HomeMy WebLinkAbout13-2453 For Prothonotary Use Only:
Supreme Court pf' Pe nnsylv
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Cour# f com r P lea s
1?ti �t
Docket No.
=Cum eir and County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required b � law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
t C Lead Plaintiffs Name: Freedom Mortgage Corporation Lead Defendant's Name: Henderson R. Green
T
I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits
0 (check one) ❑ outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? []Yes ® No
A Name of Plaintiff /Appellant's Attorney: McCabe Weisberg and Conway, P.C.
❑ Check here if you have no attorney (a Self- Represented (Pro Sel .Litigant)
T Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
I ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Department of Transportation
❑ Premises Liability (does not include ❑ Statutory Appeal: Other
S mass tort)
E ❑ Slander /Libel/ Defamation ❑ Employment Dispute:
❑ Other: Discrimination
C ❑ Employment Dispute: Other ❑ Zoning Board
T
11 Other
? I
1 0 ❑ Other
MASS TORT
N
❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
B
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑Ejectment ❑ Common Law /Statutory Arbitration
❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Disput ❑ Non- Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
1 PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
i
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑Other:
❑ Medical ❑ Other:
i ❑ Other Professional:
Updated 1/1/20'
tid�Y _3 �dp
HE PRO 1 813
�U�BERC A� ! 1: J
P EjVNS Y� A N1gAd T Y
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID #314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215 ) 790 -1010
Freedom Mortgage Corporation Cumberland County
907 Pleasant Valley Avenue Suite 3 Court of Common Pleas
Mt. Lurel, NJ 08054
V. Number
Henderson R. Green
3105 Old Gettysburg Road
Camp Hill, PA 17011
COMPLAINT IN MORTGAGE FORECLOSURE
s
C,� l
File # 68439
Page I
o
NOTICE AVISO
You have been sued in court. If you wish to defend Le han demandado a usted en la cone. Si usted quiere
against the claims set forth in the following pages, you defenderse de estas demandas ex- puestas en las paginas
must take action within twenty (20) days after this siguientes, usted tiene veinte (20) dias de plazo at partir
complaint and notice are served, by entering a written de la fecha de la demands y la notification. Hace falta
appearance personally or by attorney and filing in asentar una comparencia escrita o en persona o con un
writing with the court your defenses or objections to the abogado y entregar a la corte en forma escrita sus
claims set forth against you. You are warned that if you defensas o sus objeciones a las demandas en contra de
fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la
judgment may be entered against you by the court corte tomara medidas y puede continuar la demanda en
without further notice for any money claimed in the contra suya sin previo aviso o notification. Ademas, ]a
complaint or for any other claim or relief requested by corte puede decidir a favor del demandante y requiere
the plaintiff. You may lose money or property or other que usted cumpla con todas las provisiones de esta
rights important to you. demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU DO NOT USTED LE DEBE TOMAR ESTE PAPEL A
HAVE A LAWYER, GO TO OR TELEPHONE THE SU ABOGADO INMEDIATAMENTE. SI USTED NO
OFFICE SET FORTH BELOW. THIS OFFICE CAN TIENE A UN ABOGADO, VA A O TELEFONEA LA
PROVIDE YOU WITH INFORMATION ABOUT OFICINA EXPUSO ABAJO. ESTA OFICINA LO
HIRING A LAWYER. PUEDE PROPORCIONAR CON INFORMATION
IF YOU CANNOT AFFORD TO HIRE A ACERCA DE EMPLEAR A UN ABOGADO.
LAWYER, THIS OFFICE MAY BE ABLE TO SI USTED NO PUEDE PROPORCIONAR
PROVIDE YOU WITH INFORMATION ABOUT PARA EMPLEAR UN ABOGADO, ESTA OFICINA
AGENCIES THAT MAY OFFER LEGAL SERVICES PUEDE SER CAPAZ DE PROPORCIONARLO CON
TO ELIGIBLE PERSONS AT A REDUCED FEE OR INFORMACION ACERCA DE LAS AGENCIAS
NO FEE. QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
Cumberland County Bar Association HONORARIO REDUCIDO NI NINGUN
32 South Bedford Street HONORARIO.
Carlisle, PA 17013
(800) 990 -9108 Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990 -9108
File # 68439
Page 2
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is Freedom Mortgage Corporation .
2. The Defendant is Henderson R. Green, who is the mortgagor and owner of the mortgage
property hereinafter described, and his /her last -known address is 3105 Old Gettysburg Road, Camp Hill, PA
17011.
3. On September 24, 2009, Henderson R. Green, mortgagor, made, executed and delivered a
mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as
Nominee for Freedom Mortgage Corporation which mortgage is recorded in the Office of the Recorder of
Cumberland County in Mortgage Instrument Number 200934922 ( "the Mortgage "), such Mortgage being
incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.
4. On August 2, 2012, the Mortgage was assigned by Mortgage Electronic Registration
Systems, Inc. as Nominee for Freedom Mortgage Corporation to Freedom Mortgage Corporation, by
Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of
Mortgage Instrument Number 201224710, such Assignment of Mortgage being incorporated herein by
reference pursuant to Rule 1019(g) Pa. R. C. P.
5. The premises subject to said mortgage is described in the legal description attached as
Exhibit "A" and is known as 307 Mount Allen Drive, Mechanicsburg, Pennsylvania 17055.
6. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due July 1, 2012 and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
File # 68439
Page 3
t
7. The following amounts are due on the mortgage:
Principal Balance $ 129,464.09
Interest through May 17, 2013 $ 5,549.34
(Interest due and owing at a variable rate, currently $15.68
per diem)
Late Charges $ 106.48
Attorney's Fee $ 1,650.00
Escrow Advance $ 1,142.21
Property Inspection Fees $ 160.00
GRAND TOTAL $ 138,072.12
The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law,
and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated
prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the
reduction provisions of Act 6, if applicable.
8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice
required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail
with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands in rem Judgment againstthe Defendant in the sum of $138,879.62,
together with interest due and owing at a variable rate, currently $15.68 per diem, and other costs and charges
collectible under the mortgage and for the foreclosure and sale of the mortgaged property.
McCAB , WEISBERG AND CONWAY, P.C.
