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HomeMy WebLinkAbout13-4010 Supreme Courtof`Pennsylvania Court o %Common Pleas For Prothonotary Use Only: C vil�Cove . eS e,'t t Docket No: a� CUMBERLAND County ' v, r. The h collected on this form is used solely for court adntinistration purposes. This form doe' not suppleynent or replace the filing and service of pleading s or other papers as required by law or rules of cotirl. Commencement of Action: S 0 Complaint El Writ of Summons 0 Petition E Transfer from Another Jurisdiction 0 Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Members 1st Federal Credit Union Helen J. Starner I Are money damages requested? 'x Yes 0 No Dollar Amount Requested: Swithin arbitration limits 0 (check one) Doutside arbitration limits N Is this a ClassAction Suit? 0 Yes 0 No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff /Appellant's Attorney: Christopher E. Rice, Esquire /Martson Law Offices 0 Check here if you have no attorney (are a Self - Represented 11 Sel 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 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other 0 Board of Election's 0 Nuisance Dept. of Transportation D Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include E mass tort) 0 Employment Dispute: 0 Slander /Libel/ Defamation Discrimination C 0 Other: Employment Dispute: Other 0 Zoning Board 'I' 0 Other: I Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES Toxic Tort -Implant Toxic Waste REAL PROPERTY MISCELLANEOUS 0 Other: Ejectment 0 Common Law /Statutory Arbitration B Eminent Domain /Condemnation 1. Declaratory Judgment 0 Ground Rent Mandamus ( Landlord/Tenant Dispute Non- Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical Other: Other Professional: Updated 1!112011 q L� C= FAF1LES\ C1ients \11470 Memberslst \11470 Current\ 11470.279 Starner \] 1470.279.comp,wpd .-�:1 t.r.) •- '"'"7 n Co Christopher E. Rice, Esquire z i� Attorney I.D. No. 90916�a R. Christopher VanLandingham, Esquire C Attorney I.D. No. 307424 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ��- 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff MEMBERS 1 FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 13 - ` � TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER Contact: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249 -3166 0 10 S. - I s 1 a j. ca go ag3�)s NOTICE REQUIRED UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601 (AS AMENDED) AND THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA. CON. STAT. ANN. §201, ET SEQ. ( "THE ACTS ") To the extent the Acts may apply, please be advised of the following: 1. The amount of the original debt is stated in the Complaint attached hereto. 2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is filing this Complaint on behalf of the Creditor. 3. The debt described in the Complaint attached hereto and evidenced by the copies of the note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty (30) days after receipt of this notice, disputes the validity of the debt or some portion thereof. 4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor(s) by the Creditor's law firm. 5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty days from the receipt of this notice, the name and address of the original Creditor will be mailed to the Debtor(s) by the Creditor's law firm. 6. Requests can be made to: MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Attn: Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 (717) 243 -3341 * THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Christopher E. Rice, Esquire Attorney I.D. No. 90916 R. Christopher VanLandingham, Esquire Attorney I.D. No. 307424 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff MEMBERS 1 ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 13 - CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, ; Defendants : IN MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes the Plaintiff, MEMBERS 1s` FEDERAL CREDIT UNION, by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and files this Complaint in Mortgage Foreclosure upon the following: 1. Plaintiff, Members 1" Federal Credit Union ( "Plaintiff'), is a federally chartered credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055. 2. Defendants, Helen J. Starner and Michael Starner ( "Defendants "), are adult individuals residing at 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania 17241. 3. Defendants are the owners of the real property located at 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania 17241 ( "Real Property"), and more fully described in a certain deed recorded in the Recorder of Deeds Office of Cumberland County, Deed Book 270, Page 2158, which is encumbered by the Mortgage described below. 4. On or about January 26, 2006, Defendants executed a promissory note (the "Note ") with Plaintiff in the amount of $32,000.00. A true and correct copy of the Note is attached hereto as Exhibit "A" and is incorporated herein by reference. 5. As security for the performance of their obligations under the Note, Defendants, as Mortgagors, made, executed and delivered to Plaintiff, as Mortgagee, a mortgage upon the Real Property (the "Mortgage "). A true and correct copy of the Mortgage containing a complete legal description of the Real Property is attached hereto and incorporated as Exhibit `B." 6. The Mortgage has not been assigned. 7. Defendants are the owners of the Real Property, and Plaintiff knows of no other persons holding an ownership interest in the Real Property. 8. Plaintiff has made demand for payment of all sums due and owing thereunder, but payment has been refused. 9. Plaintiff provided Defendants with notice of the period in which Defendants' default may be cured, but Defendants have failed to cure their default. 10. As authorized under the Mortgage, the loan obligation to Plaintiff from the Defendants has been accelerated. 11. The total sum due and owing from Defendants under the Note, as of July 19, 2013, is itemized as follows: Principal: $15,575.84 Late Fees: $ 60.19 Interest as of July 19, 2013: $ 1,124.69 Court Costs and Fees (estimated): $ 500.00* Attorney Fees: $ 4,000.00 Total as of July 19, 2013: $21,260.72 Plus interest accruing at $3.70 per day from July 19, 2013, until paid in full. *To be determined by the Cumberland County Sheriff. 12. Plaintiff specifically reserves the right to increase the Court Costs and Fees, and Attorney Fees listed above should additional services be requested and /or costs /charges /fees be incurred as a result of the collection of the money owed and foreclosure of the Real Property. 13. Pursuant to the notice provision of Act 6, 41 P.S. § 403, and Act 91, 35 P.S. § 1680.403(c) (collectively, the "Notice "), Plaintiff sent notices of intention to foreclose mortgage and of the mortgage assistance program dated May 21 2013, to Defendants by certified mail, return receipt requested. WHEREFORE, Plaintiff demands judgment against Defendants under the Note in the amount of $21,260.72, plus interest from July 19, 2013, at the rate of $3.70 per day until the debt is paid in full. MARTSON LAW OFFICES By: L� ; . /Z-- Christopher E. Rice, Esquire I.D. No. 90916 R. Christopher VanLandingham, Esquire I.D. No. 307424 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Date: k 1-y �� , 2013 Attorneys for Plaintiff This is a debt collecting firm for Members V Federal Credit Union. Any information obtained will be used for that purpose. EXHIBIT "A" St CLOSED -END NOTE, DISCL09U 00 00 LOUIeO DrNs, I80it40 e0 RR 0 NFJl 7 1NMa!AMDAOORlaa Macharllaburp, 1 17406 HELEN J STARNER U L R tih•wuhrr 4 . RAIL PRINCIPAL AMI L H.99x IC NAME Co. x Flxeo ANNUAL P QYARMOLE ERCENTAGE FINANCE CHARGE Artmutt Fhartced: The amount r>< Total or Payrnenq; TIN amotrN RATE: The coat a yo ur aed as s crnosst filar amOUrtt the CredE wl � ph0I to yoU a on y you wal have pail! after you Nava yearly rete rrnde a1 PaYmeata as ecttedubd. �t 8.98 X . i 10.197.D2 a i 32,000.00 VaHabla Run r rk■nhaa. tv jobl■,w i 4 8 ,197,02 aetl8 utbn wUl k e s neigh d m Ne ivtax wu kW alwn NN Amu, Poroanu0. RaN ma1� ktrnaa ' kaw. antl N w9 nwM M lau Nan . The ro b w+1 CbYrlEa atonally an IM f all dw oI Ihs monlh rN.wn d he tramadbn N NN &WI rhntp.a. The montlN and a s Amwl Parcw,bpe Rato � aRw owni halt h mom D9Ym9m4 d dN aarrN an+strN. Pa 8TH y ou' y a muknum F614 allowed by year, the win d yw Nan W"d;nmaaa b Iwo aa,000 N 1 PA for 44 fsrM Aab: N. hack.., N. NNOMaO W+PNq b yow bow A1MOmado Payroant Dkatreltbd Rkt■; B"W'Q You M" you In } ad P a w maker ye{V r�qu month tad, ow ANHLAI PERCENTAGE RATE II b een dNOOW2w %. Tha ANaIUAL PERCENT !