z 2 6++i�1
Reason forNon-ServkG Hos•tr i.T U t: e G Kt
B. rilatelAddress Aaempted:.
Reasaa for Naa.Servke
Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury , 1 . i -, an. •m to before 41,
th: he foregoing is true :nd correct. SAY °f la
. '.Z;� I. ,,
le_ IMF ciummoir
Signature of Server r -Public (Conmissi !roes)
APS International,Ltd.
0„2104 NWEALTH OF PENNSYLVANIA
Nebula!Seal
it Mkhele Qtyton,Notary Public
CM*barq C unbedand Canty
��M t ConIrMSNon ares><dy 9.2016
VYM61/14900SUOa OF 110ThRIES
Service sr Process by
PNC Bank,National Association,et.al..Pialatilf(s) .P,. .ti M'S International, Ltd.
Paul Blackburn aka Pail G.Blackburn.at al.,Defendant(al
-, 1-500-328-7171
APS international Plaza
r 7800 Gleamy Road
Minneapolis.MN 55t39-8I22
APS Fite f: t21S1$94004
_ _ _ — _ _ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process ant
WREN LAW OFFICES —Paul Blackburn,aka Patt!G.Blackburn
Ms.Henn;Crommarty Court Case No.Cumberland Co 13-2111 Civil
t t 1 Woodcreet Rd.,Ste.200
Cherry Hill.Ni 00003-3620
Customer F;ks NI2041104-12_-_!_^
—
State of:_ - - I ss. - - -
County of r _44
i.t
Name of Server (�fed- .i C j .undersigned.being duly sworn.deposes and says
that at all times mentioned bereine was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Paul Blackburn,aka Paul G.fllnckburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is n list of the attempts made to effect service:
nnteslilme/lddrrss:lucmpted:_425 Lamp Post Lane,Camp Hill.PA 17011
Berson for Non-Salim
,
Untesfrime1Address Mirmptrd:Ij1Zrira it f/z.,/ti
Reasoa for lna-Serrirrt ,ll�p#4c Srry`' -L. .! O++/r'ge• Sft i•q�J"r jj , �r' t �`��f'tf� ker,/��sr►�
natr�me&►ddress Auempred: 3 ' At v4 3 T rs g its 44jon% f rOX I`at s t'rfy S+Pc fors Q�n at/er
j� /
Remo for Non.SSersicr: 01:3 +'ice G j?re s5
7. Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this
that he foregoing is true and co ,:y of it f • 2d3
rye ,
SignolureofServer Notary ie� ' •ttmissionl:xpireal
APS International,Ltd.
•
•-1; C r rIG C .1 t
EXHIBIT C
PNC Bank.National Association.et ai..Ptalon(lls) _
vs. 5rrvlce of Process 6�
Paul Blackburn aka Paul G.Blackburn.et al..Defcndant{s) {F� APS International, Ltd.
i ,- h:;`_ 1-800-328-7171
- ~~ APS International Prase
moo Glertroy Road
�' Minaeapeits.MN 55439-31 22
— -- —� AFFIDAVIT OF DUE APSFite at t2f564-at;et
-, AND DILIGENT ATTEMPT
UDREN LAW OFFICES r Service of Proven an:
M.Henri Crommartr --Tam Slat l.'lwra,aks Tara A.Blaeltbara
Court Case No.Camber)and Co 15-211 I Civil
I I1 Woodteesr Rd.,Ste,200
Cherry dill,NJ 080030
Customer Fik: Nl204JZ04-12
Stan:of: - _ - - - - - - - - -
County of: 9
Name of Server. are, 3-4, undersigned being duly sworn.deposes and says
that at all times mentioned herein, was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents o s+�
n
Tara Blackburn,aka Tara A.Blackburn
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
natestTiarefAddrtss Attempted 42S Lamp Post Lane.Camp Hill,PA 17011
Reason far Nan.Sroire: JJ
Datesll ime/Addrtss Attempted: I I h e m s'S 1i t:/It A1� / t
Reason tor loa-Smirt: -Sp.14 s-►r'4-L^ tf Qr+mi ()tot,- SI'or I,�7•v A1 i '/ . it GA'PIO 144 s ,)erh
Datts/limr/Addrrs+Altrmpted: 1 1 c...( 3 Z r'o C .+ G - a • r E f t, AS G p
Reston for Nun-Sevier. L)o eS its•i- o U'' s et i]s.— ii, 4 dAr4 AS
. _ Based upon the above stated facts.Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this 7
that the foregoin�is true ,nd correct. 1 day•f .
Az, ,
Signature of Server _ Notary Public (Commission Expires)
APS International,Ltd.
:nr-z:. -,et= ;:,Pre 4- PUTAI: 4
.;r t:I'.3'1',::f.6.�'.Y
Commonwealth County of Cumberland Court of Common Pleas
Of Pennsylvania Civil Division
Plaintiff(s)
PNC Bank, NA
vs
Defendant(s)
Paul G. Blackburn, Tara A.Blackburn
AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY
I, Randy Sheppard II, do hereby swear and affirm that I made the following
diligent search and inquiry on defendant, Tara A. Blackburn:
1. On November 21, 2013, I conducted a Skip Trace, the results of which indicated
the defendant's current residence is 425 Lamp Post Lane, Camp Hill, PA, 17011.
2. On November 21,2013,I conducted an Internet search for the Death Records of
the Defendant,the results of which indicated that the defendant is not deceased.
3. On November 21, 2013, I conducted an Internet search for the Voter Registration
Records of the Defendant, the results of which indicated that the defendant is a
registered voter at the address of 2077D Raleigh Road, Hummelstown, PA,
17036.