BY:
[ ] Terrence J cCa e, Esquire [ ] Marc S. Weisberg, Esquire
[ ] Edward D. Conway, Esquire { J Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire
[ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire
[ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire
( ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire
Attorneys for Plaintiff
File # 68439
Page 4
t'
VERIFICATION
The undersigned TIFFANY WONG - does hereby certify that he /she
is Vice President of LoanCare and that LoanCare has been duly nominated and appointed
by Freedom Mortgage Corporation, Plaintiff herein, as its mortgage servicing agent in regard to the
mortgage loan which is the subject of this action. Freedom Mortgage Corporation lacks sufficient knowledge
or information to make this verification but, in its capacity as mortgage servicing agent for Freedom
Mortgage Corporation, LoanCare does have sufficient knowledge or information to do so in accordance with
1024(c)(1) Pa.R.C.P.
I have personal knowledge of all matters stated in the foregoing Complaint and have been authorized
to make this Verification on plaintiff's behalf and do hereby verify that the facts as set forth in the foregoing
Complaint 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. § 4904 relating to unswom falsification to
authorities.
Freedom Mortgage Corporation
By: LoanCare, a Division of FNF Servicing, Inc.,
as attorney in fact under a limited power of attorney
Dated:
me: AN VUONG
Title: T�e 0 ent
Name: Freedom Mortgage Corporation v. Henderson R. Green
File # 68439
Page 5
Exhibit A
All that certain piece of parcel of land situate in Upper Allen Township, County of
Cumberland, and State of Pennsylvania, bounded and described as follows, to wit:
Beginning at a point in the center of a public road, known as Mt. Allen Drive, leading from
U.S. Route 15 to Bowmansdale, said point being South 27 degrees, 45 minutes 00 seconds
East, two hundred fifty -eight and twenty hundredths (258.20) feet and South 09 degrees 00 '
minutes 00 seconds East, ninety and zero hundredths (90.00) feet, from the southwestern
corner of land of L.C' Shumbaugh, Jr.; thence along the center line of said public road,
known as Mt. Allen Drive, South 09 degrees 00 minutes 00 seconds East, ninety and zero
hundredths (90.00) feet to a point at the corner of Lot No. 5 in the Plan of Lots of Paul T.
Shearer and I. S. Eberly known as Reservoir Hill; thence along said Lot No. 5, North 81
degrees 00 minutes 00 seconds East, one hundred forty -two and forty -seven hundredths
(142.47) feet to a point; thence along Lot No. 33 in said Plan of Lots,'North 09 degrees 00
minutes 00 seconds West, ninety and zero hundredths (90.0) feet to a point; thence along
Lot No. 3 in said Plan of Lots South 81 degrees 00 minutes 00 seconds cast, one hundred
forty -two and forty-seven hundredths (142.47) feet to a point in the center line of the public
road aforesaid, the place of beginning.
BEING Lot No. 4 in the Plan of Lots of Paul T. Shearer and I.S. Eberly known as i
"Reservoir Hill ", which
plan is.of record in the Cumberland County recorder of Deeds Office in Plan Book No. 1 l
at Page 8.
** For Informational Purposes Only **
The improvements thereon being known as 307 Mt. Allen Drive, Mechanicsburg, PA 17055
BEING the same property conveyed to Henderson R. Green from Robert E. Himes
and Evalyn A. Himes, by Deed'dated October 26, 2004, and recorded on October 28,
2004, in Book 265, Page 4739, as Instrument No. 2004- 043757, among the Land
Records of Cumberland County, Pennsylvania.
Tax 1D#: 42 -28 -2423 -025
FORM I
Freedom Mortgage Corporation IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBER-LAND COUNTY, PENNSYLVANIA
C.)
VS.
03
rn
Henderson R. Green Civil rn:;a
Defendant
NOTICE OF RESIDENTIAL MORTGAGE FORECL(ft
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,you may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer,you must take the following steps to be eligible for a conciliation
conference.First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal
Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative,you must
promptly meet with that legal representative within twenty(20)days of the appointment date. During that
meeting,you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty(60)days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer,you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However,you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf, If you and your lawyer complete
a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation
Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your tender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE.THIS PROGRAM IS FREE.
Respectfully submitted:
Date [Signature of Counsel for Plaintiff]
68439
Page 1
^ J�
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances to determine possible
options while working with your
Please provide the following information to the best of your knowledge:
CUSTOM ER/PRI MARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes 0 No 0 Listing date: Price$
Realtor Name: Realtor Phone:
Borrower Occupied? Yes 0 No 0
Mailing Address(if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people on household: How long?
CO-BORROWER
Mailing Address(if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people on household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payment Amount$ Included Taxes&Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes 0 No 0
r If yes,provide names, location of court, case number&attorney:
Assets Amount Owed: Value
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1: Model: Year:
Amount owed: Value:
Automobile#2: Model: Year:
Amount owed: Value:
Other transportation(automobiles,boats,motorcycles): Model
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description(not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2nd Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop.payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care/Tuft. Other 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:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance?
Yes❑No❑
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency?
Yes❑No❑
If yes,please indicate the status of those negotiations:
Please provide the following information, if known,regarding your lender or lender's loan servicing company:
Lender's Contact(Name): Phone:
Servicing Company(Name):
Contact: Phone:
I/We, ,authorize the above
named to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We.understand that I/we am/are under no obiligation
to use the services provided by the above named
Borrower Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
f Copy of a current utility bill
f Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement(if property is currently on the market)
3
SHERIFF'S OFFICE OF CUMBERLAND COUNTY,
Ronny R Anderson
s�
Sheriff
xx tr di C-11)j1 ,
Jody S Smith '� �''
Chief Deputy
cou
Richard W Stewart " '" K� �' U .► \
Solicitor �-
r
Freedom Mortgage Corporation
Case Number
vs.
Henderson R Green 2013-2453
SHERIFF'S RETURN OF SERVICE
05/09/2013 07:41 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Henderson R Green, personally,
at 177 Joya Circlem, Harrisburg, PA 17112. Jack Lotwick, Sheriff, Return of Service attached to and
made part of the within record.
05/10/2013 05:23 PM - Ronny R.Anderson, Sheriff, being duly sworn according to law, attempted service to the
Defendant, to wit: Henderson R Green at 307 Mount Allen Drive, Upper Allen, Mechanicsburg, PA 17055.
