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HomeMy WebLinkAbout13-3217 ' t For Prothonotary Use Only: * reme Court. of P'e nnsylvani a -� Co U .ru11 W Ueet Cumb ,rl and � I Docket No. Ly 1 34'� The information collected on this form is used solely for court administration purposes. This form does nor supplement or re lace the filing and service ofpleadings or other papers as required by law or rules o court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C I-cad Plaintiffs Name: M&T Bank Lead Defendant's Name: Angela Dawn Christopher T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits I 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 Sep Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS • Intentional ❑ Buyer Plaintiff Administrative Agencies • Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment 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 i C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other I O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS B ❑ Toxic Waste ❑ Ejectment ❑Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlordfrenant Disput ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: • Other Professional: I i Updated 1/1/2011 <<'t fir Pt�;OT1l0��OtAf� ";' 2013 JUN AN EO: 09 CUMBERLAND COUNTY PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 .South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 M &T Bank Cumberland County 80 Holtz Drive Court of Common Pleas Cheektowaga, NY 14225 V. Number Angela Dawn Christopher 509 West North Street Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE X03 BSI a 16 'x/ 'P�V= 0? File # 72549 Page 1 NOTICE AVISO You have been sued in court. If you wish to defend _ Le ban demandado a usted en ]a corte. 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 al partir complaint and notice are served, by entering a written de la fecha de la demanda y la notificacion. Hace falta appearance personally or by attorney and filing in asentar una comparencia escrita o en persona o con un writing with the court your defenses or objections to the abogado y entregar a la corte en forma escrita sus claims set forth against you. You are warned that if you defensas o sus objeciones a las demandas en contra de fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la judgment may be entered against you by the court corte tomara medidas y puede continuar la demanda en without further notice for any money claimed in the contra suya sin previo aviso o notificacion. Ademas, ]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 provisioner de esta rights important to you. demanda. Usted puede perder dinero o sus propiedades YOU SHOULD TAKE THIS PAPER TO u otros derechos importantes para usted. YOUR LAWYER AT ONCE. IF YOU DO NOT USTED LE DEBE TOMAR ESTE PAPEL A HAVE A LAWYER, GO TO OR TELEPHONE THE SUABOGADOINMEDIATAMENTE. SIUSTEDNO OFFICE SET FORTH BELOW. THIS OFFICE CAN TIENE A UN ABOGADO, VA A O TELEFONEA LA PROVIDE YOU WITH INFORMATION ABOUT OFICINA EXPUSO ABAJO. ESTA OFICINA LO HIRING A LAWYER. PUEDE PROPORCIONAR CON INFORMATION IF YOU CANNOT AFFORD TO HIRE A ACERCA DE EMPLEAR A UN ABOGADO. LAWYER, THIS OFFICE MAY BE ABLE TO SI USTED NO PUEDE PROPORCIONAR PROVIDE YOU WITH INFORMATION ABOUT PARA EMPLEAR UN ABOGADO, ESTA OFICINA 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 # 72549 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. IJnless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgment that we obtain. Upon your written request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: M &T Bank v. Angela Dawn Christopher Cumberland County File # 72549 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M &T Bank, duly organized and doing business at the above- captioned address. 2. The Defendant is Angela Dawn Christopher, who is the mortgagor and owner of the mortgage property hereinafter described, and his/her last -known address is 509 West North Street, Carlisle, PA 17013. 3. On February 5, 2010, Angela Dawn Christopher, mortgagor, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as nominee for M &T Bank which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 201003314 ( "the Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On March 15, 2013, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for M &T Bank to M &T Bank, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Instrument Number 201310824, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. The premises subjectto said mortgage is described in the legal description attached as Exhibit "A" and is known as 8 Kingsbridge Circle, Carlisle, Pennsylvania 17013. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due .November 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 # 72549 Page 4 7. The following amounts are due on the mortgage: Principal Balance $ 217,065.71 Interest through April 1, 2013 $ 5,562.30 (Plus $927.05 per monthly thereafter) Late Charges $ 326.46 Attorney's Fee $ 1,300.00 Escrow Advance $ 246.95 Mortgage Insurance Premiums (MIP) $ 192.62 Property Inspection Fees $ 42.00 GRAND TOTAL $ 224,736.04 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 under Act 6 of 1974 (41 P.S. §403) was sent to Defendant by certified mail, return receipt requested as required by that Act. Notice under the Homeowner's Emergency Mortgage Assistance Act (Act 91) was not provided as the provisions of such Act were not applicable at that time and no notice under such Act was required. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $224,736.04, together with interest at the rate of $927.05 per monthly thereafter and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE WEISBERG AND CO Y, P.C. BY 17 �. Terrence J. McCabe, Esquire [ ) Marc S. 