4. On November 21, 2013, I conducted an Internet search for the Motor Vehicle
Records of the Defendant, with no results obtained from the search.
5. On November 21, 2013, I conducted an Internet search of Facebook, Twitter,
Yahoo!, Google and Bing with no results obtained from the search.
6. On November 21, 2013 at 6:08pm I placed a phone call to defendants neighbor,
Mary Alaimo (717-761-8321), of 426 Lamp Post Lane, Camp Hill, PA, 17011 to
inquire about defendant's last known address. There was no answer.
7. On November 21,2013 at 6:09pm I placed a phone call to defendant's neighbor,
R. Klein(717-763-1557), of 424 Lamp Post Lane, Camp Hill, PA, 17011 to inquire
about defendant's last known address. There was no answer.
I SOLEMNLY swear and affirm that the foregoing statements are true and correct
to the best of my knowledge,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.
11 /21 /2013 � �y:P/ .
Date Randy Sheppard II
Skip Trace Manager
De Novo Attorney Services,Inc.
P.O. Box 20215
Baltimore, MD 21284
Our Job Serial Number: NOV-2013007569
Ref 12041104-12
EXHIBIT D
T....TT. OL°I A A LOL.t1 A'1.....CCI1C1 C..O..°111A^7L9CLR A
Commonwealth County of Cumberland Court of Common Pleas
Of Pennsylvania Civil Division
Plaintiffs)
PNC Bank, NA
vs
Defendant(s)
Paul G. Blackburn, Tara A. Blackburn
AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY
I, Randy Sheppard II, do hereby swear and affirm that I made the following
diligent search and inquiry on defendant, Paul G. Blackburn:
1. On November 21, 2013, I conducted a Skip Trace, the results of which indicated
the defendant's current residence is 425 Lamp Post Lane, Camp Hill, PA, 17011.
2. On November 21, 2013, I conducted an Internet search for the Death Records of
the Defendant,the results of which indicated that the defendant is not deceased.
3. On November 21, 2013, I conducted an Internet search for the Voter Registration
Records of the Defendant, the results of which indicated that the defendant is a
registered voter at the address of 2077D Raleigh Road, Hummelstown, PA,
17036.
4. On November 21, 2013, I conducted an Internet search for the Motor Vehicle
Records of the Defendant, with no results obtained from the search.
5. On November 21, 2013, I conducted an Internet search of Facebook, Twitter,
Yahoo!, Google and Bing with no results obtained from the search.
6. On November 21, 2013 at 6:o8pm I placed a phone call to defendant's neighbor,
Mary Alaimo (717-761-8321), of 426 Lamp Post Lane, Camp Hill, PA, 17011 to
inquire about defendant's last known address. There was no answer.
7. On November 21, 2013 at 6:o9Pm I placed a phone call to defendant's neighbor,
R. Klein(717-763-1557),of 424 Lamp Post Lane, Camp Hill, PA, 17011 to inquire
about defendant's last known address. There was no answer.
I SOLEMNLY swear and affirm that the foregoing statements are true and correct
to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 PA. C.S. Section 4904
relating to nnsworn falsification to authorities.
11 /21 /2013 /1$.166
Date Randy Sheppard II
Skip Trace Manager
De Novo Attorney Services, Inc.
P.O. Box 20215
Baltimore, MD 21284
Our Job Serial Number: NOV-2013007568
Ref 12041104-12
n in. OA..t t..ol_ocno..LltnnaocI 1n9A AOOC..19C^1cnc..
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: December 9,2013
Camp 1101,PA,17011 CASE No.: 1204110442
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Paul Blackburn a/k/a Paul G.Blackburn
LAST KNOWN ADDRESS:425 Lamp Post Lane,Camp Bill,PA 17011
NOTE: The name and last known address are-required for change of address information. The name,if known,and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Paul Blackburn a/k/a Paul G.Blackburn
4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 13-2111
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrest Corporate Center
111 Woodcrest • I=a
Cherry -_.- :.r w Jersey 0800
1
B
B . `i j.a4/i ,/t ! i_A
*********************************************** *************************************
POST OFFICE USE ONLY
NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS
VNot known at address given No such number AFFIX POSTMARK HERE
Left no forwarding .No change of address on file
No such street GOOD AS ADDRESSED
1SEC2 20-
EXHIBIT E
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: December 9,2013
Camp Hill,PA,17011 CASE No.:12041104-12
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Tara Blackburn a/k/a Tara A.Blackburn
LAST KNOWN ADDRESS:425 Lamp Post Lane,Camp Hill,PA 17011
NOTE: The name and last known address are required for change of address information. The name, if brown,and post
dice box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(dX6Xii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(dX1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Tara Blackburn a/lc/a Tara A.Blackburn
4. The Court in which the case has been or will be heath: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 13-2111
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
�T
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES ;
INCLUDING A FINE OF UP 70$10,000 OR IMPRISONMENT OR(2)710 AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THANFIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
`4
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrkt.Qorporate Center
111 Woodcreaa,
f/ Hill, ::003
• . Al ,Ala ,/t 1 J.07
-I-1177 - !rl S.-
*********************************************** **************************************
POST OFFICE USE ONLY
NEW ADDRESSBOXHOLDER'S NAME AND STREET ADDRESS
Not known at address given No such number AFFIX POSTMARK HERE
Left no forwarding 7 No change of address on file
No such street _GOOD AS ADDRESSED
411r, ILL pi
Dkc(' ,,l� -'
1 .
1/4v9\
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: December 9,2013
Hummelstown,PA,17036 CASE No.: 12041104-12
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Tara Blackburn a/k/a Tara A.Blackburn
LAST KNOWN ADDRESS:2077D Raleigh Road,Hummelstown,PA 17036
NOTE: The name and last known address are required for change of address information. The name, if known,and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(dX6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: tto y at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Tara Blackburn a/k/a Tara A.Blackburn
4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 13-2111
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAINAND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITHACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is trite and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,P .