The address was found to be vacant. Deputies did advise that service was not made at the 3105 Old
Gettysburg Road, Camp Hill address that was provided, that address is an attorney's office who no longer
represents the defendant but did state that the defendant did previously file bankruptcy using that office
and the case number for that bankruptcy filing is#1:12-bk-04340-RNO.
05/13/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Henderson R Green, 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.
SHERIFF COST: $75.25 SO ANSWERS,
May 13, 2013 RON ^ R ANDERSON, SHERIFF
(c)CountySuite Sherit(,Teleosoft,Inc.
u
Shelley Ruhl Jack Duignan
Real Estale 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 FREEDOM MORTGAGE CORPORATION
VS
County of Dauphin HENDERSON R. GREEN
Sheriff s Return
No. 2013-T-1484
OTHER COUNTY NO. 2013-2453
And now: MAY.9, 2013 at 7:41:00 PM served the within COMPLAINT IN MORTGAGE
FORECLOSURE upon HENDERSON R. GREEN by personally handing to HENDERSON R. GREEN
1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making
known to him/her the contents thereof at 177 JOYA CIRCLE HARRISBURG PA 17112
Sworn and subscribed to So Answers,
before me this 10TH day of May, 2013 leAl(—
Sheriff of Da m CountP
By .-
COMMONWEALTH OF PENNSYLVANIA De ty Sheriff
NOTARIAL SEAL Deputy: W CONWAY
Karen M.Hoffman,Notary Public
City of Harrisburg,Dauphin County Sheriffs Costs: $49.25 5/8/2013
My Commission Expires August 17,2014
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintir_ C:"
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 W 4C-')
HEIDI R. SPIVAK,ESQUIRE-ID#74770 CD
MARISA J.COHEN,ESQUIRE-ID#87830 y c n ;
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 T' i
BRIAN T.LAMANNA,ESQUIRE-ID#310321 .G
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH 1.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
Freedom Mortgage Corporation CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V.
Henderson R.Green Number 13-2453
Defendant
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of Plaintiff and against Defendant,Henderson R.Green,in the above-
captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess
damages as follows:
Principal $ 138,072.12
Interest from 05/18/13 to 06/11/13 $ 392.00
Total $ 138,464.12
McCABE,WEISBERG D CO
BY:
[ ]Terrence J. c abe [ ]Marc S. Weisberg,l:sq.
[ J Edward D C sq. [ ]Margaret Gairo, Esq.
[ ]Andrew L.M witz,Esq. [ ]Heidi R. Spivak, Esq.
[ ]Marisa J.C en,Esq. [ ]Kevin T.McQuail, Esq.
[ ] Christine L.Graham,Esq. �rian T. LaManna, E-sq.
[ ]Ann E. Swartz,Esq. [ ]Joseph F. Riga, Esq.
[ ]Joseph I.Foley,Esq. [ ]Celine P. DerKrikorian,Esq.
Attorneys for Plaintiff
AND NOW,this day of :�,2013,Judgment is entered in favor of Plaintiff, Freedom
Mortgage Corporation,and against Defendant,Henderson R.Green,in rem only and not in personain,and damages are
assessed in the amount of$138,464.12,plus interest an osts.
B HE P ON RY:
C4/ ## 013
14 Sg
uF�-i,�P mn,lid
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 2.8009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH 1.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215)790-1010
Freedom Mortgage Corporation CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V.
Number 13-2453
Henderson R.Green
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA:
The undersigned,being duly sworn according to law,deposes and says that the Defendant,Henderson R.Green,
is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the
Servicemembers Civil Relief Act, 50 U.S.C.App. §501,et seq.;and that the Defendant,Henderson R. Green,is over
eighteen(18)years of age,and resides as follows:
Henderson R.Green
177 Joya Circle
Harrisburg,Pennsylvania 17112
McCABE,WEISBERG CONW
SWORN AND SUBSCRIBED
BY:
BEFORE ME THIS�i-L DAY [ ]Terrence J c sq. [ ]Marc S.Weisberg,Esq.
[ ]Edward . onway,E . [ ]Margaret Gairo,Esq.
OF ►l� 12013 [ ]Andrew L.Marko ' z,Esq. [ ]Heidi R. Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq.
Christine L.Graham,Esq. [Brian T.LaManna,Esq,
NOTARY LIC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq.
[ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq.
:110 am eta Attorneys for Plaintiff
City ,i i't� a �, t`it,,l=,u? . ty
Lmy conlrl:sslOn
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.s:, to
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McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J. COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L. GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street, Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
Freedom Mortgage Corporation COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY
V. Number 13-2453
Henderson R.Green
Defendant
AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA:
The undersigned, attorney for the Plaintiff in the within matter,being duly sworn according to law,hereby
depose and say that the last-known mailing address of the Defendant is:
Henderson R.Green
177 Joya Circle
Harrisburg,Pennsylvania 17112
McCABE,WEISBERG C N . ..
SWORN AND SUBSCRIBED
BY:
BEFORE ME THIS DAY [ ]Terrence J. Cab ]Marc S.Weisberg,Esq.
[ ]Edward D. o y, q. [ ]Margaret Gairo,Esq.
OF �vV�s! 2013 [ ]Andrew L.Marko ,t', sq. [ ]Heidi R. Spivak,E:sq.
[ ]Marisa J.Cohe q. [,,]Xe��v!n T.McQuail,Esq.
[ ]Christine L.Graham,Esq. ]Brian T. LaManna, Esq.
NOTAR UB�W [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq.
[ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq.
Attorneys for Plaintiff
COMMONWEALTH OF P�h!NSYLVAN!A
NOTARIAL SEAL
MAIA KUSHICK,!votary Public
01fy of Philade hip,Phila.County
M Commission x fires May 10,2017
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S. WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street, Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1010
Freedom Mortgage Corporation CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V.
Number 13-2453
Henderson R.Green
Defendant
CERTIFICATION
The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes
and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered
against within ten(10)days from the date of said letter in accordance with Rule 237.5 ofthe Pennsylvania Rules of Civil
Procedure. A copy of said letter is attached hereto and marked as Exhibit"A".
McCABE,WEISBERG A
SWORN AND SUBSCRIBED BY:
BEFORE ME THIS i44"-DAY T J M e, s ]Marc S.Weisberg, Esq.