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 I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff File # 72549 Page 5 VERIFICATION James N. Kelly , hereby states that he /she is Banking Of f icer of M &T Bank, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to a falsification to authorities. Na ; James Kelly DATE: Title. Bank Office File #: 72549 Name: M &T Bank v. Angela Dawn Christopher File # 72549 Page 6 EXHIBIT t°A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, being Lot No. 100, as shown on a Plan entitled, "Chesterfield (formerly Greystone Manor), Single - Family Residential Development, Final Subdivision/Land Development Plan, Section 2A," dated December 8, 2000 by PennTerra Engineering, Inc., State College, Pennsylvania, being bounded and described as follows: BEGINNING at an iron pin, being a northerly corner of Lot No. 99 and lying in a southerly right of way line of Kingsbridge Circle (60 foot right of way, 28 foot wide cartway); thence along said right of way along a curve to the left, having a chord bearing of North 42 degrees 31 minutes 34 seconds East, a chord distance of 44.41 feet, a radius of 180.00 feet and an arc length of 44.52 feet to an iron pin, lying in a southerly line of said right of way and being a westerly corner of Lot No. 101; thence along said lot South 54 degrees 33 minutes 37 seconds East, 182.95 feet to an iron pin, being a southerly comer of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way); thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.18 feet to a concrete monument to be set, lying in a westerly line of said right of way and being a northeasterly comer of lands owned now or formerly by Richard A. and Elizabeth A. Damico (Deed Book 201, page 692); thence along said lands South 85 degrees 42 minutes 00 seconds West, 57.08 feet to an iron pin, lying in a northerly line of said lands and being an easterly comer of Lot No. 99; thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin, being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle, Carlisle, Pennsylvania 17013. C.-) C aC FORM t �c3 -.�• c, M &T Bank IN THE COURT OF COMMON PLEAS C `' C) Plaintiff CUMBERLAND COUNTY, PENNSYLVA _ {T ---+ p 7 ; vs. Angela Dawn Christopher Civil Defendant NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submi ed: Date [Signature of Counsel for Plaintifff 72549 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: C(jSTOMLR/Pl1l'iVlARY 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): 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? 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 ❑ 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 #]: 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 2"' 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/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑No❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your 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: f Proof of income I Past 2 bank statements r Proof of any expected income for the last 45 days I Copy of a current utility bill r Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 72549 Page 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ) ca ntr�rii Jody S Smith Chief Deputy -a Richard W Stewart Co Solicitor O c = 00 r M&T Bank CaSiNmber vs. Angela Dawn Christhoper 2013-3217 SHERIFF'S RETURN OF SERVICE 06107/2013 08:51 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Amanda Barrick, sister,who accepted as"Adult Person in Charge'for Angela Dawn Christhoper at 509 W. North Street, Carlisle Borough, Carlisle, PA 17013. DENNIt FRY, DEP SHERIFF COST: $34.78 SO ANSWERS, 6Z June 28, 2013 R-ONW R ANDERSON, SHERIFF (e)CountySuAe Sheriff,Teleosoit,lnc. • McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-1D# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 T 1 11 En_ci_,j-�l MARGARET GA IRO,CONWAY, SQUIRE D#I34 19 87 j. r j; t l� 't.1'01 10 TA F ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 nOr r HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 COUNTY a KEVIN T.MCQUAIL,ESQUIRE-ID#307169 jr��dr S�,�� j CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Angela Dawn Christopher Number 13-3217Civil Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Angela Dawn Christopher,in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules ofCivil Procedure,and assess damages as follows: . Principal $ 224,736.04 Interest from 04/02/13 to 08/02/13 $ 3,708.20 @$927.05 per monthly thereafter Total $ 228,444.24 McCABE,WEISBERG AND CONWAY,P.C. BY: -� errence J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. a [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. Ck o 1015n(/7 [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. 12#A S9 log [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. r 1 [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. 1v 0 llCf rnQ [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff Date: AND NOW,this S day of —'2013,Judgment is entered in favor of Plaintiff,M&T Bank, and against Defendant,Angela Dawn Christopher, in rem only and not in personam,and damages are assessed in the amount of$228,444.24,plus interest and costs. BY THE PR ONO A 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#31.4675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Angela Dawn Christopher Number 13-3217Civil Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: I solemnly affirm under the penalties of perjury that the contents of the foregoing paper are true to the best of my knowledge,information,and belief. Said Defendants,Angela Dawn Christopher,is not in the military service of the United States as defined in the Servicemembers Civil Relief Act,50 U.S.C. app. Sections 501 et seq.as of the date of the SCRA report attached. Said Defendant reside at: Angela Dawn Christopher,509 West North Street,Carlisle,PA 17013 McCABE,WEISB�ERGG AND CONWAY,P.C. ;BY: Terrence J.McCabe,Esq. [ -Marc S. Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ J Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff On the day of of year 20�before me, the undersigned, a Notary Public in and for said State, personally appeared ,rt' J NBC Cgs C £s ,personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity,and that by his signature on the instrument,the individual,or the person upon beh which the individual acted,executed the instrument. NO AA &g ACTH D PENNSYLVANIA NOTARIAL 9E�L. Maleekah Wiltbank,* Notary Public City of Philadelphia Philadelphia County MY COMMISSION EXPIRES APR.06,2015 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#5771.6 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1.010 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Number 13-3217Civil Angela Dawn Christopher Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendant are: Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 Angela Dawn Christopher 8 Kingsbridge Circle