Woodcrest Corpora = �
111 Woodcrest • ..
Cherry Hill, Jersey 08003
1 B : ■ 1I I V .t. i
********************************************** ***************************************
POST OFFICE USE ONLY
NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS
Not known at address given No such number AFFIX POSTMARK HERE
Left no forwarding No change of address on file
No such street GOOD AS ADDRESSED
,kMELSO
.�. pp 17036 11c
DEC 3 1 2013 Mal
G
414
Stay"
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: December 9,2013
Hummelstown,PA,17036 CASE No.: 12041104-12
Please furnish the new address or the name and street address(if a boxholder)for the following ' ease take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME:Paul Blackburn a/k/a Paul G.Blackburn
LAST KNOWN ADDRESS:2077D Raleigh Road,Hummelstown,PA 17036
NOTE: The name and last known address are required fir change of address information. The name,if known,and post
office box address are required for boxholder informat ion.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Paul Blackburn a/k/a Paul G.Blackburn,
4. The Court in which the case has been or will be heard: Cumber . '• County Pennsylvania
5. The docket or other identifying number if one has been issued: 13-2111
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrest Corporate Cen
'I 111 Woodcrest Road
Cheny Hill,New J 0- .:003
Ilf
* t,'T pecne ist
*s**•*******••*****•****• *$***•****************** ***********************************
POST OFFICE USE ONLY
NEW ADDRESSBOXHOLDER'S NAME AND STREET ADDRESS
Not known at address given _No such number AFFIX POSTMARK HERE
_Left no forwarding _No change of address on file
No such street GOOD AS ADDRESSED
.0S 1V400„
Mar e
£WZ l E 330
,ti419eoLti sit' 4'
QtriStt
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
CUMBERLAND County
v.
Paul Blackburn a/k/a Paul G. Blackburn;
Tara Blackburn a/k/a Tara A. Blackburn NO. 13-2111 Civil
Defendant(s)
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule the plaintiff may move
the court for a special order directing the method of service. The motion shall be
accompanied by an affidavit stating the nature and extent of the investigation
which has been made to determine the whereabouts of the defendant and the
reasons why service cannot be made.
NOTE: A sheriffs return of "not found" or the fact that a defendant has moved
without leaving a new forwarding address is insufficient evidence of concealment.
Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended
adoption mailed to last known address requires a "good faith effort" to discover
the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976).
An illustration of a good faith effort to locate the defendant includes (1) inquiries
of postal authorities including inquiries pursuant to the Freedom of Information
Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and
employers of the defendant and (3) examinations of local telephone directories,
voter registration records, local tax records, and motor vehicle records.
As set forth in the Returns of Service marked Exhibits "A", "B" and "C" the Sheriff and/or
Process Server has been unable to serve the following Defendant(s) at their last known addresses.
A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced
by the attached Affidavit of Good Faith Investigation marked Exhibit "D".
Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"E".
WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale
upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
rfr:
Attorne is for Plaintiff
Jordan David, Esquire
PA ID #: 311968
VERIFICATION
The undersigned hereby states that he/she is the Attorney for
the Plaintiff in this action, that he/she is authorized to make
this Verification, and that the statements made in the foregoing
MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are
true and correct to the best of his/her knowledge, information and
belief.
The undersigned understands that this statement herein is made
subject to the penalties of 18 Pa.C . S . Sec 4904 relating to unsworn
falsification to authorities .
Date : p1 *12
UDREN LAW OFFICES, P .C .
I d
i
Attor eys for Plaintiff
Jordan David, Esquire
PA ID #: 311968
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
CUMBERLAND County
v.
Paul Blackburn a/k/a Paul G. Blackburn;
Tara Blackburn a/k/a Tara A. Blackburn NO. 13-2111 Civil
Defendant(s)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on
each of the attached parties or their attorneys this3OTH day of December, 2013.
Udren Law Offices, P.C.
Attorney for Plaintiff
By:
ordan David, Esquire
PA ID #: 311968
SERVICE LIST
CUMBERLAND COUNTY, PENNSYLVANIA
CCP. No. Docket Number: 13-2111 Civil
NAME: PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
MAILING ADDRESS: 2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
NAME: TARA BLACKBURN A/K/A TARA A. BLACKBURN
MAILING ADDRESS: 2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
PNC Bank,National Association 7,7
Plaintiff
v. NO. 13-2111 Civil `
Paul Blackburn a/k/a Paul G. Blackburn;
Tara Blackburn a/k/a Tara A. Blackburn
Defendant(s)
ORDER
AND NOW, this 4' day of 94-w"7 , 20 '1 , upon consideration of Plaintiffs Motion
and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that
service of the Notice of Sale on Defendant(s), Paul Blackburn a/k/a Paul G.Blackburn, Tara
Blackburn a/k/a Tara A. Blackburn, shall be complete when Plaintiff or its counsel or agent
has served true and correct copies of the Notice of Sale by posting the mortgage premises at:
823 ANTHONY DRIVE
MECHANICSBURG, PA 17050
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
TARA BLACKBURN A/K/A TARA A. BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
BY THE COURT:
J.
fr24 .11_ErL
JoilaibtS1201.0L es.„.
.
/Am
-
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff Cumberland County
v. c--3
PAUL BLACKBURN A/K/A PAUL G. NO. 13-2111 Civil
BLACKBURN; «°CO -n
rn pi
TARA BLACKBURN A/K/A TARA A. C
BLACKBURN; et al
Defendant(s) � � " `
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date: A131/4
UDREN LAW OFFICES,P.C.