Terrence J.
sq. ]Margaret Gairo, Esq,
Edward D
OF 2013 Andrew L.StrFl�owitz,161q. [ ]Heidi R. Spivak, 'Esq.
Marisa J.Cohen,Esq, [ ] Ke rl T. McQuail, ["sq.
Christine L.Graham,Esq. [,Wrijan T.LaManna, Esq.
NOTARY -PUBZX Ann E. Swartz,Esq. Joseph F. Riga,Esq.
f Joseph 1.Foley,Esq. Celine P. DerKrikorian,Esq.
Attorneys for Plaintiff
1,®RNA P,
ctv,0%?. .
MY
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action,
and that he/she is authorized to make this verification and that the foregoing facts based on the information from the
Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and
correct to the best of his/her knowledge,information and belief and further states that false statements herein are
made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE,WEISBERG A "C.
BY:
[ )Terrenc . e,Esq. [ ]Marc S.Weisberg,I;sq.
[ ]Edw Eway,Esq. [ ]Margaret Gairo, lsq.
An ew .14owitz,Esq. [ ]Heidi R.Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ evm T.McQuail,Esq.
[ ]Christine L.Graham,Esq. Brian T.LaManna,Esq.
[ ]Ann E. Swartz,Esq. [ )Joseph F.Riga,Esq.
{ ]Joseph I.Foley,Esq. [ ]Celine P. DerKrikorian,Esq.
Attorneys for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse,Carlisle,Pennsylvania 1701.3
Curt Long
Prothonotary
May 31, 2013
To: Henderson R. Green
177 Joya Circle
Harrisburg,Pennsylvania 17112
Freedom Mortgage Corporation Cumberland County
vs. Court of Common Pleas
Henderson R. Green
Number 1.3-2453 Civil
NOTICE PURSUANT TO RULE 237.5
NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE NOTIFICACION IMPORTANTE
YOU ARE IN DEFAULT BECAUSE YOU HAVE 17AILED TO ENTER A USTED SE ENCUENTRA 1-1-N ESTADO DE RL'BELDIA POR NO HADER
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRES'ENTADO UNA COMPARECFNCIA ESCRITA, YA SEA
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE, PERSONALMENTE 0 POR ABOGADO Y POP,NO HABER RADICADO POR
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) FSCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS
DAYS FROM THE DATE"OF THIS NOTIC14 A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUYO. Al. NO TOMAR LA
AGAINST YOU WIT14OUT A HEARING AND YOU MAYLOSE YOUR PROPERTY ACCION DEBIDA DENI'RO DE DIFZ(10)DIAS m LA FECHA DE ESTA
OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NF..CESIDAD DE
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE•,. IF YOU COMPARECER USTED EN CORTL"- U OIR PREUBA ALGUNA, D1C'rAR
DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTLiD PODRIA PERDER BIENES U OTROS
BrLOw. THIS OI FICF CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTrS.
HIRING A LAWYER. USTED LE DEBE TOMAR FSTE PAPEI, A SU ABOGADO
11'YOUCANNOTAPFORDTO HIRE A LAWYER,THISOFFICEMAYBEABLE INMEDIATAMENTE. Sl USTED NO TIENE A UN ABOGADO, VA A O
TOPROVIDEYOUIWITH INFORMATION ABOUTAGL'NCIF,S THAT MAY OFFER TELEFONEA LA OFICINA F\PUSO ABAJO.ESTA OFICINA LA PUEDE
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON 1NFORMACION ACERCA DE EMPLrAR A UN
ABOGADO.
Cumberland County Bar Association St USTED NO PUEDFPROPORCIONARPARA EMPLEARUN ABOGADO,
32 South Bedford Street ESTA OFICINA PUEDF SER C:APAZ Dr.. PROPORCIONARLO CON
Carlisle,Pennsylvania 17013 INFORMAC10N ACERCA DE LAS AGENCIAS QUE PUEDrN OPRECERLOS
(800)990-9108 SERVICIOS L.EGALF.S A PERSONAS ELEGIBLPS EN UN HONORARIO
REDUCIDO NI NINGIIN HONORARIO.
Cumberland County Bar Association
32 South Bedford Street
Carlisle,Pennsylvania 17013
(800)990-9108
MICA , EIS RR G,A� CO AY,P.C.
BY:
[ ]Te ,nce.J.McCabe,E wire [ ] Marc S. Weisberg,Esquire
[ dward D.Conway,Esquire 1 ] Margaret Gairo,Esquire
[
]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail, Esquire
[ ]Christine L.Graham,Esquire [ ]Brian T.LaManna, Esquire
]
Ann E.Swartz,Esquire [ ]Joseph F. Riga,Esquire
Alioseph 1.Foley,Esquire
Attorneys for Plaintiff
dao
Results as of:Jun-}1.2013 06:26:06
-Department of Defense Manpower Data Center
SCRA 3.0
€. Staters Deport
5
P musrrt to SeMcemmbm Civil Rolief Act
Last Name: GREEN
First Name: HENDERSON
Middle Name:
Active Duty Status As Of: Jun-11-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
•N-N = r�.rte 1.
NA NA fJ,'i"� 1."r-^.._" � .».:-rid' N NA
This response reflecs e'in_]�id u «
als'a-dNe duy satus lwsad-oZn i h dArWn1
,Status Data
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Data Active Duty End Date Status t Service Component
NA " �3NA 't NA
This response reflects where tiffs individual left actve duty status within 367 Bays preceding the Active Duty Status Date
The Member or Ha/Her Unit Was Notified of a Future Cali-Up to Active Duty on Active Duty Status Data
Order Notification Start Data Order Notification End End Data Status, Service Component
NA NA r7 C, , r�,.i"rte✓No£tiff'y! NA
This response reflects whether ttie individual Zr itisiher unit has receWed eady 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 Carps,Air Farce,NOAH,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
1A 4
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
.The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.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: Y3R21772X08B200
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle,Pennsylvania 17013
Prothonotary
To: Henderson R.Green
177 Joya Circle
Harrisburg,Pennsylvania 17112
Freedom Mortgage Corporation
COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY
V.
Henderson R.Green No. 13-2453
Defendant
NOTICE
Pursuant to Rule 236,you are hereby notified that a JUDGMEN3heen e red in t a Bove proceedi
as indicated below.