�!'� OAO� m xuNmalk dadw.y(at Nom yew Checkhy8e�htpa an IM ^rao P+Ymant Dbmunted RaN, TNa W* wV Nyaau by .2dlk "K ^A;e dbdo°ad endw N MANNUAL PERGbNTAOE RAT6 ere. k cover a $ mO.Ymmoan VpaNwnn, h auoh a au, the ellaolol Nb �. uau M ■dontNb MyrttaM NanOdNNN a bN b malnbel MaNdM hutdY la a e,00Q00 ben fw 60 monlM end lnarwO w "h a. b" ad the r tam d yyoour , Par Nwm^ N Aubmktb naM OI � tlf Rate 16 1 m 4viMlal k Rail PwfarlOd loatr M you ceua atO autprttyb peYMaM unr ee oaMl fwta raw wE abroaaO b 10,7Dlk 1p dlt onNl� am akd RW q t0% prtdwrad ANNUAL k{ VW PERCENT O RA we d�v v ad b cha @r� f a DManad ralY. YCW PrW" O dkhxh aw mt b bkan al MO Ikw you hlw out PERCENTAGE RATE b 12% tint, btu the heron a by� tlyE b di.du4d..oval, For awn a, N . This we a m vary eemrd4 m tha Index, Is dlwao"d In P R - yN � ��ENTACB RAfE rR bO NMIk. Your WNwiI�O nN IanY WNy AWNK Filed PukrrOA LN ted ANNUAL PERCENTAGE taa U Yew tan b a falOtl bb lwn atq arbela Bahr poNabn P above, Pnfa PERCENTAGH RATE Aulese0.hove for u as eRW atkYia rernohs eRadolnk, Yaw ANNUAL PERCENTAGE RATE will be the PryfmNd ANNUAL NINT11WNPOymanw AI ofF yMrmRb P RIn"M Fiv"wtty When P Yew ayewnu An out P►ooeAv ran": YOU mev OW In ►°MbM 597.98' Inaua erryono 819 you wOM that ��ppb to ad's 'mo 63103/2000 m if a you y Get the Murarpe rom the Ml sea t 190.91 Final Due • On vAl _ O2Jt2A7010 i MIA on w M ab W9JV 16 loan. You an pMng a aa NW YI Oseda err oropry Othu Yaw awls aoIApeelIn the cnd Woon,attd � �OPNOnaaal �IDaaorblr Lab Cta wNe ymrl4 l=.=.d mnfeta you Yrq Raryu bk k b aaoou Dl=aaUYtoa:Trta rw ove AnnWPahlaee Raild PIB t a laic lu o} tRf vl POY�bnL rw1 O RM YOW rogJred dopeal balwaa. 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Wr. of d°tauy, INydtne os.b o(aob,ad na.ena N.•, drat IM andR a•ron a.ry Neta up to a0% o f lh. dUnts sN Me .M w Nolen or daht se •a►n.a. anon .h.ra ana R•tMa I nr y aM M A ° Ne p a�M" a "K °r �Yr,hana whNN may tra held N an 9ndlNaual Nqh Plea,^ YoU 9re �aOW aakoa 10 oueranlee Iltb debt. Tltlnk betas O You CE TO C0- E Pay n you haw lo, and Uwl you want to aooeq tnle�IDllRy. do. If the Willow doean 1 pay the debt, you wU1 have (o. ge wre you can albrd to debt frem "ho"t YOU meY Dave to Pay WWptoesrt�hpe Ay amount ofVtkhtoe dap C the borgroyxoeurrdoes not pay, YYoo ma also ° u n y hays o pay late fees or c can C61184 te dedlat coals, wMdt I"ma this ana rBp not tM Corxr'eq +iEa , 1lehle tleDL R""9 ' ver a� ul, IDei iea rna a acre a �rl cFy oi R 43760 1/02 APPRO n Vwft WW. 224.a7e Page 2 or 2 EXHIBIT 66B" Prepared By: Memt errs 1 st FCU 5000 Louise Drive ; Mechanicsburg, PA 17055 When recorded mail to: rD 3 �� 3 36 FIR$TA11IEttICAN TITLE ZNS UR�IVCE t �'' 1-128 EUC'LII3AVENUE, SUITE 400 CLEVELAN•b, OHIO 44115 ATTN.• FT1120 MORTGAGE Made OU26J2006 , { f ✓ z� Between HELEN J STARNER AND MICHAEL STARNER (hereinafter ea "Mortgagor") And MEMBERS IT FEDERAL CREDIT BUNION (hereinafter called "Mortgagee' Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note ") of even date herewith, payable to the order of Mortgagee in the principal sum of $ 32,000.00 , lawful money of the United States of America, and has provided therein For payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with Interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and containing certain other terms and conditions, all of which are specifically incorporated herein by reference; Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or under I the terms of the Note, does grant and convey unto Mortgagee, All that certain property of the Mortgagor located in WEST PENSBORO TQWNSJJ2 Cumberland. County, Pennsylvania SEE EXHIBIT'A" which currently has the address of 36 STONE LEDGE RD. [Street] Newville Pennsylvania 17241 [City] [Zip Code] I Acct No 206980 -06 AppID 1377 Page 1 of i K { 94OPCO6 I I t ' t Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversion's, remainders, rents, issues and profits thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever. Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and i discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, I including interest and penalties thereon, if arty, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged remises at any reasonable hour for the purpose of inspecting the order, condition and repair of the build ngs and improvements erected thereon. AodNo 206940 -06 Appm 137703 Page 2 of 4 i BK 1940PE06' 12 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the i principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a rarity with, the lien of this Mortgage. I (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum., additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (5 %) of the total indebtedness or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. j The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several Acct No 20644006 Appm 137703 Page 3 of 4 B t94oPG0613 Witness the due execution hereof the day and yeT first above written. ELEN J S - E MICHAEL STARNER Commonwealth of Pennsylvania ) ss: County of C„ml e r 1 a n d } I Onthis,the 26th day of Januar 7 2006 ,before me, Luanne E. Kyle n n t a ny j l, 7 i f , the undersigned officer, personally appeared Helen scn satisfactorily proven to me to be a Person(s) whose name (s) i are su a to the within Mortgage, and acknowledged that he /she executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. My commission expires; COMMONWALTH 2F EghM§M L VANjA Notarial5eal Luanne B, Kyle, Notary Publla Shtppensburg Boro, Cumberland County my Commission F..xplres Jan. 20, 2009 Member, Pennsyivanle Aasbcsatlan of Notaries - Certificate of Residence of Mortgagee Members 1ST Federal Credit Union, Mortgagee within named, hereby certifies that i residence is 5000 Louise Drive, Mechanicsburg, PA 17055. t sy Acct No 206940 -06 AppTD 137703 Page 4 of 4 9.aa EXHIBIT "A" LEGAL DESGRIPTION A PARCEL OF LAND SITUATED IN TAE STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND, WITH A STREET LOCATION ADDRESS OF 36 STONE LEDGE RD; NEWVILLE, PA 17241 -9457 CURRENTLY OPINED BY HELEN J. STARNER AND MICHAEL STARNER HAVING A TAX IDENTIFICATION NUKBER OF 10- 0618 -0018- 0000000 -46 AND BEING THE SANE PROPERTY MORE FULLY DESCRIBED IN BOOK /BADE OR DOCUMENT NUMBER 194 -319 AND FURTHER DESCRIBED AS LOT 11 PB26 PG 81. j 10- -0618- 0018 - 0000000 -46 36 STONE LEDGE RD; NEWVILLE, PA 17241 -9457 137703 llillll[Illllllllll IIIIISTR RNER 8752627 27328445/f/or FIRST AMERICAN LENDERS ADVANTAGE MORTGAGE Ilil 111 IIIIIIIIlIIIIIiIIIIIIAII Ill IIIIIlIU 1111 j � In ')LIlItY .IAA or 0 i n d VERIFICATI I , as an employee ofMembers I S` Federal Credit Union, acknowledge I have the authority ex gt y o eeut this Ver ificatio n on behalf of Members 1 Federal Credit Union and certify that the foregoing Complaint in Mortgage Foreclosure is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of this document is that of counsel and not my own. I have read the document and to the extent the Complaint is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent the content of the Complaint is that of counsel, I have relied upon counsel in making this Verification, This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. MEMBERS 1s FEDERAL CREDIT UNION By. �1 U - FAFILESICIlentakI 1410 MembenlsAl 1470 CunvntU 1470.279 StameAt 1470,279.comp.wP4 a C - Christopher E. Rice, Esquire MW Attorney I.D. No. 90916 r M C= rn,= r R. Christopher VanLandingham, Esquire c Attorney I.D. No. 307424 r" - MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER c .' C') MARTSON LAW OFFICES c 10 East High Street is Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff MEMBERS 1 sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 13 - CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE 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 Services for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 0-" � �. Christopher E. Rice, Esquire I.D. No. 90916 R. Christopher VanLandingham, Esquire I.D. No. 307424 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Date: '711 , 2013 Attorneys for Plaintiff ATTACH FINANCIAL WORKSHEET 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: CUSTONIER/PREN APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No Q, Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No 0 Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes [❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ . $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Y ear: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transaortation (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 ' M — ortgage Utilities Car Pa ens Condo/Neigh. Fees Auto Insurance Med. not covers Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Cary 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: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes F1 No If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lend__ettr's counsel: V Proof of income Y Past 2 bank statements Proof of any expected income for the last 45 days Y Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation 1 (hardship letter) V Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson I--*Lf O..OF h L a Sheriff c N !ai 'v.�rtr���t�,rtsr�y �,i� �C�� �reT��� Ci ,.iti i Jody S Smith Chief Deputy :° 2013 JUL 26 AM 10" 3 Richard W Stewart CUMBERLAND COUNTY Solicitor sic ` " PENNSYLVANIA Members 1st Federal Credit Union Case Number VS. 2013-4010 Helen Starner(et al.) SHERIFF'S RETURN OF SERVICE 07/22/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Helen Starner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 36 Stone Ledge Road, West Pennsboro Township, Newville, PA 17241. Residence is vacant and per the Newville Postmaster mail is delivered to the address provided. 07/22/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Starner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 36 Stoneledge Road, West Pennsboro, Newville, PA 17241. Residence is vacant and per the Newville Postmaster mail is delivered to the address provided. SHERIFF COST: $68.02 SO ANSWERS, July 22, 2013 RONW R ANDERSON, SHERIFF (c)CouhtySuite Sheriff,Telecsoft,Inc. FAFILES\C1ients\11470 Members I st\1 1470 Current\17470.279 Starner\11470.279.pra.reinstate.wpd W 't? t/) ; Christopher E. Rice, Esquire Attorney I.D. No. 90916 �a '- R. Christopher VanLandingham, Esquire o Attorney I.D. No. 307424 ° CD_11 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER x� MARTSON LAW OFFICES } 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE PRAECIPE To the Prothonotary of Cumberland County: Please reinstate the Complaint in the above-referenced matter and forward to the Sheriff for service upon Defendants. MARTSON LAW OFFICES By L/, � /7 Christopher E. Rice, Esquire I.D. No. 90916 R. Christopher VanLandingham, Esquire I.D.No. 307424 Ten East High Street ��� 7�Pd / Carlisle, PA 17013-3093 (717) 243-3341 Ck A.1 7s�� Date: 9/ , 2013 Attorneys for Plaintiffs-9S8'�f This is a debt collecting firm for Members IS` Federal Credit Union. Any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY t-, �., Ronny R Anderson ---i Sheriff tkl001 04 CstaraPec"r "'?;*t Jody S Smith (fir— is a Chief Deputy °. >tom- cat ?rte Richard W Stewart ---r ) f Solicitor ;,,:;F,a;F,OF 1Y E,Rtr ca .s4 '1'-' -..4 '! -< 1 Members 1st Federal Credit Union Case Number vs. 2013-4010 Helen Starner(et al.) SHERIFF'S RETURN OF SERVICE 09/24/2013 03:35 PM-Stephen Bender served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Starner at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. Per defendant the residence at 36 Stoneledge Road, Newville, PA is vacant. "e---( STEPHEN BENDER, DEPUTY 10/31/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Helen Starner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1156 Greenspring Road, N. Newton Township, Newville, PA 17241. Defendant was not located at either address provided to this office and was contacted by phone but refused to provide us with her current address and did not come into the office to pick up Complaint as promised, at this time the Complaint has expired. SHERIFF COST: $63.02 SO ANSWERS, gp_. . "'" . November 01, 2013 RONNY R ANDERSON, SHERIFF (o)Caunty Suite:^harifr Te!eosofi rnc F.\FILES\Clients\11470 Members 1st\11470 Current\11470.2795 tamer\11470.279.pra.reinstate.3.wpd 1111 l 9. • Christopher E. Rice, Esquire 2013 DEC - Attorney I.D. No. 90916 7 y Aaron S. Haynes, Esquire CUMBERLAN GOU Attorney I.D. No. 307746E �v1SYLA�tf� MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE PRAECIPE To the Prothonotary of Cumberland County: Please reinstate the Complaint in the above-referenced matter. MART:ON LAW OFFICES ay: % WIL/V C stosher E. Rice, Esqui le �. N•. 90916 A. o . Haynes, Esqui - :07746 ill. 73 { c" I.D. •. 307424 Ten East High Street (i ;--72 () Carlisle, PA 17013-3093 ,t0-17/1-7 (717) 243-3341 Date: a/VA? Attorneys for Plaintiff This is a debt collecting firm for Members 1st Federal Credit Union. Any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4�ti„vr,of Ctunbrt4„,,, i_'..' } I J :Hi.-.11 I, ,. Jody S Smith Chief Deputy s 3 tri: ! 7 �M .): Richard W Stewart F Solicitor �}_� [ 1 }FFICE�c THE ,1•1 - f---•/ N i£l r'”1" } Members 1st Federal Credit Union vs. Case Number Helen Starner(et al.) 2013-4010 SHERIFF'S RETURN OF SERVICE 12/11/2013 07:08 PM - Deputy Shawn Harrison, being duly sworn according to law, served t . requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint i f ortga•- oreclosure by "personally" handing a true copy to a person representing themselve . t - '-fendant, to wit: Helen Starner at 141 East Main Street, Mechanicsburg Borough, Mechanic• • P' 155. ,ti,/.1/ S AWN -ISON, DEPUTY SHERIFF COST: $39.76 SO ANSWERS, H,.,..,..a 'KI December 12, 2013 RONR ANDERSON, SHERIFF (G Ccunt Suite;Sheri'(.Teieesort Inc. F:\FILES\Clients\11470 Members Ist \11470 Current \11470.279 Starner\ 11470 .279,Starner.MotiontoLiftStay Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff pd r-CF-FiCE T HE p t©TNCIHt; IA 7 Y 29R fiAP -5 PH 3: O CUMBERLAND COUNTY PENNSYLVANIA OTTO GILROY & FALLER MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE PLAINTIFF'S MOTION TO LIFT THE STAY AND NOW, comes Plaintiff Members 15` Federal Credit Union, by and through its attorneys, MARTSON LAW OFFICES, and files this Motion to Lift the Stay as follows: 1. Plaintiff, Members 151 Federal Credit Union ( "Plaintiff'), is a federally chartered credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055. 2. Defendant, Helen J. Starner ( "Defendant "), is an adult individual residing at 141 East Main Street, Mechanicsburg Borough, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant, Michael Starner ( "Defendant "), is an adult individual residing at 389 Georgetown Road, Gardners, Adams County, Pennsylvania. 4. On July 12, 2013, Plaintiff filed a Complaint in the above - captioned mortgage foreclosure action, and forwarded a copy of the Complaint to the Cumberland County Sheriff for service upon Defendants. 5. Cumberland County Sheriffs were unable to serve Defendants at that time. 6. Plaintiff reinstated a Complaint in the above-captioned mortgage foreclosure action on or about September 20, 2013, and forwarded a copy of the Complaint to the Cumberland County Sheriff for service upon Defendant. 7. The Complaint included a Notice of the Cumberland County Residential Mortgage Foreclosure Diversion Program as well as the Financial Worksheets. (See Complaint). 8. According to the Sheriff's Return of Service, attached hereto and incorporated herein as Exhibit "A," Defendant Michael Starner was served with the reinstated Complaint on September 24, 2013. 9. Defendant Michael Starrier informed Sheriffs that the property which is the subject of this mortgage foreclosure action is vacant, and Defendant Helen J. Starner did not reside at the premises. 10. On December 30, 2013, Defendant Michael Starner filed for Chapter 7 Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania, which placed an automatic stay on any action against Defendant Michael Starner. 