Carlisle,Pennsylvania 17013 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED �� `, Pp BY: ice" c BEFORE ME THIS 2 DAY [ ] errence J.McCabe,Esq. [ ]Marc S.Weisberg, sq:- G ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. Z)ARt)YPU!B'1 �! ,2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. IC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph L Foley,Esq. [ ] Celine P.DerKrikorian,Esq. COMMONWEALTH. OF-PENNSYLVANIA Attorneys for Plaintiff NOTARIAL SEAL Date: Maleekah Wiltbanks-Notary Public � City of Philadelphia,Philadelphia County MY COMMISSION EXPIRES APR.06,2015 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID 474770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109. (215)790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-3217Civil Angela Dawn Christopher 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 them within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS��DAY 3ferrence J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. 2tr� 6� ,2013 [ ] Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ] Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P. DerKrikorian,Esq. COMMONWEALTH OF PENNSYLVANIA Attorneys for Plaintiff NOYAR1A,• SEAL Date: sI I t 3 Maleekah Vviitbar;�,s4l0tary Public' City of Philadelphia,Ptwadelphia County MY COMMISSION EXPIRES APR.06,2015 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. McCABESBERG AND CONWAY,P.C. BY: [ Terrence J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. ]Edward D. Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]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 P a ntiff Date: �`� (� M&T Bank v.Angela Dawn Christopher Cumberland County;Number: 13-3217Civil OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 1.701.3 Curt Long Prothonotary Tune 28,2013 To: Angela Dawn Christopher 509 West North Street Carlisle, Pennsylvania 17013 m&,r Bank Cumberland County VS. Court of Common Pleas Angela Dawn Christopher Number 13-3217 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENT"ION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAUI T BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENrRA EN ESTADO DE REBEL.DIA POR.NO IIABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR-OBJECTIONS TO'I'HE PERSONALMENTE 0 POR ABOGADO Y POR NO I4ABER 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 NOTICE,,A.JUDGMENT MAY BE ENTERED RECLAMOS FORMUL.ADOS EN CONTRA sUYO. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERT'Y ACCION DEBIDA DENTRO DF Dirz(10)DIAS DE LA FECHA DE F..sTA. OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DF YOU SHOULD TAKE TI 113 PAPER TO YOUR LAWYER A'r ONCE, IF YOU COMPARECER USTFD EN CORT'E U OIR PREUBA AL(IUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SL I'FORTH SENTENCIAL'•N SU CONTRA Y USTED PODRIA PERDLR BIENES UOT'ROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS TMPORTANTES, IBRING A LAWYER. LISTED LE DEBE TOMAR EST'E PAPEL A SU ABOGADO IF YOU CANNOTAFFORDTO14111 EALAWYER,THIS OFFICE MAY BEADLE INMFDIATAMENTE. ST USTED NO TIENE A UN ABOGADO, VA A O TO PROVIDE YOU WITHINFORMATIONABOU'J'AGENCIL•ST14AT MAY OFFER TFLEFONEA LA OFICINA EXPUSO ABAJO.1 STA OPICINA LO PUEDE LI:iGAL SERVICES TO ELIGIBLE.PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMACION AcrRCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NO PUEDE..PROPORCIONAR PARA EMPLEAR(IN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONAR.LO CON Carlisle,Pennsylvania 17013 INFORMACIONACERCADELASAGENCIASQUEPUEDFNOFRFCERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS EI.EOIBLE"S EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cui and Count Bar Association South I3edforc arlis e,P nns 1 aria 17 13 McCABri�^EISBERG C AY,P.C. ]Terrence J.Mc ' e, f ire [ ]M.afc S. Weisberg,Esquire [ ] Edward.D.C way, squire [ /.Margaret Gairo,Esquire ]Andrew L . arkowtz,Esquire [ ] Heidi R. Spivak,Esquire [ ] Marisa J.Cohen,Esquire [ ] Kevin T.McQuail,Esquire ] Christine L.Graham,Esquire [ ]Brian'r. LaMantia,Esquire [ ]Ann E. Swartz,Esquire [,,d Joseph F. Riga,Esquire [ ]Joseph 1.Foley,Esquire Attorneys for Plaintiff ch OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 1701.3 Curt Long Prothonotary June 28, 2013 To: Angela Dawn Christopher 8 Ki.ngsbridge Circle Carlisle,Pennsylvania 17013 M&T Bank Cumberland County vs. Court or Common Pleas Angela Dawn Christopher Number 13-3217 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED'I'D ENTER A USTED SE FNCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR 13Y ATTORNEY AND PILE IN PRESF,NTADO UNA COMPARECF..NCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR 013JFCPIONS TO THE PFRSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTFI AGAINST YOU. UNLESS YOU ACT WITHIN'rrN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMUL.ADOS EN CONTRA sUYo. AL NO TOMAR LA AGAINST YOU WITHOUTA HEARING AND YOU MAY LOSE YOURPROPERTY ACCION DEBIDA DENTRO DE DIET.(10)DIAS DE LA FECHA DE FSTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER To YOUR LAWYER AT ONCE.. IF YOU COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SEN'ENCIA EN SU CONTRA Y USTED PODRIA PERDF,RBIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER,. USTED LE DE•BF, TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE,MAY 131.;ABLE INMEDIATAMENTE. SI USTED NO TIF.NE A UN ABOGADO, VA A O T OPROVIDEYOU WITH INFORMATIONABOUTAGENCIES THAT MAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO.ESTA OFICINA LO PUEDE, LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED F'E'E OR NO FEE, PROPORCIONAR CON INFORMACION ACERCA DE FMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE" SER CAPA7. DE PROPORCIONARL.O CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS (800)990-9108 SERVICIOS LF;GALF..S A PERSONAS ELEGIBLES FN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cul raf id aunty liar Association South dord Street Carlin nnsylvania 17013 990-9108 McC,ARE, _TSBERG ANl AY,P '. BY: ' [ ]Terrence J. MCC, e, jr, ] Marc S. Weisberg,Esquire [ ]Edward D. away, :�,squlre �[ ]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 [ j Ann E. Swartz,Esquire [.,Joseph F.Riga,Esquire [ ]Joseph.L Foley,Esquire Attorneys for Plaintiff ch. Department of Defense Manpower Data Center Results as of:Aug-02-2013RA3.4 SCRA 3.0 Staters Report Pursunt to;Servicernembes Civil Relief Acct Last Name: CHRISTOPHER First Name: ANGELA Middle Name: Active Duty Status As Of: Aug-02-2013 On Active Duty On Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects the individuals'active duty status based on the Active Duty Status Date i Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA -No NA This response reflects where the indfvdual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA ANA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,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. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: L3VOD86FH05CPFO OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Angela Dawn Christopher No. 13-3217Civil Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGME as be tere he above a ing as indicated below. as Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C.at(215)790-1010. ` OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Angela Dawn Christopher 8 Kingsbridge Circle Carlisle,Pennsylvania 17013 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Angela Dawn Christopher No. 13-3217Civil Defendant NOTICE you are hereby notified that a JUDGMENT h been en ed in tke above proceed Pursuant to Rule 236,y y e, as.indicated below. Protho X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe Weisberg and Conway, P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 13-3217 Civil Term M&T Bank V. AMOUNT DUE: $228,444.24 Angela Dawn Christopher INTEREST: from 08/03/13 $4,656.20 at$37.55 ATTY'S COMM.: COSTS: M =C) TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or aqdounf; based on a confession of judgment,but if it does,it is based on the appropriate original proceeding fil6d 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) 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt,interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: t 1 13 Terrence J.McCabe,Esq. Marc Vveisberg,Esq. Edward D.Conway,Esq. Margarit Gairo,Esq. Andrew L.Markowitz,Esq. Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. Kevin T.McQuail,Esq. Christine L. Graham,Esq. Brian T.LaManna,Esq. Ann E. Swartz,Esq. ]Joseph F. Riga,Esq. Joseph 1.Foley,Esq. ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff Firm:MCCABE,WEISBERG AND CONWAY I Sc) 1t tj Address:123 S. Broad Street, Suite 1400 Or Philadelphia,PA 19109 J /Y t�& Attorney for:Plaintiff Telephone: (215)790 1010 Supreme Court ID No. D,"as �Ui S LEGAL DESCRIPTION All THAT CERTAIN tract of land situated in the Borough of Carlisle,Cumberland County,Pennsylvania, being Lot No. 100,as shown on a Plan entitle,Chesterfield(formerly Greystone Manor), Single-Family Residential Development,Final Subdivision/Land Development Plan,Section 2A,dated December 8,2000 by PennaTerra Enginnering,Inc., State College,Pennsylvania,being bounded and described as follows: BEGINNING at an iron pin,being a northerly comer of Lot No.99 and lying in a southerly right of way line of Kingsbridge Circle(60 foot right of way,28 foot wide cartway);thence along said right of way along a curve to the left,having a chord bearing of North 42 degrees 31 minutes 34 seconds East,a chord distance of 44.41 feet,a radius of 180.00 feet and an are length of 44.52 feet to an iron pin,lying in a southerly line of said right of way and being a westerly comer of Lot No. 101;thence along said lot South 54 degrees 33 minutes 37 seconds East, 182.95 feet to an iron pin,being a southerly comer of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way);thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.18 feet to a concrete monument to be set,lying in a westerly line of said right of way and being a northeasterly comer of lands owned now or formerly by Richard A.and Elizabeth A.Damico(Deed Book 201,Page 692);thence along said lands South 85 degrees 42 minutes 00 Seconds West,57.09 feet to an iron pin,lying in a northerly lines of said lands and being an easterly comer of Lot No. 99;thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin,being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle,Carlisle, Pennsylvania 17013. SUBJECT to a 10' wide utility easement along its street frontage. ALSO,UNDER AND SUBJECT to a sign easement in favor of Chesterfield Homeowners Association for the placement and maintenance of subdivision signage.This easement grants the Homeowners Association the right to enter the premises herein described for the purpose of maintaining the sign and the landscaping surrounding the sign. UNDER AND SUBJECT to any existing covenants,easements,encroachments,conditions,restrictions,and agreements affect the property,visible or of record. 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013. BEING the same premises which JAMES W.CLARK III AND EVA G.CLARKE,HUSBAND AND WIFE by deed dated January 30,2010 and recorded February 8,2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201003313,granted and conveyed to Angela Dawn Christopher,married woman,in fee. TAX MAP PARCEL NUMBER:05-19-1647-240 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 MARC S. WEISBERG,ESQUIRE-ID#17616 Attorneys for Plaintiff EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 C_ — HEIDI R. SPIVAK,ESQUIRE-ID#74770 _` MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 fi CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 t,., BRIAN T. LaMANNA,ESQUIRE-ID#310321 `= ANN E. SWARTZ,ESQUIRE-ID#201926 'n JOSEPH F.RIGA,ESQUIRE-ID#57716 CD JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 .� n,) 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-3217 Angela Dawn Christopher 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: 8 Kingsbridge Circle, Carlisle,Pennsylvania 17013,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 Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 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 Discover Bank 12 Reads Way New Castle,Delaware 19720 Discover Bank c/o Weltman, Weinberg&Reis,Co. 436 Seventh Avenue, Suite 1400 Pittsburgh,Pennsylvania 15219 4• Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 Chesterfield Manor Homeowners P.O.Box 71005 Association Newnan, Georgia 30274 S&A Custom Build Homes,Inc. 5005 Carlisle Pike Mechanicsburg,Pennsylvania 17055 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 8 Kingsbridge Circle Carlisle,Pennsylvania 17013 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. I BY: McCabe,Terrence J.MciC ,Esq. arc S.We sberg,Esq. � DAtE Edward D.Conway,Esq. Margaret Gairo,Esq. Andrew L.Markowitz,Esq. Heidi R.Spivak,Esq. Marisa J.Cohen,Esq. Kevin T.McQuail,Esq. Christine L.Graham,Esq. Brian T.LaManna,Esq. Ann E.Swartz,Esq. Joseph F.Riga,Esq. Joseph L Foley,Esq. Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION All THAT CERTAIN tract of land situated in the Borough of Carlisle,Cumberland County,Pennsylvania, being Lot No. 100,as shown on a Plan entitle,Chesterfield(formerly Greystone Manor), Single-Family Residential Development,Final Subdivision/Land Development PIan,Section 2A,dated December 8,2000 by PennaTerra Enginnering,Inc.,State College,Pennsylvania,being bounded and described as follows: BEGINNING at an iron pin,being a northerly corner of Lot No. 99 and lying in a southerly right of way line of Kingsbridge Circle(60 foot right of way,28 foot wide carlway);thence along said right of way along a curve to the left,having a chord bearing of North 42 degrees 31 minutes 34 seconds East,a chord distance of 44.41 feet,a radius of 180.00 feet and an arc length of 44.52 feet to an iron pin,lying in a southerly line of said right of way and being a westerly corner of Lot No. 101;thence along said lot South 54 degrees 33 minutes 37 seconds East, 18295 feet to an iron pin,being a southerly corner of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way);thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.1.8 feet to a concrete monument to be set, lying in a westerly line of said right of way and being a northeasterly corner of lands owned now or formerly by Richard A.and Elizabeth A.Damico(Deed Book 201,Page 692);thence along said lands South 85 degrees 42 minutes 00 Seconds West,57.09 feet to an iron pin, lying in a northerly lines of said lands and being an easterly corner of Lot No. 99;thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin,being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle,Carlisle, Pennsylvania 17013. SUBJECT to a 10' wide utility easement along its street frontage. ALSO,UNDER AND SUBJECT to a sign easement in favor of Chesterfield Homeowners Association for the placement and maintenance of subdivision signage.This easement grants the Homeowners Association the right to enter the premises herein described for the purpose of maintaining the sign and the landscaping surrounding the sign. UNDER AND SUBJECT to any existing covenants,easements,encroachments,conditions,restrictions,and agreements affect the property,visible or of record. 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013. BEING the same premises which JAMES W.CLARK III AND EVA G.CLARKE,HUSBAND AND WIFE by deed dated January 30,2010 and recorded February 8,2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201003313,granted and conveyed to Angela Dawn Christopher,married woman,in fee. TAX MAP PARCEL NUMBER:05-19-1647-240 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 n CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 0- + ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#3136731 123 South Broad Street,Suite 1400 -� Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW M&T Bank COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Angela Dawn Christopher Number 13-3217 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 Your house(real estate)at 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013 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$228,444.24 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to M&T Bank the back payments,late charges,costs, and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) V. 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)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION All THAT CERTAIN tract of land situated in the Borough of Carlisle,Cumberland County,Pennsylvania, being Lot No. 100, as shown on a Plan entitle,Chesterfield(formerly Greystone Manor), Single-Family Residential Development,Final Subdivision/Land Development Plan, Section 2A, dated December 8,2000 by PennaTerra Enginnering,Inc., State College,Pennsylvania,being bounded and described as follows: BEGINNING at an iron pin,being a northerly corner of Lot No. 99 and lying in a southerly right of way line of Kingsbridge Circle(60 foot right of way,28 foot wide cartway);thence along said right of way along a curve to the left,having a chord bearing of North 42 degrees 31 minutes 34 seconds East, a chord distance of 44.41 feet,a radius of 180.00 feet and an arc length of 44.52 feet to an iron pin,lying in a southerly line of said right of way and being a westerly corner of Lot No. 101;thence along said lot South 54 degrees 33 minutes 37 seconds East, 182.95 feet to an iron pin,being a southerly corner of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way);thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.18 feet to a concrete monument to be set, lying in a westerly line of said right of way and being a northeasterly corner of lands owned now or formerly by Richard A. and Elizabeth A.Damico(Deed Book 201,Page 692);thence along said lands South 85 degrees 42 minutes 00 Seconds West, 57.09 feet to an iron pin,lying in a northerly lines of said lands and being an easterly corner of Lot No. 99;thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin,being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle,Carlisle, Pennsylvania 17013. SUBJECT to a 10' wide utility easement along its street frontage. ALSO,UNDER AND SUBJECT to a sign easement in favor of Chesterfield Homeowners Association for the placement and maintenance of subdivision signage. This easement grants the Homeowners Association the right to enter the premises herein described for the purpose of maintaining the sign and the landscaping surrounding the sign. UNDER AND SUBJECT to any existing covenants,easements,encroachments,conditions,restrictions, and agreements affect the property,visible or of record. 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013. BEING the same premises which JAMES W. CLARK III AND EVA G.CLARKE,HUSBAND AND WIFE by deed dated January 30,2010 and recorded February 8,2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201003313,granted and conveyed to Angela Dawn Christopher,married woman,in fee. TAX MAP PARCEL NUMBER: 05-19-1647-240 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 13-3217 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK Plaintiff(s) From ANGELA DAWN CHRISTOPHER (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 gamishee(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: $228,444.24 L.L.: $.50 Interest 8/3/13-$4,656.20 AT$37.55 Atty's Comm: Due Prothy: $2.25 Atty Paid: $183.53 Other Costs: Plaintiff Paid: Date:August 16,2013 David D. Buell,Prothonota (Seal) By: Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for:PLAINTIFF Telephone:215-790-1010 Supreme Court ID No. 17616 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Atto_rneys for Plaintiff MARC S. WEISBERG ESQUIRE-ID# 17616 +" EDWARD D. CONWAY,ESQUIRE -ID#34687 �''y cifo �rj MARGARET GAIRO, ESQUIRE-ID# 34419 U""3 NOY _ ANDREW L. MARKOWITZ, ESQUIRE- ID# 28009 ' HEIDI R. SPIVAK, ESQUIRE-ID#74770 C17-13ERL/-diD COUNT` MARISA J. COHEN, ESQUIRE-ID# 87830 PE MNI S YLVANIA KEVIN T. MCQUAIL, ESQUIRE-ID#307169 CHRISTINE L. GRAHAM, ESQUIRE-ID# 309480 BRIAN T. LAMANNA, ESQUIRE-ID#310321 ANN E. SWARTZ, ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID# 57716 JOSEPH 1. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN, ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-3217 Angela Dawn Christopher 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 Sheriff s 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 CONWAY,P.C. BEFORE ME THIS 30 DAY BY: s' C- ii [ ]Terrence J.McCabe,Esquire [ ar . Weisberg,Esquire OF b r 12013 [ ]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 NOTARY PUBLIC [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA NO SEAL MAIA KUSHICK,No Public City of Philadelphia,Phila.County M Commission Expires Ma 10,2017 File#72549 Page 5 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-3217 Angela Dawn Christopher 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 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013,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 Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 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 Discover Bank 12 Reads Way New Castle,Delaware 19720 File#72549 Page 1 Discover Bank c/o Weltman,Weinberg&Reis,Co. 436 Seventh Avenue, Suite 1400 Pittsburgh,Pennsylvania 15219 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Mortgage Electronic Registration P.O.Box 2026 Systems,Inc. Flint,Michigan 48501-2026 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 Chesterfield Manor Homeowners P.O.Box 71005 Association Newnan,Georgia 30274 S&A Custom Build Home.,Inc. 5005 Carlisle Pike Mechanicsburg,Pennsylvania 17055 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 8 Kingsbridge Circle Carlisle,Pennsylvania 17013 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 File#72549 Page 2 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept. of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#72549 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 10/ 3') McCABE,WEISBERG AND CONWAY,P.C. DATE < BY: [ ]Terrence J.Mc abe,Esquire [0,tTv'fa—rc �V��dislberg,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:M&T Bank v.Angela Dawn Christopher. et al. Cumberland County;Number: 13-3217 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Angela Dawn Christopher Number 13-3217 Defendant DATE: October 29,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Angela Dawn Christopher PROPERTY: 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $228,444.24 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. r '+ ro 4 ° =-Pm to 'i �?"n A A 5 A 7 UQ e a E �r QQ C /'• � V C m ly 6 as f7 ono J o°o ° b K, N m p eD < r. 0n ` �oess d -i Oe eod ►s p-�° �r"ti o� a-��,o a+ ►rJ` ee 'ab�1V, n >x b0on C�00* 0<0d0�cl Oa ° a C = ° o a 4 � "3 O _ eDw � ; i y C/1� eD v. �� eD in'� < n`Y v� '•Z C = Zy �� y� sC•' c� a �OeD OHO A7 C O :rN�y C Q cc o2 N�,r'�, -�s Cow ft -�s eo� � "�� der A�eo•, � d"I N •wA � 'd�.O O.IQ 00 C 00 IQ 7Q rA eD eD Go eD eD � G � Ss eD eD OV*- y - Ay : y N C1OQ> yws < n .00 C �C C oo o. o 0 w o y �'•d o '.A b ao ft °•eb 3�. . 00 eD< 00 eD < c° aQ 7 r 0NO .< „� o eD O O A y r+ eD Gp .C' V1'°3 vC vCi eb eo 00 O -1 ^t w w o-Cy"•! 07 W a 3 5 CD eD O O O eD eD p7 C� eeDD A7 n. o, ry eD O yin CON ^ ON�� Cn O W Ito � O cn a co D Aft D I v 1O '0 to N I m M < N yy a3 m 0 w O Y1 y O (n. t11 .'r� C N� eD O A p �° A+ O C/�'.�. C O C/I^� ... 00 �. th C: _O O .r n A ►< < a� td A n C� eD dG�a eD dG�a �v't1i?,a '.oa o eae C A A D O A CD O .t � m � C, = y aq R C O � ryq O C O ,fir C C op CD � � � dA ems+ K i� 'O .7'N to �_ ' -1. ^�eD � ° � vam C � ay bW C' �G1"id0 C'a ,�,, Q v O � < O eeb F < "O ft ara C.r fQ �. �� b Z��A >N� 0 �fD �� eb � � V7C CD CD O a C Ce --4w vii < w V]�1...'* n ��A "" n �,°� A eD C �A7 O O �A7 G O O b� � t TO n�' �'+`"' (� !v,*� �A eaD `t y CSC O y �' O O Y �O �' �,O C O A C I A OO. O�C n O�.n' �p C A O�•ei J'��C,�p n 'sJ'TJ'a+ QY> o A a:n fD �`d s. »>a rA W B ro ; A pN W rA M 11 C A > 'eD eD N N p, O .1. CO C OO � C O� O �.n• p C CD DD �eD j,N:YfD y va of ,o� �, a to CO m c* o, Coro fD y eD n 00 d ft w EA C O N ^C eD p A � C O M � cE G & | I $ - 2 o � § § X22 2 � $ 2 Oil * 0 \ E k / ƒ k ■(IQ ■_ + m # � q k # R ¢ ) % 2 \ © @ k k o W CD / G2� o ƒ k § R SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ` Chief Deputy °'� H 4 JF3 1�7 ri4 11, Richard W Stewart Solicitor QFF CE cr.THE$.1.ERiFF M&T Bank Case Number vs. 2013-3217 Angela Dawn Christhoper SHERIFF'S RETURN OF SERVICE 09/20/2013 02:12 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Angela Dawn Christhoper at 509 W. North Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 09/20/2013 02:28 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 8 Kingsbridge Circle, Carlisle- Borough, Carlisle, PA 17013, Cumberland County. 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$1.00 to Attorney Terrance McCabe, on behalf of M &T Bank, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,310.39 SO ANSWERS, January 10, 2014 RONNY R ANDERSON, SHERIFF a, a_c Pd. 1,. t,41, elk x'1/5-5. 