Protho
X Judgment by Default �13'+
Money Judgment
Judgment in Replevin
_ Judgment for Possession
If you have any questions concerning this Judgment,please call McCabe Weisberg and Conway,
P.C.at(215)790-1010.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
FILE NO.: 13-2453 Civil Term
Freedom Mortgage Corporation
V. AMOUNT DUE: $138,464.12 =2
xca C—
Henderson R. Green INTEREST: from 06/12/13 --J
$4,005.76 at$22.76
ATTY'S COMM.:
CD
COSTS: C:) C:-,M
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account
based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to
Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the
following described property of the defendant(s)
307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055
(More fully described as attached)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs,as above,
directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies
of the description;supply four copies of lengthy personalty list)
and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s).
—(Indicate)Index this writ against the gamishee(s)as a]is pendens against real estate of the defendant(s)
described in the attached exhibit.
DATE: 7 Z- BY:
150 pc� Terrence J.McCabe,Esq. 1,]Narc S. Weisberg,Esq.
Edward D.Conway,Esq. Margaret Gairo,Esq.
Andrew L.Markowitz,Esq. Heidi R. Spivak,Esq,
I J�Marisa J.Cohen,Esq. Kevin T.McQuail,Esq.
x4 Christine L.Graham,Esq. Brian T.LaManna,Esq.
]Ann E. Swartz,Esq. Joseph F.Riga,Esq.
]Joseph 1,Foley,Esq. Celine P.DerKrikorian,Esq,
Attorneys for Plaintiff
C1
nnq 00 Firm:MCCABE,WEISBERG AND CONWAY
Clio, Alt Address:123 S.Broad Street, Suite 1400
Philadelphia,PA 19109
Attorney for-Plaintiff
Telephone: (215)790 1010
Supreme Court ID No.
��. ill r �'�-, �� �x �S vex/
LL-
P w
LEGAL DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Upper Allen Township, County of Cumberland,and State of
Pennsylvania,bounded and described as follows,to wit:
BEGINNING at a point in the center of a public road,known as Mt.Allen Drive, leading from U.S.Route 15 to
Bowmansdale,said point being South 27 degrees,45 minutes 00 seconds East,two hundred fifty-eight and twenty
hundredths(258.20)and South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet, from
the southwestern corner of land of L.C. Shumbaugh,Jr.;thence along the center line of said public road,known as Mt.
Allen Drive, South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet to a point at the
corner of Lot No. 5 in the Plan of Lots of Paul T. Shearer and I. S. Eberly known as Reservoir Hill;thence along said
Lot No. 5,North 81 degrees 00 minutes 00 seconds East,one hundred forty-two and forty-seven hundredths(142.47)
feet to a point;thence along Lot No. 33 in said Plan of Lots,North 09 degrees 00 minutes 00 seconds West,ninety
and zero hundredths(90.00)feet to a point;thence along Lot No. 3 in said Plan of Lots South 81 degrees 00 minutes
00 seconds east,one hundred forty-two and forty-seven hundredths(142.47)feet to a point in the center line of the
public road aforesaid,the place of BEGINNING.
BEING Lot No.4 in the Plan of Lots of Paul T. Shearer and 1. S.Eberly known as Reservoir Hill,which plan is of
record in the Cumberland County Recorder of Deeds Office in Plan Book No. 11,at Page 8.
HAVING ERECTED THEREON a dwelling house being known and numbered as 307 Mt.Allen Drive,
Mechanicsburg,Pennsylvania.
307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055.
BEING the same premises which ROBERT E.HIMES AND EVALYN A.RIMES,HUSBAND AND WIFE by deed
dated October 26,2004 and recorded October 28,2004 in the office of the Recorder in and for Cumberland County in
Deed Book 265,Page 4739,granted and conveyed to Henderson R. Green,a single individual, in fee.
TAX MAP PARCEL NUMBER:42-24-2423-025
r
L i .
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID#17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.McQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LaMANNA,ESQUIRE-ID#310321 CD.
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F. RIGA,ESQUIRE-ID#57716 t
JOSEPH I. FOLEY,ESQUIRE-ID#314675 =M
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010 I'c-)
_CD
Freedom Mortgage Corporation CUMBERLAND COUNTY f
COURT OF COMMON PLEAS . .r
Plaintiff
V. NO: 13-2453
Henderson R. Green
Defendant
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning
the real property located at: 307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055, as of the date the Praecipe
for the Writ of Execution was filed.A copy of the description of said property being attached hereto.
1. Name and address of Owner or Reputed Owner
Name Address
Henderson R. Green 177 Joya Circle
Harrisburg,Pennsylvania 17112
2. Name and address of Defendant in the judgment:
Name Address
Henderson R. Green 177 Joya Circle
Harrisburg,Pennsylvania 17112
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name Address
Plaintiff herein
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
Wells Fargo Financial Bank. 3201 N.4th Ave
Sioux Falls, South Dakota 57104
5. Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
Name Address
Tenants/Occupants 307 Mount Allen Drive
Mechanicsburg,Pennsylvania 17055
Commonwealth of Pennsylvania Department of Public Welfare
Bureau of Child Support Enforcement
P.O.Box 2675
Harrisburg,PA 17105
ATTN:Dan Richard
Commonwealth of Pennsylvania 110 North 8`h Street
Inheritance Tax Office Suite#204
Philadelphia,PA 19107
Commonwealth of Pennsylvania 6th Floor, Strawberry Square
Bureau of Individual Tax Department#280601
Inheritance Tax Division Harrisburg,PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O. Box 8486
Recovery Program Harrisburg,PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O.Box 281230
Harrisburg,PA-17128-1230
PA Department of Revenue PO BOX 280948
Bureau of Compliance Harrisburg PA 17128-0948
Lien Section
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg,PA 17128-1230
Compliance ATTN: Sheriff's Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia,PA 19106
Domestic Relations P.O.Box 320
Cumberland County Carlisle,PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
William J.Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton,PA 18503
and
Harrisburg Federal Building&Courthouse
228 Walnut Street, Ste.220
Harrisburg,PA 17108-1754
United States of America c/o U.S. Dept of Justice,Room 5111
Atty General of the United States 950 Pennsylvania Avenue NW
Washington,DC 20530-0001
United States of America c/o U.S.Dept of Justice,Room 4400
Atty General of the United States 950 Pennsylvania Avenue NW
Washington,DC 20530-0001
8. Name and address of Attorney of record:
Name Address
None
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
'l L BY:
r [ ] Terrence J.McCabe,Esq. [ ] Marc S.Weisberg,Esq.