11. On January 23, 2014, Plaintiff filed a Motion for Relief from Automatic Stay, informing the Court that a stay would have a direct impact on the interests of Plaintiff if the stay were to remain in place. 12. On February 8, 2014, the Honorable Mary D. France, Chief Bankruptcy Judge for the U.S. Bankruptcy Court, Middle District ofPennsylvania granted Plaintiff s Motion, allowing Plaintiff to proceed with legal remedies against Defendant Michael Starner in foreclosure. 13. Prior to Defendant Michael Starner's filing for Chapter 7 Bankruptcy, Plaintiff re- instated a Complaint in the above-captioned mortgage foreclosure action on or about December 9, 2013, against Defendant Helen J. Starner, and forwarded a copy of the Complaint to the Cumberland County Sheriff for service upon Defendant. 14. The Complaint included a Notice of the Cumberland County Residential Mortgage Foreclosure Diversion Program as well as the Financial Worksheets. (See Complaint). 15. According to the Sheriff's Return of Service, attached hereto and incorporated herein as Exhibit "B," Defendant Helen J. Starner was served with the reinstated Complaint on December 11, 2013. 16. Per Administrative Order dated February 28, 2012, a 60 day Automatic Stay is placed on all residential mortgage foreclosure actions in Cumberland County. 17. In order to participate in the Cumberland County Mortgage Diversion Program, both Defendants were required to file a Request for Conciliation Conference within 60 days of the date of service of the Complaint. Said 60 day deadline expired on February 10, 2014. 18. Upon information and belief, neither Defendants have filed a Request for Conciliation Conference in this matter and have not opted into the Diversion Program. 19. No judge has previously ruled in this matter. 20. Plaintiff has written to Defendants requesting concurrence in this motion. Defendants have not responded and therefore, Plaintiff presumes Defendants do not concur. WHEREFORE, Plaintiff requests this Court issue an Order lifting the Stay in this matter. Date: MARTSON LAW OFFICES By: r Christopher E. Rice, Esquire I.D. No. 90916 Aaron S. Haynes, Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 , 2014 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit Union. Any information obtained will be used for that purpose. Ronny R Anderson Sheiiff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SHERiFc Members lst Federal Credit Union vs. Helen Starner (et al.) Case Number 2013-4010 SHERIFF'S RETURN OF SERVICE 08/24/2013 03:35 PM - Stephen Bender served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personaily" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Starner at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013, Per defendant the residence at 36 Stoneledge Road, Newville, PA is vacant. -STEPHEN BENDER, DEPUTY 10/31/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Helen Starner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 1156 Greenspring Road, N. Newton Township, Newville, PA 17241. Defendant was not located at either address provided to this office and was contacted by phone but refused to provide us with her current address and did not come into the office to pick up Complaint as promised, at this time the Complaint has expired. SHERIFF COST: s63.O2 SO ANSWERS November O1.2O13 RONN R ANDERSON, SHERIFF cc) CounlySuite Sheriff, Teleosoff, Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY eom ot (1111 4 OFFICE OF THE SHERIFF LEJLft :r PPCTHO 2f.113 DEC 1 7 AM 9: 50 U hIpBEEt:414LsAy!ii%.1,04 T Members 1st Federal Credit Union vs. Helen Starner (et al.) Case Number 2013-4010 SHERIFF'S RETURN OF SERVICE 12/11/2013 07:08 PM - Deputy Shawn Harrison, being duly sworn according to law, served t requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint i ort a oreclosure by "personally" handing a true copy to a person representing themselve -fendant, to wit: Helen Starner at 141 East Main Street, Mechanicsburg Borough, Mechanic 55. S AWN 1SON, DEPUTY SHERIFF COST: $39.76 SO ANSWERS, December 12, 2013 RONRR ANDERSON, SHERIFF (c) County Suite Sheriff, Teleosoft, CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Motion to Lift the Stay was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Helen J. Starner 141 East Main Street Mechanicsburg, PA 17055 Mr. Michael Starner 389 Georgetown Road Gardners, PA 17324 MARTSON LAW OFFICES By: Dated: 3/5/17 ) a IPrice Ten E. High Street Carlisle, PA 17013 (717) 243-3341 MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2013 - 4010 CIVIL TERM HELEN J. STARNER, MICHAEL STARNER, Defendant : IN MORTGAGE FORECLOSURE ORDER AND NOW, this 1 .' day of rh , 2014, upon consideration of Plaintiff s Motion to Lift the Stay, it appearing that Defendants have not opted in to the Cumberland County Residential Mortgage Foreclosure Diversion Program by filing a Request for Conciliation Conference within 60 days of the date of service upon them of the Complaint in this action, and it further appearing that the 60 day deadline to file the said Request has expired, said Motion is hereby granted and it is Ordered that the Stay is hereby lifted. Wstribution to: Christopher E. Rice Esquire MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 Counsel for Plaintiff /i■/Is. Helen J. Starner 141 East Main Street Mechanicsburg, PA 17055 Pro Se Michael Starner 389 Georgetown Road Gardners, PA 17324 Pro Se Cp1 117,ttc-c- 21 ° BY THE COURT, A AL . 4 F:\FILES\Clients\11470 Members 1st\11470 Current\11470.279 Starner\11470.279.pra.default.wpd Christopher E. Rice, Esquire 2[ 1 MAR 21 49 10: ►, - Attorney I.D. No. 90916 Aaron S. Haynes, Esquire C L'M B E rl_A N: PENNSYLVANIA SYLVANIA Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13 - 4010 CIVIL TERM • HELEN J. STARNER and • MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants Helen J. Starner and Michael Starner in the amount of$21,260.72, plus interest from July 19, 2013 at the rate of$3.70 per day,until the debt is paid in full for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that written notice of intention to file this Praecipe was mailed to Defendants Helen J. Starner and Michael Starner on March 13, 2014, which date is subsequent to the date default occurred and at least ten(10) days prior to the date of this Praecipe. MARTSON LAW OFFICES By: (. 4 Christopher E. Rice, Esquire I.D. Number 90916 Aaron S. Haynes, Esquire I.D. No. 307746 0,4. Ce) /�2� � Ten East High Street r Carlisle, PA 17013 C'#,Ze//R (717) 243-3341 Dated: 3 - 21— 1 if Attorneys for Plaintiff 3031s? X�� C� NC?/?,e/ F:\FILES\Clients\11470 Members 1st\I 1470 Current\11470 279 Starner\11470.279.10day.hs.wpd Christopher E. Rice, Esquire Attorney I.D.No. 90916 Aaron S. Haynes, Esquire Attorney I.D.No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff • v. : NO. 13 - 4010 CIVIL TERM • HELEN J. STARNER and • MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Helen J. Starner DATE OF NOTICE: March j3 ,2014 141 East Main Street Mechanicsburg,PA 17050 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone(717)249-3166 MARTSON LAW OFFICES By: Christopher E. Rice, Esquire This is a debt collecting firm attempting to collect a debt for Members l'Federal Credit Union. Any information obtained will be used for that purpose. • F:\FILES\Clients\11470 Members 1st\11470 Current\11470.279 Starner\11470.279.10day.ms.wpd Christopher E. Rice, Esquire Attorney I.D.No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : NO. 13 -4010 CIVIL TERM • HELEN J. STARNER and • MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Michael Starner DATE OF NOTICE: March/3,2014 389 Georgetown Road Gardners,PA 17324 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone(717)249-3166 MARTSON LAW OFFICES By: Christopher E. Rice, Esquire This is a debt collecting firm attempting to collect a debt for Members Vt Federal Credit Union. Any information obtained will be used for that purpose. F.\FILES\Clients\I1470 Members 1st\I1470 Current\I1470.279 Starner\11470.279.pra.default.wpd 21114 t .i ' ip Christopher E. Rice, Esquire r•1.