011 /
BY: r f
Attorney for • ainti
3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
PNC Bank,National Association " '
Plaintiff r , :� r>,
v. NO. 13-2111 Civil r- .�
Paul Blackburn a/k/a Paul G.Blackburn; r-
Tara Blackburn a/k/a Tara A.Blackburn c , -?
Defendant(s)
ORDER
AND NOW,this L. day of 9aw•7 ,201 / ,upon consideration of Plaintiffs Motion
and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that
service of the Notice of Sale on Defendant(s), Paul Blackburn a/k/a Paul G.Blackburn,Tara
Blackburn a/k/a Tara A.Blackburn,shall be complete when Plaintiff or its counsel or agent
has served true and correct copies of the Notice of Sale by posting the mortgage premises at:
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN,PA 17036
TARA BLACKBURN A/K/A TARA A.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
BY THE COURT:
J.
mai
Jo 1 oL en-5?
�lL/�y
. 1 , Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s) vv1,.1('T!(\ APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) a (*4 " \/\ 1-800-328-7171
I ,ti's tyTEti NAT loNgL ; APS International Plaza
--`-1 7800 Glenroy Rd.
Minneapolis,MN 55439-3122
APS File#: 127177-0001
AFFIDAVIT OF SERVICE -- Individual
1---- Service of Process on:
UDREN LAW OFFICES --Paul Blackburn,aka Paul G. Blackburn by posting
Ms.Henni Crommarty Court Case No.Cumberland Co 13-2111 Civil
Ill Woodcrest Rd..Ste.200
Cherry Hill,NJ 08003-3620
State of: ` \V y �,1ss.
County of: iit•
Name of Server: Kl Vnit''hPIkto .(....(1.)u. 4-dam-undersigned, being duly sworn,deposes and says
that at the time of ervice, s/he was of legal age and was notra party to this action;
Date/Time of Service: that on the I[ ay of A \ .20 I-t ,at3' I`1 o'clock M
Place of Service: at 823 Anthony Drive , to Mechanicsburg,PA 17050
Documents Served: the undersigned served the documents described as:
Notice of Sheriff's Sale of Real Property w/Order
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Paul Blackburn,aka Paul G. Blackburn by posting
Person Served,and
Method of Service: - By personally delivering them into the hands of the person to be served.
XBy delivering them into the hands of -\ `t .a person
of suitable age, who verified,or who upon questioni ated. that he/she resides with
Paul Blackburn,aka Paul G. Blackburn by posting
at the place of service, and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex ; Skin Color ; Hair Color ; Facial Hair
Approx. Age ; Approx.Height : Approx. Weight
To'tfie,best of my knowledge and b-lief.said person was not engaged in the US Military at
'the-kin-le of service.
Signature of Server: Undersign C .rep nder •e • of perjury Subscribed and sworn to before me this
that the'f• p s,
(I( . . ect. a day . t 20 '
rceptorn
(► ature rver Notary Puu•■is (ommission Expires)
APS International,Ltd. -
PENI\ISYLIANIA
-AIM OF�._..---- Notarial Se^!wry Public
Petits,
Cumberland ntY
T a 1m .,ro, Expire aept 9 2015 TF5
i ,i0 .,nc3� i M TG.�
• • Service of Process by
PNC Bank,National Association.et.al.,Plaintiff(s) ;` �,.- APS International, Ltd.
Paul Blackburn aka Paul C.Blackburn,et.al.,Defendant(s) /' ' , '—� 1 1-800-328-7171
APS 1ST FR ht0Ngi APS International Plaza
7800 Glenroy Rd.
Minneapolis,MN 55439-3122
APS File ti: 1:7177-0001
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES --Tara Blackburn,aka Tara A. Blackburn by posting
Ms.Henni Crommarty Court Case No.Cumberland Co 13-2111 Civil
Ill Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
►— - — _ -- -
State of: eh ,0 ss.
County of:
Name of Server: N I (`(' Came i1P_7-- -��j Y) . undersigned. being duly sworn,deposes and says
that at the time of service, s/he was of legal age and was not a party to this action:
Date/Time of Service: that on the day of ,i .20 , at ,11--\ o'clock M
Place of Service: at 823 Anthony Drive , in Mechanicsburg,PA 17050
Documents Served: the undersigned served the documents described as:
Notice of Sheriff's Sale of Real Property w/Order
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Tara Blackburn,aka Tara A. Blackburn by posting
Person Served,and
Method of Service: By personally delivering them into th s of the person to be served.
- y delivering them into the hands of e+ra� � �ilC' ,a person
of suitable age. who verified,or who upon questionin sated.that he/she resides with
Tara Blackburn,aka Tara A.Blackburn by posting
at the place of service,and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex ; Skin Color : Hair Color : Facial Hair
Approx. Age : Approx.Height : Approx.Weight
r To the best of my knowledge and belief, said person was not engaged in the US Military at
tittle o rvisf. /
Signature of Server: ndersi: a eclares under penalty of .e'F Subscribed and s% o4 to before me this
t •t;t f. eing is`true and correct � 16 day • , ,l L ,20 `1
"Signatu e of er Notary Public (Commission Expires)
APS International, Ltd.