DATE [ ]Edward D. Conway,Esq. ] Margaret Gairo,Esq.
[ J Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq.
[ ],Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq.
[vI Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq.
[ J Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq.
[ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq.
Attorneys for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Upper Allen Township,County of Cumberland,and State of
Pennsylvania,bounded and described as follows,to wit:
BEGINNING at a point in the center of a public road,known as Mt.Allen Drive,leading from U.S.Route 15 to
Bowmansdale,said point being South 27 degrees,45 minutes 00 seconds East,two hundred fifty-eight and twenty
hundredths(258.20)and South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet,from
the southwestern corner of land of.L.C. Shumbaugh,Jr.;thence along.the.center line of said public road,known as Mt.
Allen Drive,South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet to a point at the
corner of Lot No, 5 in the Plan of Lots of Paul T. Shearer and I. S.Eberly known as Reservoir Hill;thence along said
Lot No. 5,North 81 degrees 00 minutes 00 seconds East,one hundred forty-two and forty-seven hundredths(142.47)
feet to a point;thence along Lot No. 33 in said Plan of Lots,North 09 degrees 00 minutes 00 seconds West,ninety
and zero hundredths(90.00)feet to a point;thence along Lot No. 3 in said Plan of Lots South 81 degrees 00 minutes
00 seconds east,one hundred forty-two and forty-seven hundredths(142.47)feet to a point in the center line of the
public road aforesaid,the place of BEGINNING.
BEING Lot No.4 in the Plan of Lots of Paul T.Shearer and 1. S.Eberly known as Reservoir Hill,which plan is of
record in the Cumberland County Recorder of Deeds Office in Plan Book No. 11,at Page 8,
HAVING ERECTED THEREON a dwelling house being known and numbered as 307 Mt.Allen Drive,
Mechanicsburg,Pennsylvania.
307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055.
BEING the same premises which ROBERT E.HIMES AND EVALYN A.HIMES,HUSBAND AND WIPE by deed
dated October 26,2004 and recorded October 28,2004 in the office of the Recorder in and for Cumberland County in
Deed Book 265,Page 4739,granted and conveyed to Henderson R. Green,a single individual,in fee.
TAX MAP PARCEL NUMBER:42-24-2423-025
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S. WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.McQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LaMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716 '
JOSEPH 1.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street,Suite 1400 ??
Philadelphia,Pennsylvania 19109 ice—,
(215)790-1010
CIVIL ACTION LAW _ ; =
Freedom Mortgage Corporation COURT OF COMMON PLEAS
V. CUMBERLAND COUNTY
Henderson R. Green
Number 13-2453
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Henderson R. Green
177 Joya Circle
Harrisburg,Pennsylvania 17112
Your house(real estate)at 307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055 is scheduled to
be sold at Sheriffs Sale on December 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the
2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the
court judgment of$138,464.12 obtained by Freedom Mortgage Corporation against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Freedom Mortgage Corporation the back payments,late
charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may
call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of
stopping the sale. (See the following notice on how to obtain an attorney.)
J y
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate.
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find
out if this has happened,you may call McCabe,Weisberg and Conway,P.C.at(215)790-1010.
4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days
of the sale. This schedule will state who will be receiving that money. The money will be paid out
in accordance with this schedule unless exceptions(reasons why the proposed schedule of
distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the
schedule of distribution.
7. You may also have other rights and defenses,or ways of getting your real estate back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle,Pennsylvania 17013
(800)990-91.08
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
32 South Bedford Street
Carlisle,Pennsylvania 17013
(800)990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Upper Allen Township,County of Cumberland,and State of
Pennsylvania,bounded and described as follows,to wit:
BEGINNING at a point in the center of a public road,known as Mt.Allen Drive,leading from U.S.Route 15 to
Bowmansdale,said point being South 27 degrees,45 minutes 00 seconds East,two hundred fifty-eight and twenty
hundredths(258.20)and South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet, from
the,southwestern corner of land of L.C.,Shumbaugh,Jr.;thence along.the center line of said public road,known as Mt.
Allen Drive,South 09 degrees 00 minutes 00 seconds East,ninety and zero hundredths(90.00)feet to a point at the
corner of Lot No. 5 in the Plan of Lots of Paul T. Shearer and I. S.Eberly known as Reservoir Hill;thence along said
Lot No. 5,North 81 degrees 00 minutes 00 seconds East,one hundred forty-two and forty-seven hundredths(142.47)
feet to a point;thence along Lot No. 33 in said Plan of Lots,North 09 degrees 00 minutes 00 seconds West,ninety
and zero hundredths(90.00)feet to a point;thence along Lot No. 3 in said Plan of Lots South 81 degrees 00 minutes
00 seconds east, one hundred forty-two and forty-seven hundredths(142.47)feet to a point in the center line of the
public road aforesaid,the place of BEGINNING.
BEING Lot No.4 in the Plan of Lots of Paul T. Shearer and I. S.Eberly known as Reservoir Hill,which plan is of
record in the Cumberland County Recorder of Deeds Office in Plan Book No. 11,at Page 8.
HAVING ERECTED THEREON a dwelling house being known and numbered as 307 Mt.Allen Drive,
Mechanicsburg,Pennsylvania.
307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055.
BEING the same premises which ROBERT E.HUVIES AND EVALYN A. HIMES,HUSBAND AND WIFE by deed
dated October 26,2004 and recorded October 28,2004 in the office of the Recorder in and for Cumberland County in
Deed Book 265,Page 4739,granted and conveyed to Henderson R.Green, a single individual,in fee.
TAX MAP PARCEL NUMBER: 42-24-2423-025
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO, 13-2453 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FREEDOM MORTGAGE CORPORATION Plaintiff(s)
From HENDERSON R.GREEN
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $138,464.12 L.L.: $.50
Interest FROM 6/12/2013-$4,005.76 AT$22.76
Atty's Comm: Due Prothy: $2.25
Atty Paid: $224.00 Other Costs:
Plaintiff Paid:
Date: 7/19/13
David D.Buell,Prot notary
(Seal)
Deputy
REQUESTING PARTY:
Name: CHRISTINE L. GRAHAM,ESQUIRE
Address: MCCABE,WEISBERG AND CONWAY
123 S.BROAD STREET,SUITE 1.400
PHILADELPHIA,PA 1.9109
Attorney for:PLAINTIFF
Telephone:215-790-1010
Supreme Court ID No.309480
} McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J. McCABE,ESQUIRE- ID# 16496 Attornpys for_Plaintiff
MARC S. WEISBERG,ESQUIRE-ID# 17616
EDWARD D. CONWAY, ESQUIRE -ID# 34687 !T;,
MARGARET GAIRO,ESQUIRE-ID# 34419 9 ' — 1
ANDREW L. MARKOWITZ, ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770 !'Ul',�BERLAND COUNT`
MARISA J. COHEN,ESQUIRE-ID# 87830 RENNSYUvANIA
KEVIN T. MCQUAIL, ESQUIRE-ID# 307169
CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480
BRIAN T. LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F. RIGA, ESQUIRE-ID# 57716
JOSEPH 1. FOLEY,ESQUIRE- ID#314675
CELINE P. DERKRIKORIAN, ESQUIRE-ID# 313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Freedom Mortgage Corporation CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. Number 13-2453
Henderson R. Green
Defendant
AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 29th day of
October,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent
lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto.
A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part
hereof.
SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONW�Y,P.C.
BEFORE ME THIS DAY BY: (,J�/
[ ] Terrence J.McCabe,Esquire [ �]-IGIarc S. Weisb g,Esquire
OF ,2013 [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ] Kevin T.McQuail,Esquire
[ ] Christine L.Graham,Esquire [ ] Brian T.LaManna,Esquire
NOTAR PUBLIC [ ]Ann E. Swartz,Esquire [ ] Joseph F. Riga,Esquire
[ ]Joseph L Foley,Esquire [ ] Celine P.DerKrikorian,Esquire
Attorneys for Plaintiff
I
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S. WEISBERG,ESQUIRE-ID# 17616
EDWARD D. CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO, ESQUIRE-ID# 34419
ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J. COHEN,ESQUIRE-ID# 87830
KEVIN T. MCQUAIL, ESQUIRE-ID# 307169
CHRISTINE L. GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F. RIGA,ESQUIRE-ID# 57716
JOSEPH I. FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN, ESQUIRE-ID#313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
215 790-1010
Freedom Mortgage Corporation CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. NO: 13-2453
Henderson R. Green
Defendant
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
The undersigned attorney for Plaintiff in the above action sets forth the following information concerning
the real property located at 307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055,as of the date the Praecipe
for the Writ of Execution was filed.A copy of the description of said property is attached hereto.
1. Name and address of Owner or Reputed Owner
Name Address
Henderson R.Green 177 Joya Circle
Harrisburg,Pennsylvania 17112
2. Name and address of Defendant in the judgment:
Name Address
Henderson R. Green 177 Joya Circle
Harrisburg,Pennsylvania 17112
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name Address
Plaintiff herein
File#68439
Page 1
1
t
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
Wells Fargo Financial Bank 3201 N.4th Ave
Sioux Falls, South Dakota 57104
5. Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
Name Address
Tenants/Occupants 307 Mount Allen Drive
Mechanicsburg,Pennsylvania 17055
Commonwealth of Pennsylvania Department of Public Welfare
Bureau of Child Support Enforcement
P.O.Box 2675
Harrisburg,PA 17105
ATTN: Dan Richard
Commonwealth of Pennsylvania 110 North 8`h Street
Inheritance Tax Office Suite#204
Philadelphia,PA 19107
Commonwealth of Pennsylvania 6th Floor,Strawberry Square
Bureau of Individual Tax Department#280601
Inheritance Tax Division Harrisburg,PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O.Box 8486
Recovery Program Harrisburg,PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O.Box 281230
Harrisburg,PA 17128-1230
PA Department of Revenue PO BOX 280948
Bureau of Compliance Harrisburg PA 17128-0948
Lien Section
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg,PA 17128-1230
Compliance ATTN: Sheriff's Sales
File#68439
Page 2
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia,PA 19106
Domestic Relations P.O.Box 320
Cumberland County Carlisle,PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
William J.Nealon Federal Bldg.
235 North Washington Avenue,Ste. 311
Scranton,PA 18503
and
Harrisburg Federal Building&Courthouse
228 Walnut Street,Ste.220
Harrisburg,PA 17108-1754
United States of America c/o U.S. Dept.of Justice,Rm 4400
Atty General of the United States 950 Pennsylvania Avenue,NW
Washington,DC 20530
United States of America c/o U.S.Dept.of Justice,Rm 5111
Atty General of the United States 950 Pennsylvania Avenue,NW
Washington,DC 20530
8. Name and address of Attorney of record:
Name Address
None
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
10 /3-;�/l3 McCABE,WEISBERG AND CONWAY,P.C.
DATE /� � `, /
BY l a- C.c (/�,/
[ ]Terrence J.McCabe,Esquire [ arc-§. Weisberg,Esquire
[ )Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire
[ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire
[ ]Joseph 1.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire
Attorneys for Plaintiff
Re: Freedom Mortgage Corporation v.Henderson R.Green.et al.
Cumberland County;Number: 13-2453
File#68439
Page 3
McCABE,WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S. WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J. COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L. GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F. RIGA,ESQUIRE-ID#57716
JOSEPH I. FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street, Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
Freedom Mortgage Corporation COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY
V.
Henderson R.Green Number 13-2453
Defendant
DATE: October 29,2013
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNERS:Henderson R. Green
PROPERTY: 307 Mount Allen Drive,Mechanicsburg,Pennsylvania 17055
IMPROVEMENTS: Residential Dwelling
JUDGMENT AMOUNT: $138,464.12
The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the
Sheriffs Sale on December 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of
the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that
you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished
by the sale. You may wish to attend the sale to protect your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days
after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten
(10)days after the filing of the schedule.
If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to
CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson s° 3- : "rC E.