+M B E t L A NJ u U u ,.1. Attorney I.D. No. 90916 PENNSYLVANIA Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION„ : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and • MICHAEL STARNER, • Defendants : IN MORTGAGE FORECLOSURE AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, Defendants Helen J. Starner and Michael Starner, above named are not in the military service of the United States of America,that he has knowledge that the said Defendant Helen J. Starner's last known address is: 141 East Main Street, Mechanicuburg, PA 17050 and Defendant Michael Starner's last know address is 389 Georgetown Road,Gardner's PA 17324. Said Defendants' place of employment is unknown. Christopher E. Rice, Esquire Sworn to and subscribed before me this.Zls f day of March, 2014. / I @ No . JI'ubliCNI N OF PEN Notce,Notary NSYLVANIA mayM Public 'Pricer and County Cacti AUg.18,2015 Commismon Expires c AMA ASSOCIATION OF NOTARIES F:\FILES\Clients\11470 Members 1st\11470 Current\11470.279 Starner\11470 279 pra.defaultwpd Christopher E. Rice, Esquire Attorney I.D.No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION„ : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and : MICHAEL STARNER, • Defendants : IN MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against Defendants Helen J. Starner and Michael Starner was given to them by mail on March 13, 2014. 04 A ‹: 7Z _ Christopher E. Rice, Esquire Sworn to and subscribed before me this ii I.ct day of i(ifrijz_ , 2014. l t g./1.44-e. No . O'ublic COMMONWEr%L1h OF PENNSYLVANIA Notarial Seal Mary M.Price,Notary Public Carlisle Elora,Cumberland County My Commission Expires Aug.18,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER,hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 Michael Starner 389 Georgetown Road Gardners, PA 17324 MARTSON LAW OFFICES By :O M . Price 10 East High Street Carlisle, PA 17013 Dated: j/a..Or-- This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit Union. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : NO. 13 - 4010 CIVIL TERM • HELEN J. STARNER and • MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE TO: MICHAEL STARNER NOTICE OF ENTRY OF DEFAULT JUDGMENT S-� You are hereby notified that on the/f day of March,2014,the following Judgment was entered against you in the above-captioned action:judgment in the amount of$$21,260.72, plus interest from July 19,2013 at the rate of$3.70 per day,until the debt is paid in full for failure to file an Answer to Plaintiffs Complaint. Date: (.3/720 jr,...)30111411P Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Michael Starner 389 Georgetown Road Gardners, PA 17324 F.\FILES\Clients\11470 Members 1st\11470 Current\11470.279 Starner\I 1470.279.pra.default.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT • IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : NO. 13 - 4010 CIVIL TERM • HELEN J. STARNER and • MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE TO: HELEN J. STARNER NOTICE OF ENTRY OF DEFAULT JUDGMENT I Sf" You are hereby notified that on the p,(! day of March,2014,the following Judgment was entered against you in the above-captioned action: judgment in the amount of$21,260.72, plus interest from July 19,2013 at the rate of$3.70 per day,until the debt is paid in full for fail to file an Answer to Plaintiffs Complaint. Date: 3 0/ / / 323 Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 FAFILESTlients \ 11470 Members 1st \ 11470 Current \ 11470.279 Starner \ 11470.279.pre.writ of execution.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 2fik APR -2 Pi112: I (.',UMBERLAND Ci)UNTY PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT N THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against Helen J. Starner and Michael Starner, Defendants; and (3) execute against real property known as 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania, owned by Defendants Helen J. Starner and Michael Starner, and identified on Exhibit "A" attached hereto. Principal Balance: $ 15,575.84 Interest as ofJuly 19, 2013: $ 1,124.69 Interest accruing at $3.70 per day from July 19, 2013: Late Fees: $ 60.19 qJ Court Costs and Fees (estimated): $ 500740* 11„yoy r 'MU Attorney's Fees: $ 4,000.00 Total Due as of July 19, 2013: * To be determined by the Cumberland County Sheriff. I certify that: (a) This Praecipe is based upon a judgment by confession; and (b) Notice will be served at least thirty days prior to the date of the sheriff's sale of real property pursuant to Rule 2958.2. MARTSON LAW OFFICES By: A Christopher E. Rice, Esquire I.D. No. 90916 Aaron S. Haynes, Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Attorneys for Plaintiff Date: ,4// This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit Union and any information obtained will be used for that purpose. c 36377 r 51637 co 1 jl 14 /1 r1 EXHIBIT "A" DOCKET NO. 2013-4010 Parcel No: 46- 10- 0618 -018 ALL THAT CERTAIN tract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence along the latter, North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of 210 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of 39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of 275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 seconds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROPERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. This is a debt collecting firm attempting to collect a debt for Members 1" Federal Credit Union and any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff !H:.r QjIr - IONZvT A ;i 2014 APR -2 P1112: 1 ! CU ERLAHQ COUNT[ OTTO GILROY & FALL1 NNS YLYA M MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1" Federal Credit Union, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania, 17241, and as further described in Exhibit "A" attached hereto: 1. Name and address of owner(s) or reputed owner(s): Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 Michael Starner 389 Georgetown Road Gardners, PA 17324 2. Name and address of defendant(s) in the judgment: Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 Michael Starner 389 Georgetown Road Gardners, PA 17324 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1" Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Discover Bank c/o Edward Stock, Esq. Stock and Grimes, LLP 804 West Avenue Jenkintown, PA 19046 LVNV Funding, LLC 15 South Main Street Suite 500 Greenville, SC 29601 Asset Acceptance, LLC c/o David R. Galloway, Esq. Fulton, Friedman, and Gullace LLP 130B Gettysburg Pike Mechanicsburg, PA 17055 Adams County National Bank 675 Old Harrisburg Road Gettysburg, PA 17325 Cumberland County Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Members 1" Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Adams County National Bank 675 Old Harrisburg Road Gettysburg, PA 17325 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program 211 North Front Street P.O. Box 15530 Harrisburg, PA 17105 -5530 5. Name and address of every other person who has any record lien on the property: Cumberland County Tax Claims Bureau 1 Courthouse Square Old Courthouse, Room 106 Carlisle, PA 17013 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: 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. 