OF PENNSYLVANIA
star'•al Seal
r ,a I.. Peters,Notary Public
Bern,Cumberland County
'c*.,Cry Sept.9,2015
:f,'S',;":n'?N OF NOTARIES
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
I leadin s , udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. CUMBERLAND County
PAUL BLACKBURN A/K/A PAUL G. MORTGAGE FORECLOSURE c2
BLACKBURN, -a= - =-4
TARA BLACKBURN A/K/A TARA A. NO. 13-2111 Civil r -
BLACKBURN, r-r r- — - -
Defendant(s) r— c-
-L Yt
>C)
VERIFICATION OF SERVICE OF NOTICE OF SALE ? ,_ u F
BY CERTIFIED MAIL AND REGULAR MAIL
PURSUANT TO COURT ORDER co =
The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that
pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by
certified mail and regular first class mail as follows:
TO:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
2077D RALEIGH ROAD,HUMMELSTOWN, PA 17036
TARA BLACKBURN A/K/A TARA A. BLACKBURN
2077D RALEIGH ROAD, HUMMELSTOWN, PA 17036
DATE MAILED: January 9,2014
I verify that the statements made herein are true and correct and I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Dated: 2014
UDREN LA yt F CES, P.C.
BY: I ( 1
Attorney for 'lai t
MJU#: 12041104 CASE#: 12041104-12 &„,_kt x
Cintt
,r
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
C
PNC Bank,National Association -±
Plaintiff x_n I `=y ''V. NO. 134111 Civil
Paul Blackburn a/k/a Paul G.Blackburn; rr
Tara Blackburn a/k/a Tara A.Blackburn
Defendant(s)
ORDER
AND NOW,this G' day of 9 7 ,20 1'1 ,upon consideration of Plaintiffs Motion
and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that
service of the Notice of Sale on Defendant(s), Paul Blackburn a/k/a Paul G.Blackburn,Tara
Blackburn a/k/a Tara A.Blackburn,shall be complete when Plaintiff or its counsel or agent
has served true and correct copies of the Notice of Sale by posting the mortgage premises at:
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN,PA 17036
TARA BLACKBURN A/K/A TARA A.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
BY THE COURT:
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UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
.leadin•s • udren.com
PNC Bank,National Association COURT OF COMMON PLEAS 1
Plaintiff CIVIL DIVISION
V. Cumberland County rn in q .,,,,-31::,
U�T� C.D
PAUL BLACKBURN A/K/A PAUL G. MORTGAGE FORECLOSURE -< ' +i
BLACKBURN, d r� - ct
TARA BLACKBURN A/K/A TARA A. NO. 13-2111 Civil .c, c
BLACKBURN, --- s'
Defendant(s) ';''= n? 1
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff,by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as
Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date
of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date
appearing on the attached Return Receipt,which was signed for by Defendant(s)on the date specified on
the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B".
3. If a Return Receipt is not attached hereto,then service was by personal service on the date
specified on the attached Return of Service, attached hereto as Exhibit "B".
4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as
Exhibit"B".
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
I verify that the statements made in this affidavit are true and correct to the best of my
information and belief.I understand that false statements herein are made subject to the penalties
of 18 Pa.C.S.sec.4904 relating to unsworn falsification to authorities.
Dated: a,1 1 )L UDREN LAW OFFICES,P.C.
BY: , �
Attorneys for •' . !i(i
MJU#: 12041104 CASE#: 12041104-12
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin•s ' udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. Cumberland County
Paul Blackburn a/k/a Paul G.Blackburn MORTGAGE FORECLOSURE
Tara Blackburn a/k/a Tara A. Blackburn
Defendant(s) NO. 13-2111 Civil
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
PNC Bank,National Association, Plaintiff in the above action,by its undersigned attorney,
upon information and belief,Udren Law Offices, P.C., sets forth, as of the date the Praecipe for
the Writ of Execution was filed, the following information concerning the real property located
at:
823 Anthony Drive, (Hampden Township), Mechanicsburg,PA 17050
1. Name and address of Owner(s) or reputed Owner(s):
Paul Blackburn a/k/a Paul G. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
Paul Blackburn a/k/a Paul G. Blackburn
823 Anthony Drive, (Hampden Township),
Mechanicsburg, PA 17050
Tara Blackburn a/k/a Tara A. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
Tara Blackburn a/k/a Tara A. Blackburn
823 Anthony Drive, (Hampden Township),
Mechanicsburg, PA 17050
2. Name and address of Defendant(s) in the judgment:
Paul Blackburn a/k/a Paul G. Blackburn
2077D Raleigh Road
Hummelstown,PA 17036
Paul Blackburn a/k/a Paul G. Blackburn
823 Anthony Drive, (Hampden Township),
Mechanicsburg,PA 17050
Tara Blackburn a/k/a Tara A. Blackburn
2077D Raleigh Road
Hummelstown, PA 17036
Tara Blackburn a/k/a Tara A.Blackburn
823 Anthony Drive, (Hampden Township),
Mechanicsburg, PA 17050
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Jr Lien Holders -None
4. Name and address of the last recorded holder of every mortgage of record:
PNC Bank,National Association
3232 Newmark Drive
Miamisburg, OH 45342
Sr Mortgage Holders -None
Susquehanna Valley FCU
3850 Hartzdale Drive
Camp Hill, PA 17011
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders-None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA,Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
823 Anthony Drive
Mechanicsburg, PA 17050
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:
Federal Tax Lien Holders-None
Condo/Homeowners Association-None
I verify that the statements made in this affidavit are true and correct to the best of my
information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
DATED: )3 1(N UDREN LA OFFICES, P.C.
BY: r
Attorney for ai ti
MJU#: 12041104 CASE#: 12041104-12
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
' ` an , ahona ssociation COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. Cumberland County
PAUL BLACKBURN A/K/A PAUL G.
BLACKBURN; MORTGAGE FORECLOSURE
TARA BLACKBURN A/K/A TARA A.
BLACKBURN;
Defendant(s) NO. 13-2111 Civil
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
OWNER(S): PAUL BLACKBURN A/K/A PAUL G. BLACKBURN;
TARA BLACKBURN A/K/A TARA A. BLACKBURN;
PROPERTY: 823 Anthony Drive, (Hampden Township), Mechanicsburg, PA 17050
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale
on 12/04/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners
Hearing Room,2nd Floor,Carlisle,PA 17013. Our records indicate that you may hold a
mortgage or judgment on the property, which will be extinguished by the sale. You may wish to
attend the sale to protect your interests.
The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30
days after sale. Distribution will be made in accordance with the schedule unless exceptions are
filed thereto within 10 days after the filing of the schedule.
MJU#: 12041104 CASE#: 12041104-12
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UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
•leadin s udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. CUMBERLAND County
PAUL BLACKBURN A/K/A PAUL G. MORTGAGE FORECLOSURE
BLACKBURN,
TARA BLACKBURN A/K/A TARA A. NO. 13-2111 Civil
BLACKBURN,
Defendant(s)
VERIFICATION OF SERVICE OF NOTICE OF SALE
BY CERTIFIED MAIL AND REGULAR MAIL
PURSUANT TO COURT ORDER
The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that
pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by
certified mail and regular first class mail as follows:
TO:
PAUL BLACKBURN A/K/A PAUL G. BLACKBURN
2077D RALEIGH ROAD,HUMMELSTOWN,PA 17036
TARA BLACKBURN A/K/A TARA A. BLACKBURN
2077D RALEIGH ROAD,HUMMELSTOWN,PA 17036
DATE MAILED: January 9,2014
I verify that the statements made herein are true and correct and I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to
authorities.
Dated: WO. v ,2014
UDREN LA OF CES,P.C.
BY: 11111 '
Attorney for 'la'
.
MJU#: 12041104 CASE#: 12041104-12 %Amu& ( pl
EnhEIN
;r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
_ - �� ?
. PNC Bank,National Association ' -!
Plaintiff a=rt, „ I
v. NO. 13-2111 Civil �P r'_
Paul Blackburn a/k/a Paul G.Blackburn; r
• Tara Blackburn a/k/a Tara A.Blackburn c, ? <_ ;•
Defendant(s)
ORDER
AND NOW,this `' day of 94...91 ,20)I ,upon consideration of Plaintiffs Motion
and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that
service of the Notice of Sale on Defendant(s),Paul Blackburn a/k/a Paul G.Blackburn,Tara
Blackburn a/k/a Tara A.Blackburn,shall be complete when Plaintiff or its counsel or agent
has served true and correct copies of the Notice of Sale by posting the mortgage premises at:
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN
2077D RALEIGH ROAD
• HUMMELSTOWN,PA 17036
TARA BLACKBURN A/K/A TARA A.'BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN, PA 17036
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UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PNC Bank,National Association COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff Cumberland County
v.
PAUL BLACKBURN A/K/A PAUL G. NO. 13-2111 Civil
BLACKBURN;
TARA BLACKBURN A/K/A TARA A.
BLACKBURN; et al
Defendant(s)
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date: vi
UDREN LAW OFFICES,P.C.
BY: IA
Attorney for ainti'
Amato- e-tiow
C
EKYODE
it
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
PNC Bank,National Association —,
Plaintiff x r= ; ;;
v. NO. 13-2111 Civil �? ` r
Paul Blackburn a/k/a Paul G.Blackburn; r: a,
Tara Blackburn a/k/a Tara A.Blackburn _a
Defendant(s) I '�
ORDER
AND NOW,this ` day of 9aw•7 ,20''1 ,upon consideration of Plaintiffs Motion
and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that
service of the Notice of Sale on Defendant(s), Paul Blackburn a/k/a Paul G.Blackburn,Tara
Blackburn a/k/a Tara A.Blackburn,shall be complete when Plaintiff or its counsel or agent
has served true and correct copies of the Notice of Sale by posting the mortgage premises at:
823 ANTHONY DRIVE
MECHANICSBURG,PA 17050
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
PAUL BLACKBURN A/K/A PAUL G.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN,PA 17036
TARA BLACKBURN A/K/A TARA A.BLACKBURN
2077D RALEIGH ROAD
HUMMELSTOWN,PA 17036
BY THE COURT:
r r
�.Jb 10 eS9•
ly
\Atli )111
1 Service of Process by
PNC Bunk,National Association,et.al.,Plaintiff(s) 1`4,,ncrrJ APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn,et.al.,Defendant(s) /"i a,. �/ 1-800-328-7171
.1YS INTERNATIONAL 1' APS International Plaza
7800 Glenroy Rd.
�� Minneapolis,MN 55439-3122
APS File#: 127177-0001
_ AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES —Paul Blackburn,aka Paul G.Blackburn by posting
Ms.Henni Crommarty Court Case No.Cumberland Co 13-2111 Civil
I 1 1 Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
TA
State ot: ` \N) ► 0 ss.
County of: A. " . ‘._• I �
Name of Server: M. V tI 11 C9 Tl' kto_ &A\.,4 -undersigned,being duly sworn,deposes and says
that at the time of ervice, s/he was of legal age and was not a party to this action:
Date/Time of Service: that on the 10 ay of� L.tc ( \ .20 14_,at S' I`\o'clock M
Place of Service: at 823 Anthony Drive , In MechanicsburgJA 17050
Documents Served: the undersigned served the documents described as:
Notice of Sheriff's Sale of Real Property w/Order
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Paul Blackburn,aka Paul G. Blackburn by posting
Person Served,and
Method of Service• By personally delivering them into the hands of the person to be served.
. XBy delivering them into the hands of r--- A-% 0 a person
of suitable age,who verified,or who upon questioni ated.that he/she resides with
Paul Blackburn,aka Paul G.Blackburn by posting
at the place of service,and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex ; Skin Color ; Hair Color ; Facial Hair
Approx.Age ; Approx.Height : Approx. Weight
- best of my knowledge and b-lief; said person was not engaged in the US Military at
theyii4e of service.