38aS7 cuntyS,nte Snenff,Telecsnft,Inc. McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 • JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. NO: 13-3217 Angela Dawn Christopher 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: 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013,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 Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 • 2. Name and address of Defendant in the judgment: Name Address Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 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 Discover Bank 12 Reads Way New Castle,Delaware 19720 Discover Bank c/o Weltman,Weinberg&Reis,Co. 436 Seventh Avenue, Suite 1400 Pittsburgh,Pennsylvania 15219 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 Chesterfield Manor Homeowners P.O.Box 71005 Association Newnan,Georgia 30274 S&A Custom Build Homes,Inc. 5005 Carlisle Pike Mechanicsburg,Pennsylvania 17055 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 8 Kingsbridge Circle Carlisle,Pennsylvania 17013 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. BY: lC/L LI I 6 Terrence J.McCabe,Esq. [ arc S.We sberg,Esq. DATE [ ] Edward D.Conway,Esq. [ ] Margaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION . All TIAT CERTAIN tract of land situated in the Borough of Carlisle,Cumberland County, Pennsylvania, being Lot No. 100, as shown on a Plan entitle,Chesterfield(formerly Greystone Manor), Single-Family Residential Development,Final Subdivision/Land Development Plan, Section 2A, dated December 8,2000 by PennaTerra Enginnering,Inc., State College, Pennsylvania,being bounded and described as follows: BEGINNING at an iron pin,being a northerly corner of Lot No. 99 and lying in a southerly right of way line of Kingsbridge Circle(60 foot right of way,28 foot wide cartway);thence along said right of way along a curve to the left,having a chord bearing of North 42 degrees 31 minutes 34 seconds East,a chord distance of 44.41 feet,a radius of 180.00 feet and an arc length of 44.52 feet to an iron pin, lying in a southerly line of said right of way and being a westerly corner of Lot No. 101;thence along said lot South 54 degrees 33 minutes 37 seconds East, 182.95 feet to an iron pin,being a southerly corner of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way);thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.18 feet to a concrete monument to be set,lying in a westerly line of said right of way and being a northeasterly corner of lands owned now or formerly by Richard A. and Elizabeth A.Damico(Deed Book 201,Page 692);thence along said lands South 85 degrees 42 minutes 00 Seconds West,57.09 feet to an iron pin,lying in a northerly lines of said lands and being an easterly corner of Lot No. 99;thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin,being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle,Carlisle, Pennsylvania 17013. SUBJECT to a 10' wide utility easement along its street frontage. ALSO,UNDER AND SUBJECT to a sign easement in favor of Chesterfield Homeowners Association for the placement and maintenance of subdivision signage. This easement grants the Homeowners Association the right to enter the premises herein described for the purpose of maintaining the sign and the landscaping surrounding the sign. UNDER AND SUBJECT to any existing covenants,easements,encroachments,conditions,restrictions,and agreements affect the property,visible or of record. 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013. BEING the same premises which JAMES W.CLARK III AND EVA G.CLARKE,HUSBAND AND WIFE by deed dated January 30,2010 and recorded February 8,2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201003313, granted and conveyed to Angela Dawn Christopher,married woman,in fee. TAX MAP PARCEL NUMBER: 05-19-1647-240 - McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE'J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARLS.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 CIVIL ACTION LAW M&T Bank COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Angela Dawn Christopher Number 13-3217 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Angela Dawn Christopher 509 West North Street Carlisle,Pennsylvania 17013 Your house(real estate)at 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013 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$228,444.24 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to M&T Bank the back payments,late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may fmd 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 fmd 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)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION • All THAT CERTAIN tract of land situated in the Borough of Carlisle, Cumberland County,Pennsylvania, being Lot No. 100,as shown on a Plan entitle,Chesterfield(formerly Greystone Manor), Single-Family Residential Development,Final Subdivision/Land Development Plan, Section 2A, dated December 8,2000 by PennaTerra Enginnering,Inc., State College,Pennsylvania,being bounded and described as follows: BEGINNING at an iron pin,being a northerly corner of Lot No. 99 and lying in a southerly right of way line of Kingsbridge Circle(60 foot right of way,28 foot wide cartway);thence along said right of way along a curve to the left,having a chord bearing of North 42 degrees 31 minutes 34 seconds East, a chord distance of 44.41 feet,a radius of 180.00 feet and an arc length of 44.52 feet to an iron pin,lying in a southerly line of said right of way and being a westerly corner of Lot No. 101;thence along said lot South 54 degrees 33 minutes 37 seconds East, 182.95 feet to an iron pin,being a southerly corner of said lot and lying in a westerly right of way line of Meetinghouse Spring Road (60 foot right of way);thence along said right of way South 04 degrees 04 minutes 35 seconds East 72.18 feet to a concrete monument to be set, lying in a westerly line of said right of way and being a northeasterly corner of lands owned now or formerly by Richard A.and Elizabeth A.Damico(Deed Book 201,Page 692);thence along said lands South 85 degrees 42 minutes 00 Seconds West,57.09 feet to an iron pin,lying in a northerly lines of said lands and being an easterly corner of Lot No.99;thence along said lot North 40 degrees 23 minutes 16 seconds West, 196.45 feet to an iron pin,being the place of BEGINNING. HAVING THEREON erected a dwelling house known and numbered as 8 Kingsbridge Circle,Carlisle, Pennsylvania 17013. SUBJECT to a 10' wide utility easement along its street frontage. ALSO,UNDER AND SUBJECT to a sign easement in favor of Chesterfield Homeowners Association for the placement and maintenance of subdivision signage.This easement grants the Homeowners Association the right to enter the premises herein described for the purpose of maintaining the sign and the landscaping surrounding the sign. UNDER AND SUBJECT to any existing covenants,easements,encroachments,conditions,restrictions,and agreements affect the property,visible or of record. 