4904 relating to unsworn falsification to authorities. Date: If - -/— /47 MARTSON LAW OFFICES By: eee 4 S Christopher E. Rice, Esquire This is a debt collecting firm attempting to collect a debt for Members ls` Federal Credit Union and any information obtained will be used for that purpose. • EXHIBIT "A" DOCKET NO. 2013-4010 Parcel No: 46-10-0618-018 ALL THAT CERTAINtract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence along the latter, North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of 210 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of 39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of 275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 seconds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROPERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. This is a debt collecting firm attempting to collect a debt for Members 1" Federal Credit Union and any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire 20 14 APR -2 PM 12: 12 Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER CUMBERLAND COUNTY ,l MARTSON LAW OFFICES PENNSYLVANIA 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKE NOTICE that the Sheriffs Sale of Real Property will be held on September 3, 2014, by the Cumberland County Sheriffs Office, at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, at 10:00 a.m., prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land (SEE LEGAL DESCRIPTION ATTACHED HERETO). THE LOCATIONofthe property to be sold is 36 Stoneledge Road, Newville, Pennsylvania 17241. THE JUDGMENT under or pursuant to which the property is being sold is docketed to: No. 2013 -4010, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THE PROPERTY are Helen J. Starner and Michael Starner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and /or government or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff within thirty (30) days after the sale, and distribution of the proceeds of the sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of Cumberland County, Cumberland County Courthouse, 1 Courthouse Square, Room 303, Carlisle, Pennsylvania 17013, (717) 240 -6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTYOR PROPERTYRIGHTS. It has been issued either because there is a Judgment against you or because the sale of real property described herein may affect an interest you have in the real property. It may cause your property to be held, sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE Date: T — /— / `f Cumberland County Bar Association 34 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 MARTSON LAW OFFICES By: 4 S21 Christopher E. Rice, Esquire I.D. 90916 Aaron S. Haynes, Esquire I.D. 307746 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members V Federal Credit Union and any information obtained will be used for that purpose. • EXHIBIT "A" DOCKET NO. 2013-4010 Parcel No: 46 -10- 0618 -018 ALL THAT CERTAIN tract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence along the latter, North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of 210 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of 39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of 275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 seconds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROPERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. This is a debt collecting firm attempting to collect a debt for Members V Federal Credit Union and any information obtained will be used for that purpose. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net MEMBERS 1sT FEDERAL CREDIT UNION Vs. NO 13 -4010 Civil Term CIVIL ACTION — LAW HELEN J. STARNER and MICHAEL STARNER WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $15,575.84 L.L.: $.50 Interest AS OF 07/19/13: $1,124.69 INTEREST ACCRUING AT $3.70 PER DAY FROM 07/19/13 - TO BE DETERMINED Atty's Comm:$4,000.00 - ATTORNEY'S FEES Due Prothy: $2.25 Atty Paid: $343.05 Other Costs: LATE FEES: $60.19 COURT COSTS AND FEES - TO BE DETERMINED BY THE CUMBERLAND COUNTY SHERIFF Plaintiff Paid: Date: 04/02/14 (Seal) REQUESTING PARTY: Name: CHRISTOPHER E. RICE, ESQ. Address: MARTSON LAW OFFICES 10 EAST HIGH STREET CARLISLE, PA 17013 Attorney for: PLAINTIFF Telephone: 717- 243 -3341 Supreme Court ID No. 90916 David D. Buell, Prothonot ry Deputy Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff OTTO GILROY & FALLER ��!LE0-0 F1 0r 7 HE PROTHONOTARY 20RR1FjAY 19 P1i 2: 29 CUMBERLAND COUNTY BNNSYLVANIA MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE AFFIDAVIT OF NOTIFICATION Christopher E. Rice, Esquire, attorney for Plaintiff, first having been duly affirmed according to law, deposes and says that on or about the 12' day of May, 2014, he notified all lien creditors and any other parties listed in the 3129.1 affidavit of the sheriff's sale in the above -captioned action. Notification was sent by regular mail. The 3817 certificates of mailing are attached hereto. Affirmed and subscribed to before me this / ?/i6 day of • a C).),0-eJ Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Mary M. Price, Notary Public Carlisle Bono, Cumberland County M COmmisSiOri Expires. Aug. 18, 2015 N Vq . •_ ,• -: ATION OF NOTARIES 4EMAt Date: 5//7//y1 This is a debt collecting firm attempting to collect a debt for Members 1s` Federal Credit Union and any information obtained will be used for that purpose. Ki 4 c , 2014. Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff UNITED STATES Certificate Of POSTAL SERVICE*Mailing Tr This Certificate of Mapes provides evidence that mail has been presented to USPS® for mailing. This forrn may be used for domestic end International mail. From:, To: . RTSON LAW OFFICES 1 30V1SOd Sn Malted From 17013 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 UNITED STATES Certificate Of POSTAL SERVICE* Mailing This Certificate of Mailing provides evidence that ma has been presented to USPS® for mailing. This form may be used for domestic and International mall. Froin: To: MARTSON LAW OFFICES.-ei 3_ 10 East High Street P� C -rusk, PA 17015 [L14( A,a 3OV1SOd sn c/o Edward Stock, Esquire/Stock 804 West Avenue Jenkintown, PA 19046 PS Farm 3817 Anril 2007 PSN 7530-02-000-9065 UNITED -STATES Certificate Of POSTAL SERVICE* Mailing This Certificate of Mailing provides evidence that maS has been presented to USPS® for mailing. Thy form may be used for domestic and international mail. From: MARTSON LAW OFFICES 10 East High Street ."-"c101 Mailed From 17013 :Ing:': ti• 4r4—...1". 5 : 30d1SOd sn To: LVNV Fundin LLC 15 South. Main Street; Suite 5fln Greenville, SC 29601 PS Fnrm 3817 Anril 2007 PSN 7530-02-000-9065 UNITED STATES Certificate Of POSTAL SERVICE Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS® for mailing. This form may be used for domestic and Inhambane! mai. From: • MARTSON LAW OFFICES 10 East Hlgh S Ca, 4i0k, PA To: Asset Acceptant LLC sols c/o David R. Galloway, Es Paton, Friedman, and Gullace P To 0 metr Po+ 130B Gettysburg, Pike, Mechanicsburg, PA 17C PC Fnrm 3817 Anvil 2007 PSN 7530-02-000-9055 iral UNITED STATES Certificate Of -.44111 POSTAL SERVICE* SERVICE* Mailing This Certificate of Mailing provides guldens that mai has been presented to USPS® for mailing. This form may be used for domestic and Intonations' mai. From: MARTSON LAW OFFICES;; --e99 10 East High Street Ca.iak, PA 17013 <1 N ill' --� N To: Adams County National Bank 675 Old Harrisburg Pike �tr) GO S 0 Gettysburg, PA 17325 PC Fnrm 3817 Anvil 2007 PSN 7530-02-000-9055 --11"11, UNITED STATES POSTAL SERVICE* Certificate Of Mailing This Certificate a Mailing provides been presented to USPS® for mailing. for domestic and International mall. From: MARTSON LAW OFFICES 10 East High Street 43� Lrf To'Cumberland County Domestic Rela'js 0'. 13 North Hanover Street, P.O. B Ca.li�k, PA 17013 Carlisle, PA 17013 3OVISOd Sn ,r OI 6O M R OW g0 H31SVH Mailed From 17013 I 30VlSOd Sn 0 01 M R 8 • N v E, 1131SVH Mailed From 17013 3OVJ sod sn 7H15559757 CH CD C') 1- E9 05/12/2014 2I31SVH Mated From 17013 PS Fnrm 3817 Anril 2007 PSN 7530-02-000-9065 UNITED STATES Certificate Of POSTAL SERVICE Mailing This Certificate of Map provides evidence that mil hes been presented to USPS® for mailing. This fpm may be used for dornestk and Intarnatl,i mat From: 10 East High S Ca, taaic, PA 1 To Pennsylvania Homeowner's Emergency Mor 211 North Front St., P.O. Box 15530 Harrisburg, PA 17105-5530 PS Fnrrn 3817 And! 2007 PSN 7530-02-000-9065 UNITED STATES Certificate Of POSTAL SERVICE Mailing This Certificate of !Alders provides evidence that mail has been presented to USPS® for mating. This tom may be used for domestic and International mal. From: 1 3DViSod sn M n at O a tv o l3-1SV H To: Cumberland County Tax Claim BuPea� 1 Old Courthouse Square �S Old Courthouse Room 106 PS Fnrm 3817 Anrll 2007 PSN 7530-02-000-9065 1 1 Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff t U tsIse. THE 70 I hOi _IAi. t 2OI'iAUG 29 PM12: 13 CUMBERLAND COUNTY OTTO GILROY & FALLL N N S Y LVA N I A MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1st Federal Credit Union, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania, 17241, and as further described in Exhibit "A" attached hereto: 1. Name and address of owner(s) or reputed