1,
Signature of Server: Undefsl r • , c .re• nder .e . of perjury Subscribed and sworn to before me this
gn
/Maybe/fr. :./ e • • ect. day • i .V ,20 '—\
C 1
'LL /
. ature •'erver Notary PubJiic ( mmission Expires)
APS International,Ltd.
MMORV`'Ehi Of PEBN5YLV
co P4M P'
bpeterl rotary public
�'atrsrnie L.P£a/.gland Courts
carts: F3oro, tres Sept.9,20'15
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t tv Rirnl".a51Ur4 f° 118 I OF N .•
'�� et7�A?Stith r � n , n
Service of Process by
- PNC Bank,National Association.et.al.,Plaintiff(s) /�—�
vs. /�;�� �'/,�\ APS International, Ltd.
Paul Blackburn aka Paul G.Blackburn.et.al.,Defendant(s) / '(. ��� 1 1-800-328-7171
APS IM1 R�ATIONgi APS International Plaza
,'-;-AkitznI/97 78 .
3iinneapolis00 Glenroy,MRdN 55439-3122
APS File#: 127179.0001
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES - I --Tara Blackburn,aka Tara A. Blackburn by posting
Ms.Henni Crommarty
Court Case No.Cumberland Co 13-2111 Civil
I I 1 Woodcrest Rd..Ste.200
Cherry Hill,NJ 08003-3620
State of: S s,_. , ,. Na`am ss.
County of: A6. liffla
1
Name of Server: N fn ci-v t P. ya . undersigned, being duly sworn,deposes and says
that at the time of service,s/he was of legal age and was notta party to this action:
fs �
Date/Time of Service: that on the w day of . 0 CU i i
&(� .20 ,at _A o'clock M
Place of Service: at 823 Anthony Drive , in Mechanicsburg,PA 17050
Documents Served: the undersigned served the documents described as:
Notice of Sheriff's Sale of Real Property w/Order
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Tara Blackburn,aka Tara A.Blackburn by posting
Person Served,and
By personally delivering them into th s of the
Method of Service: person to be served.
_ y delivering them into the hands of a r# f -\i1•► ,a person
of suitable age. who verified,or who upon questionin'4 ated,that he/she resides with
Tara Blackburn,aka Tara A.Blackburn by posting
at the place of service,and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex ; Skin Color ; Hair Color : Facial Hair
Approx. Age : Approx.Height ; Approx.Weight
r 1 To the best of my knowledge and belief,said person was not engaged in the US Military at
ti e of ervise.
Signature of Server: ndersi: ea •eclares under penalty of/e.r Subscribed and s% o to before me this ,
t a t,t - fa eg•ing is true and correct , 11 day • , ,/, ,20 i"1
Air, Lk 4 ////i 'l1Z l�
— Signatu •of''"'der Notary Publi (Commission Expires)
APS International, Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Tas;mfe i...Peters,(Votary Public l�'nr+��+,; n 1
r„„;1:;,:s tiara,Cumberland County l I 1 Z
,;,: e,;k;r;tssion 1'xplres Sept.9 2015 —,(p,1..:Li ;}J.. '1
,-, "-s.' \,4,R VNOCTATION of NOTARIES
r ,
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff
9{°CM')to rE PROTHONOTARY
ow
Jody S Smith "€`Y
Chief Deputy >e . 20 14 NAY -6 Pu 2: 01
Richard W Stewart CUMcERLAFiD COUNTY
Solicitor OPNCE' I"r "R'r PENNSYLVANIA
PNC Bank National Association
vs. Case Number
Tara Blackburn a/k/a Tara A. Blackburn (et al.) 2013-2111
SHERIFF'S RETURN OF SERVICE
08/09/2013 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: Tara Blackburn, a/k/a Tara A. Blackburn, but was unable to
locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the
within Real Estate Writ, Notice and Description, in the above titled action, according to law.
08/09/2013 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: Tara Blackburn, a/k/a Tara A. Blackburn, but was unable to
locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the
within Real Estate Writ, Notice and Description, in the above titled action, according to law.
09/30/2013 06:57 PM -Deputy Shawn Gutshall, 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 823 Anthony Drive, Hampden -Township,
Mechanicsburg, PA 17050, Cumberland County.
10/23/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Dauphin County upon Paul Blackburn, a/k/a Paul G. Blackburn, personally, at the Dauphin County
Sheriffs Office, 101 Market Street, Room 104, Harrisburg, PA 17101 on 10/8/13 at 1612 hrs. So
Answers: Megan Tritt, Deputy Sheriff.
10/23/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Dauphin County upon Tara Blackburn, a/k/a Tara A. Blackburn, personally, at the Dauphin County
Sheriffs Office, 101 Market Street, Room 104, Harrisburg, PA 17101 on 10/8/13 at 1612 hrs. So
Answers: Megan Tritt, Deputy Sheriff.
11/22/2013 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 2/5/2014
01/08/2014 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 3/12/2014
03/12/2014 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 March 12, 2014 at 10:00
a.m. He sold the same for the sum of$ 5,000.00 to Attorney Karl Ledebohm, on behalf of Federal
National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$
04/11/2014 Proposed Schedule Of Distribution Posted
SHERIFF COST: $1,932.68 SO ANSWERS,
May 01, 2014 RONNY R ANDERSON, SHERIFF
48.00 per'
pd- Co.