8 Kingsbridge Circle,Carlisle,Pennsylvania 17013. BEING the same premises which JAMES W.CLARK III AND EVA G.CLARKE,HUSBAND AND WIFE by deed dated January 30,2010 and recorded February 8,2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201003313,granted and conveyed to Angela Dawn Christopher,married woman, in fee. TAX MAP PARCEL NUMBER: 05-19-1647-240 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3217 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK Plaintiff(s) From ANGELA DAWN CHRISTOPHER (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:$228,444.24 L.L.: $.50 Interest 8/3/13-$4,656.20 AT$37.55 Atty's Comm: Due Prothy: $2.25 Atty Paid: $183.53 Other Costs: Plaintiff Paid: Date: August 16,2013 David D. Bu-11,Prothonotary (Seal) ` • ■ _ ' • Zed Deputy REQUESTING PARTY: Name: MARC S. WEISBERG,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 TRUE COPY FROM RECORD In Testimony whereof,I here unto set my hand and the seal of said Court at Carlisle,Pao This___ LL day of / Ai/et (prothonotary • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-3217 Civil Term easterly corner of Lot No.99;thence along said lot North 40 degrees 23 MBsT BANK minutes 16 seconds West, 196.45 vs. feet to an iron pin,being the place of ANGELA DAWN CHRISTHOPER BEGINNING. Atty.:Terrance McCabe HAVING THEREON erected a dwelling house known and numbered All THAT CERTAIN tract of land as 8 Kingsbridge Circle, Carlisle, situated in the Borough of Carlisle, Pennsylvania 17013. Cumberland County, Pennsylvania, SUBJECT to a 10' wide utility being Lot No. 100, as shown on a easement along its street frontage. Plan entitle, "Chesterfield (formerly ALSO, UNDER AND SUBJECT Greystone Manor), Single-Family to a sign easement in favor of Ches- Residential Development,Final Sub- terfield Homeowners Association for division/Land Development Plan, the placement and maintenance of Section 2A,"dated December 8,2000 subdivision signage. This easement by PennaTerra Engineering, Inc., grants the Homeowners Association State College, Pennsylvania, being the right to enter the premises herein bounded and described as follows: described for the purpose of main- BEGINNING at an iron pin,being taining the sign and the landscaping a northerly corner of Lot No. 99 and surrounding the sign. lying in a southerly right of way line UNDER AND SUBJECT to any of Kingsbridge Circle(60 foot right of existing covenants, easements, way, 28 foot wide cartway); thence encroachments, conditions, restric- along said right of way along a curve tions, and agreements affect the to the left,having a chord bearing of property,visible or of record. North 42 degrees 31 minutes 34 sec- 8 Kingsbridge Circle, Carlisle, onds East,a chord distance of 44.41 Pennsylvania 17013. feet, a radius of 180.00 feet and an BEING the same premises which arc length of 44.52 feet to an iron pin, JAMES W. CLARK III AND EVA G. lying in a southerly line of said right CLARKE, HUSBAND AND WIFE by of way and being a westerly corner deed dated January 30, 2010 and of Lot No. 101; thence along said recorded February 8, 2010 in the lot South 54 degrees 33 minutes 37 office of the Recorder in and for Cum- seconds East, 182.95 feet to an iron berland County in Deed Instrument pin,being a southerly corner of said #201003313,granted and conveyed lot and lying in a westerly right of way to Angela Dawn Christopher,married line of Meetinghouse Spring Road(60 woman,in fee. foot right of way); thence along said TAX MAP PARCEL NUMBER:05- right of way South 04 degrees 04 19-1647-240. minutes 35 seconds East 72.18 feet to a concrete monument to be set, lying in a westerly line of said right of way and being a northeasterly corner of lands owned now or formerly by Richard A.and Elizabeth A. Damico (Deed Book 201, Page 692); thence along said lands South 85 degrees 42 minutes 00 Seconds West,57.09 feet to an iron pin,lying in a north- erly lines of said lands and being an 32 • 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. isa Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 �.✓�� Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 4120 Technology Pkwy htPiàitiiiis 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. lseagl aql 1e 1-wvu r,._-,fl- .-,gig O11�17 CIA'Sinn 2 t NA 1/ SANK This ad ran on the date(s)shown below: vs. I 10/13/13 ANGELA DAWN t $TNOPER ' AtsP: RTAINos+MeCabe , /,��/ 10/20/13 All THAT rough of saris of land situated l 10/27/13 in the Borough of Catlisk, Cnndrethnd ��, r /� County, ieuesylxauia, Let No 100, / /2 c,,__— i j as shown ou a Phs aitilk"old //`/ / r//% (fly : k - ,1 . . (I Rim* 'Rehisitild Pesegesitak Final *tin'2Aildfont x` worn to and subscribed bef.ime this 11 day of November, 2013 A.D. 1 s.: y, \ . 1 ■ 1 , . o ary Pu• is Cite(60 r ` ' •., . ; a PO pa the left,hstififi a rba'd heat* of North 42 degrees 3I woods East,a.chord distance of 44.41 Wit,a radius COMMONWFAL OF PENNSYLVANIA X 180.00 feet mi ium length of 4452 feet r 1 i Seal YO en kon*IyinginsouthWine of said Holly t.rwr?4 &,Notary Public right of way mid being,a corner of Wasrpo w ,r ;?rraphin County Lot Nb.101; Send+54 My Comm+ k;,c, a res Dec.12,2016 degrees 33 minutes 37 seconds East,182.95 i MEMBER PENNSYIVAVd .,,OCIATION Of NOTARIES feet to an iron pin,being a southerly comer 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 M& T Bank 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 16th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3217, at the suit of M & T Bank against Angela Dawn Christopher is duly recorded as Instrument Number 201401145. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /5 day of J U , A.D. a0)11 )Kcoutt, a )thy, De/DA/ Recorder of Deeds Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018