owner(s): Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 Michael Starner 389 Georgetown Road Gardners, PA 17324 2. Name and address of defendant(s) in the judgment: Helen J. Starner 141 East Main Street Mechanicsburg, PA 17050 Michael Starner 389 Georgetown Road Gardners, PA 17324 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Discover Bank c/o Edward Stock, Esq. Stock and Grimes, LLP 804 West Avenue Jenkintown, PA 19046 LVNV Funding, LLC 15 South Main Street Suite 500 Greenville, SC 29601 David R. Galloway, Esq. Fulton, Friedman, and Gullace LLP 130B Gettysburg Pike Mechanicsburg, PA 17055 Adams County National Bank 675 Old Harrisburg Road Gettysburg, PA 17325 Cumberland County Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Sharon E. Myers, Esq. CGA Law Firm 135 North George Street York, PA 17404 Asset Acceptance, LLC 28405 Van Dyke Warren, MI 48093 David J. Apothaker, Esq. Apothaker and Associates, P.C. 520 Fellowship Road, C306 Mount Laurel, NJ 08054 4. Name and address of the last recorded holder of every mortgage of record: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Adams County National Bank 675 Old Harrisburg Road Gettysburg, PA 17325 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program 211 North Front Street P.O. Box 15530 Harrisburg, PA 17105-5530 ACNB P.O. Box 3129 Gettysburg, PA 7325 5. Name and address of every other person who has any record lien on the property: Cumberland County Tax Claims Bureau 1 Courthouse Square Old Courthouse, Room 106 Carlisle, PA 17013 West Pennsboro Township 2150 Newville Road Carlisle, PA 17015 West Pennsboro Township c/o Hubert X. Gilroy, Esq. Martson Law Offices 10 East High Street Carlisle, PA 17013 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: 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. 4904 relating to unsworn falsification to authorities. Date: 6 _ 2 c,_/(( MARTSON LAW OFFICES By: Christopher E. Rice, Esquire This is a debt collecting firm attempting to collect a debt for Members lst Federal Credit Union and any information obtained will be used for that purpose. EXHIBIT "A" DOCKET NO. 2013-4010 Parcel No: 46-10-0618-018 ALL THAT CERTAIN tract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence along the latter, North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of 210 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of 39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of 275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 seconds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROPERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. This is a debt collecting firm attempting to collect a debt for Members 15` Federal Credit Union and any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 CUMBERLAND COU .P MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER PENNSYLVANI MARTSON LAW OFFICES 2014 AUG 29 PM 12: 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE AFFIDAVIT OF NOTIFICATION Christopher E. Rice, Esquire, attorney for Plaintiff, first having been duly affirmed according to law, deposes and says that on or about the 29th day of August, 2014, he notified all lien creditors and any other parties listed in the 3129.1 affidavit of the sheriffs sale in the above -captioned action. Notification was sent by regular mail. The 3817 certificates of mailing are attached hereto. Affirmed and subscribed to before me this DZ. day of N Pu • lic • COMMONWEALTH OF PENNSYLVANIA Notarial Seel Mary M. Price, Notary Public Oeriiele Baro, CUMberiend County M CoMtI SIOri , res au, .8, 2015 Es .~.1417. Date: ija41h/p S Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff , 2014. This is a debt collecting firm attempting to collect a debt for Members 15` Federal Credit Union and any information obtained will be used for that purpose. UNITED STATES Certificate. POSTAL SERVICE This Certificate of Wang provides evidence that mal has been presented to Uses® tor m i This form:mey be used for domesdc and intimations! mei. From: A k'TSON LAW OFFICES 10 Last High Street Carlisle, PA 17013 �r�� m n 0�7� mE, N 3 -rm. pp.. C(D o(n�-+O Q7 ZIP rC((1) .p)rr To:West Pennsboro Township 2150 Newville Road Carlisle, PA 17015 UNITED STATES Certificate Of Midi POSTAL SERVICEt Mailing This Corna%ol MaNing provides evidence that mal has been presented to USPS® tor mailing. o mo This tomay be used for domestic and international rnai.' From:: .A?TSON LAW OFFICES , 10 East High Street N To: David J. Apothaker, Esquire Apothaker and Associates,. P.C. 520 Fellowship Road, C306 Mount Laurel, NJ 08054 co03. cn UNITED STATES Certificate 01 Milt POSTAL SERVICE Mailing This Certificate of Mailing provides evidence that maN has been presented to USPS® for mailing. — This form may. be used tor domestic and inMrotiornl mall. o Front. ' A RTSON LAW' OFFICES TO -East High Street Carlisle, PA 17013 To: David R. Galloway, Esquire Fulton, Friedman, and Gullace LLP 00 �_'WT (n - V D rn 130B Gettysburg Pike Mechanicsburg, PA 17055 1 1 UNITED STATES % POSTAL SERVICE* Ns Certificate od Weeny provides evidence that 'ma has been presented to USPSS for main This loan may be used of domestic end international mail. Certificate C Mailin Frain: ALITSON LAW OFFICES iUTrast lifgh street Carlisle, PA 17013 Tc4Asset Acceptance, LLC 28405 Vah Dyke Warren, MI 48093 UNITED STATES POSTAL SERVICE* Certificate 0$ Mailin This Certnicale al Mailing, provides evidence tt mall has been presented USPSS to mallini This lone may be !lama for domestic and international mall. Ram:: x> n C c) 3 •-•r-1/* —1.„..00, oN--.1•-'3)", ctoc>o•-•• - kAa Z-14 •-a-nnc3c2,— . --I 2> Cril A.TSON LAW OFFICES To: Sharon E. Myers, Esquire CGA Law Firm 135 North George Street York, PA 17404 a, UNITED STATES Certificate Of POSTAL SERVICE* Mailing Thb C. Vficate of Mailing provides evidence that mail has been presented to USPS® for mailing. Thts form may be used for domestic and Intamationii mat. From: MARTSON LAW OFFICES 10 East High Street :.artts1v, PA 17029 To: West Pennsboro Township c _oo - c� x t• i. 1 --t •D c/o Hubert X. Gilroy, Esquire/Ma sQn Law �. CoC,(1).,77 ices muj z- -•roo r^wm -1 03 d m cm-) m 10 East High Street Carlisle, PA 17013 PS Fnrm 3817 Anrll 2007 PSN 7530-02-000-9065 UNITED STATES Certificate 01 POSTAL SERVICE Mailing This Corneste d Mailing provides evidence Stat mat has been presented to USPS® for mailing. o This farm may be used for dornesde and Inlentaddgd mail. o From: >.A RTSON LAW OFFICES To. ACNB P.O. Box 3129 Gettysburg, PA 17325 r m. cupen�1 z• --roo •w. m m F:\FILES\Clients\11470 Members 1st \11470 Current \ 11470.279 Starner\ 11470.279.notice of continuance pd Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff THE PROTHONI I!r"53. 1I)1liSEP -4 AM 10: 38 CUMBERLAND COUNTY PENNSYLVANIA OTTO GILROY & FALLER MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale of the property located at 36 Stoneledge Road, Newville, Cumberland County, Pennsylvania 17241, scheduled for October 1, 2014, at 10:00 a.m., in the above -captioned matter has been continued until November 5, 2014, at 10:00 a.m. Date: 7/5/ f L� MARTSON LAW OFFICES By: 4 S ,( Christopher E. Rice, Esquire I.D. No. 90916 Aaron S. Haynes, Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit Union and any information obtained will be used for that purpose. F:\FILES\Clients\11470 Members 1st V11470 Current \11470.279 Starner\11470.279.pra.reissue writ.