F. . i HE P St t:# TAE
Sheriff � y to tit clunbrt,���c
Jody S Smith r
Chief Deputy ,., ,; t,1 JAN 21 AN ti 35
Richard W Stewart CUMBEaLAND COUNT
Solicitor KE OF°f=E$ ER F PENNSYLVANIA
Freedom Mortgage Corporation Case Number
vs.
2013-2453
Henderson R Green
SHERIFF'S RETURN OF SERVICE
08/26/2013 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: Henderson R. Green, 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 06:29 PM -Deputy Jason Kinsler, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 307 Mount Allen Drive, Southampton -Township,
Mechanicsburg, PA 17055, Cumberland County.
10/01/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Dauphin County upon Henderson R. Green, personally, at 177 Joya Circle, Harrisburg, PA 17112 on
9/20/13 at 0855 hrs. So Answers: W. Conway, Deputy Sheriff.
12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at
10:00 AM. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of Secretary of
Veterans Affairs, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,075.65 SO ANSWERS,
January 17, 2014 RONR ANDERSON, SHERIFF
1M AO Rol •de4
.a� p� ,�c,.
ieA'A �d4elo9
i. Coun,ySuife Sheriff:Teleosoft.In::.
On August 26, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Cumberland County, PA,
Known and numbered as, 307 Mount Allen Drive,
Mechanicsburg, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
Date: August 26, 2013
r.:
t .
By:
Real Estate Coordinator
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No.2013-2453 Civil Term County Recorder of Deeds Office in
Plan Book No.II,at Page 8.
FREEDOM MORTGAGE HAVING ERECTED THEREON
CORPORATION a dwelling house being known and
vs. numbered as 307 Mt. Allen Drive,
HENDERSON R. GREEN Mechanicsburg,Pennsylvania.
307 Mount Allen Drive, Mechan-
Atty.:Terrance McCabe icsburg,Pennsylvania 17055.
ALL THAT CERTAIN piece of BEING the same premises which
parcel of land situate in Upper Allen ROBERT E. HIMES AND EVALYN
Township, County of Cumberland, A.HIMES,HUSBAND AND WIFE by
and State of Pennsylvania,bounded deed dated October 26, 2004 and
and described as follows,to wit: recorded October 28, 2004 in the
BEGINNING at a point in the office of the Recorder in and for Cum-
center of a public road,known as Mt. berland County in Deed Book 265,
Allen Drive,leading from U.S.Route Page 4739,granted and conveyed to
15 to Bowmansdale,said point being Henderson R. Green, a single indi-
South 27 degrees, 45 minutes 00 vidual,in fee.
seconds East,two hundred fifty-eight TAX MAP PARCEL NUMBER:42-
and twenty hundredths (258.20) 24-2423-025.
and South 09 degrees 00 minutes
00 seconds East, ninety and zero
hundredths (90.00) feet, from the
southwestern corner of land of L.C.
Shumbaugh, Jr.; thence along the
center line of said public road,known
as Mt.Allen Drive,South 09 degrees
00 minutes 00 seconds East,ninety
and zero hundredths(90.00)feet to a
point at the corner of Lot No.5 in the
Plan of Lots of Paul T. Shearer and
I. S.Eberly known as Reservoir Hill;
thence along said Lot No. 5, North
81 degrees 00 minutes 00 seconds
East, one hundred forty-two and
forty-seven hundredths(142.47)feet
to a point;thence along Lot No.33 in
said Plan of Lots, North 09 degrees
00 minutes 00 seconds West,ninety
and zero hundredths (90.00) feet to
a point; thence along Lot No. 3 in
said Plan of Lots South 81 degrees
00 minutes 00 seconds east, one
hundred forty-two and forty-seven
hundredths (142.47) feet to a point
in the center line of the public road
aforesaid,the place of BEGINNING.
BEING Lot No.4 in the Plan of
Lots of Paul T.Shearer and I.S.Eb-
erly known as Reservoir Hill,which
plan is of record in the Cumberland
59
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 11, October 18 and October 25, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation,and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
sa Marie Coyne, E 'tor
SWORN TO AND SUBSCRIBED before me this
25 day of October, 2013
/
Notary
NC,TARIAL SEAL
DEBORAH A COLLINS
Notary Public -
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.2020 Technology Pkwy t atflOtXCWS
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.
w This ad ran on the date(s)shown below:
e1 , 10/13/13
10/20/13
t R mint % c" �i, 10/27/13
M,: ; :;,j 'G7 ,G
ALL THAT(=PAIN piece of parcel of ./"-- —
land situate in UpperAffenlbwnship,County
of Cumbed nod;and State of Pennsylvania,
bounded and described as follows,to wit:
BEGINNING at a point in the center of Sw• te and subscribed before,;.e ,is 11 day of November, 2013 A.D.
a public road,known as ME Allen Drive,
leading Route
South 27 degees, 45 i �� �
said point being South 2? degiees 45 �f ,
minutes 80seconds East,two hundred fifty- i
eight and twenty hundredths(258.20) and j — — . "�ili
South 09 degrees 00 minutes 00 seconds
*•� •UbIiC
East, ninety and zero hundredths (90.00)
feet,from the southwestern corner.of land
of LC.Shumbaugh,Jr;thence along the,
center line of said blicroad,known as Mt. i
COMMONWEALTH OF PENNSYLVANIA
Allen Drive,South 09 degrees 00 minutes 00
seconds East,ninety and zero moths I" rris Seal
(90.00)feettoapoinfat rufLotNo. Nally Lynn;afar�l,Notary Public
5 in plats of nts;af Fatty/✓Shearer and Washington .up,,Dauphin County
L S.Eberly- thence My Commission Expires Dec 12,2016
along said Lot No. oath 81 degrees MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
minutes 00 seconds East,one hundred forty-
two and forlyseven,htmdiedths(142.47)feet
to a point;thence along Lot No.33 in said
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 Secretary of Veterans Affairs is the grantee the same having been sold to said
grantee on the 4th day of December A.D., 2013,under and by virtue of a writ Execution issued on the
19th day of July, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013
Number 2453, at the suit of Freedom Mortgage Corporation against Henderson R. Green is duly
recorded as Instrument Number 201401518.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 7/ day of
A.D. 029/
p,y Recorder of Deeds
Recorder Deeds,Cumberland County,Carlisle,PA
My Commission Expires me First Moon„,s Ian.2018