. _ v Z._e_
c4, /70
Soteriff,releosoft,
3a5.s3f
On August 9, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA,
Known and numbered as, 823 Anthony Drive,
Mechanicsburg, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
Date: August 9, 2013
• By:
Ct_C_Qk L-116/7
(,.7+
Real Estate Coordinator
_ •
}
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No. 2013-2111 Civil Term dredths (128.71) feet to a point at
the dividing line between Lots 42 and
PNC BANK NATIONAL 43,the place of beginning. Being all
ASSOCIATION of Lot No.42 on Final Plan No.2,Sec-
vs. tion II, Deimler Manor, recorded in
Plan Book 33,Page 10,Cumberland
TARA BLACKBURN a/k/a TARA County Records.
A.BLACKBURN,Paul Blackburn BEING THE SAME PREMISES
a/k/a Paul G.Blackburn WHICH Susan D. Dupree by deed
Atty.:Mark Udren bearing date the 14 day of February,
ALL THAT CERAIN tract or par- 2008 and about to be herewith re-
cel of land with the improvements corded in the Office of the Recorder of
thereon erected situate, lying and Deeds in and for the County of Cum-
being in the Township of Hampden, berland, Pennsylvania, granted and
in the County of Cumberland and conveyed unto Paul G. Blackburn
Commonwealth of Pennsylvania, and Tara A.Blackburn,husband and
more particularly described as fol- wife under and subject to conditions
lows,to wit: and restrictions which now appear
BEGINNING at a point on the of record. Parcel# 10-17-1037-042.
southwestern side of Anthony Drive Being known as:823 Anthony Drive,
(formerly Margaret Road)at the divid- Meciianicsburg, PA 17050 Property
ing line between Lots 42 and 43 of the ID No.: 10-17-1037-042.
hereinafter mentioned plan; thence TITLE TO SAID PREMISES IS
by said dividing line, South fifty- VESTED IN Pual C. Blackburn and
nine(59)degrees three(03)minutes Tara A. Blackburn, husband and
forty-seven (47) seconds West, one wife by deed from Susan D.Dupree,
hundred ninety-six and twenty-eight single individual dated 02/14/2008
hundredths (196.28) feet to a point recorded 02/21/2008 in Deed Book
at the dividing line between Lot 42 Instrument#200805073.
and Lot 53 of the Plan; thence by
said dividing line and the line of Lot
54, North twenty-eight (28) degrees
twenty-six(26) minutes twenty-four
i (24)seconds West,one hundred fifty-
one and twenty-seven hundredths
(151.27)feet to a point on the south-
ern side of Anthony Drive;thence by
the southern side of Anthony Drive by
an arc curving to the right,having a
radius of one hundred forty(140)feet
an arc distance of sixty-seven and
seventeen hundredths (67.17) feet
to a point; thence continuing along
the southern side of Anthony Drive,
North eighty-nine(89)degrees three
(03) minutes six (06) seconds East,
sixty-one and seven tenths(61.7)feet
to a point; thence continuing along
the southern side of Anthony Drive
by an arc curving to the right,having
a radius of one hundred fifty (150)
feet an arc distance of one hundred
twenty-eight and seventy-one hun-
23
The,Patriot-News Co.
<- •?` 2020 Technology Pkwy e atriotNews
Suite,300
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
`b uo! as`xoo.1gs`d'!N JO u ump ao 1•oH
2013-2111 This ad ran on the date(s) shown below:
PNC BANK NATIONAL
ASSOCIATION 10/13/13
V5' / 10/20/13
TARA BLACKBURN A/K/A TARA /
A.BLACKBURN 10/27/13
Paul Blackburn a/k/a Paul G.
4/
Blackburn ...0 •
Atty: Mark Udren
ALL THAT CERTAIN TRACTOR PARCEL
OF LAND WITH THE IMPROVEMENTS
THEREON ERECJU)SITUATE,LYING
AND BEING IN THE TOWNSHIP OF Sworn to .nd subscribed before me this 11 day of November, 2013 A.D.
HAMPDEN,IN THE COUNTY OF
CUMBERLAND , 1 '
ANDCOMMONWEALTH
OF PENNSYLVANIA, MORE CjIt' I,
PARTICULARLY DESCRIBED AS I • ary Pub '
FOLLOWS,TO WIT:
BEGINNING AT A POINT ON THE
SOUTHWESTERN SIDE OF ANTHONY
DRIVE (FORMERLY MARGARET COMMONWEALTH OF PENNSYLVANIA
ROAD) AT THE DIVIDING LINE Notarial Seal
BETWEEN LOTS 42 AND 43 OF THE Holly Lynn Warfel,Notary Public
HEREINAI'1 ER MENTIONED PLAN; Washington Twp.,Dauphin County
THENCE BY SAID D !; LINE, My Commission Expires Dec.12,2016
SOUTH FIFTY-NI 9) DEGREES 15 ,PENNSYLVANIA ASSOCIATION OF NOTARIES
THREE(03) MINUTES FORTY-SEVEN
(47)SECONDS WEST ONE HUNDRED I
NINETY-SIX.AND TWENTY- EIGHT
HUNDREDTHS (196.28). FEET TO
A POINT AT THE DIVIDING LINE
A ncrurvcnt I(IT .0 ANT) MT 5'i r
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff's Deed in which Federal Natl Mtg Assoc is the grantee the same having been sold to said grantee
on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 8th day of
August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number
2111, at the suit of PNC Bank N A against John Matthew Hyams, Charles J DeHart III, Paul Blackburn
aka Paul G Blackburn, Tara Blackburn aka Tara A Blackburn is duly recorded as Instrument Number
201409325.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
, A.D. Q /L/
)2c- -
j' Recorder of Deeds
corde L,. i eds,Cumberland County,Carlisle,PA
My Com vission Expires the First Monday of Jan.2018