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ... TFL PRO THONG 1014 SEP -l+ AftI0:33 CUMBERLAND COUNTY PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13 - 4010 CIVIL TERM HELEN J. STARNER and MICHAEL STARNER, Defendants : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE WRIT OF EXECUTION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the Writ of Execution against Helen J. Starner. Pil, 7.0 pausy k yg7Y3 12.41P.3/os13 Date: 9 " /y MARTSON LAW OFFICES By: Christopher E. Rice, Esquire I.D. No. 90916 Aaron S. Haynes, Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members 1s` Federal Credit Union and any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff , 1,/ -ire - cr:/: 499,0, s4.),„ I ,„,..., 4 ni, OTTO GILROY & FALL c r ,,,, ft(64 1140 , AN MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKE NOTICE that the Sheriff's Sale of Real Property will be held on November, 5, 2014, by the Cumberland County Sheriffs Office, at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, at 10:00 a.m., prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land (SEE LEGAL DESCRIPTION ATTACHED HERETO). THE LOCATIONof the property to be sold is 36 Stoneledge Road, Newville, Pennsylvania 17241. THE JUDGMENT under or pursuant to which the property is being sold is docketed to: No. 2013-4010, Cumberland County C.C.P., Pennsylvania. THE NAME OF THE OWNERS OR REPUTED OWNERS OF THE PROPERTY are Helen J. Starner and Michael Starner. A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff within thirty (30) days after the sale, and distribution of the proceeds of the sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of Cumberland County, Cumberland County Courthouse, 1 Courthouse Square, Room 303, Carlisle, Pennsylvania 17013, (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTYOR PROPERTYRIGHTS. It has been issued either because there is a Judgment against you or because the sale of real property described herein may affect an interest you have in the real property. It may cause your property to be held, sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE Date: Cumberland County Bar Association 34 South Bedford Street Carlisle, PA 17013 (717) 249-3166 MART ON LAW OFFIC topher E. 0916 A. S. Haynes, E I.D. 07746 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members Pt Federal Credit Union and any information obtained will be used for that purpose. EXHIBIT "A" DOCKET NO. 2013-4010 Parcel No: 46-10-0618-018 ALL THAT CERTAIN tract ofland and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence along the latter, North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of 210 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of 39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of 275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 seconds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROPERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. This is a debt collecting firm attempting to collect a debt for Members lst Federal Credit Union and any information obtained will be used for ,that purpose. FAFILESTlients111470 Members 'MI 1470 Current\11470.279 Starner \11470.279.cerbfmate of filing.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 Aaron S. Haynes, Esquire Attorney I.D. No. 307746 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff :LEOCFFCE T HE PROTHONVAR ZORSEP-t 1111 10; '3 f3 CUMBERLAND COUP' PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff v. HELEN J. STARNER and MICHAEL STARNER, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 13 - 4010 CIVIL TERM : IN MORTGAGE FORECLOSURE CERTIFICATE OF FILING On this date, I filed with the Prothonotary of Cumberland County, a copy of the Notice of the Date of Continued Sheriffs Sale in the above -captioned matter. Date: 7/ MARTSON LAW OFFICES By: Christopher E. Rice, Esquire I.D. No. 90916 Aaron S. Haynes, Esquire I.D. No. 307746 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Members ist Federal Credit Union and any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody SSmith Chief Deputy Richard W Stewart Solicitor LEU -OFF/[ oFTHE 'ROT. W "�/\��� 2014 NO 1 PH���� '� "~ CUM8'RLAND OUNTY NNSYLVANIA Members 1st Federal Credit Union vsHelen Starner (et al.)� Case Number 2013-4010 SHERIFF'S RETURN OF SERVICE 06/17/2014 11:55 AM - Deputy William Cline, 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 personaily handing a true copy to a person representing themselves to be Mary Starner, Mother, who accepted as "Adult Person in Charge" for Michael Starner at 389 Georgetown Road, Dickinson Township, Gardners, PA 17324, Cumberland County. 08/19%2014 08:37 PM - Deputy Dawn Kell, 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 36 Stoneledge Road, West Pennsboro - Township, Newville, PA 17050, Cumberland County. 07/14/2014 Ron Anderson, Gha/iff, being duly sworn according to aw, states that he made a diligent search and inquiry for the within named Defendant, to wit: Helen Starner, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Deecriptinn, in the above titled action, ao"Not Found" at141 East Main Street, Mechanicsburg, PA 17055, defendant moved arid did not leave a forwarding address with the post office. 09802/2014 As directed by Christopher E Rice, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 08/11/2014 As directed by Christopher E Rice, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/5/2014 09/22/2014 04:13 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Oesori[tion, 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 Daryl Moore, Boyfriend, who accepted as "Adult Person in Charge" for Helen Starner at 711 Breezewood Drive, KAeohanicsburg, PA 17055, Cumberland County. 11/03C3014 Ronny R Anderson, Sheriff, being duly sworn according to |ow, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1.092.07 (c)ooun*akiimSheriff. TeleoswInc. SO ANSWERS, RON R ANDERSON, SHERIFF On May 20, 2014 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Known and numbered as, 36 Stoneledge Road, Newville, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 1P, 2014 By: \ )7U/Adol Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-4010 Civil MEMBERS 1ST FEDERAL CREDIT UNION vs. HELEN STARNER Michael Starner Atty.: Christopher E. Rice ALL THAT CERTAIN tract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 Ion the hereinafter mentioned plan of lots; thence along the latter, North21 degrees 30 minutes 52 sec- onds West, a distance of210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an iron pin on the dividing line between Lots Nos. 11 and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 seconds East, a distance of21 0 feet to an iron pin on the northern side of said proposed street; thence along the latter, South 53 degrees 9 minutes 41 seconds West, a distance of39.51 feet to an iron pin; thence along the same, by a curve to the right having a radius of275 feet, an arc distance of 54.84 feet to a point; thence continuing along the same, South 64 degrees 35 minutes 16 sec- onds West, a distance of 60.64 feet to an iron pin, the Place of BEGINNING. BEING described according to a Plan of Lots of Carl A. Fink, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 26, Page 81, and being designated as Lot No, 11 thereon. TO BE SOLD AS THE PROP- ERTY OF MICHAEL L. STARNER and HELEN STARNER, HIS WIFE ON JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM. 96 This is a debt collecting firm at- tempting to collect a debt for Mem- bers 1,I Federal Credit Union and any information obtained will be used for that purpose. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 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. 1Varie oyne, Edit r SWORN ' — AND SUBSCRIBED before me this of Jul 2014 -6_acetd/a..4J Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 1900 Patriot Drive -Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriot News Now you know 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 Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither 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. 013-4010 Civil erm M MBERS 1ST ERAL CREDIT UNI N vs. HELEN STARNER Michael Starner Atty: Christopher E Rice ALL THAT CERTAIN tract of land and the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the northern side of a proposed street on the dividing line between Lots Nos. 10 and 11 Ion the hereinafter mentioned plan of lots; thence along the latter:: North 21 degrees 30 minutes 52 seconds West, a distance of 210 feet to an iron pin; thence North 59 degrees 39 minutes 18 seconds East, a distance of 154.42 feet to an' -� ; do the dividing line between Lots Nos. 11. and 12 on said plan; thence along the latter, South 21 degrees 30 minutes 52 Sec.=.-+u�c_C •te=a .�..r_D+, n.,+. Sworn to a This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 .14rEgfcL d bscribed efore me this 20 day of August, 2014 A.D. COMMONWEALTH OF PENNVLVANtA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES