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HomeMy WebLinkAbout13-4368 Supreme Court;of Pennsylvania Court Commo ,Pleas n1!, , �� �v. For Prothonotary Use Only: Giv1l heet CVMBER'L�ARi ti 4 C ounty Docket No: The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace the filing and service ofpleadings or other papers as req uired by law or rules of court. S Commencement of Action: ❑D Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: SOVEREIGN BANK, N.A. Lead Defendant's Name: KAREN J. COOK T I Are money damages requested? ❑ Yes ❑x No Dollar Amount Requested: ❑ within arbitration limits Q (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes 9 No A Name of Plaintiff /Appellant's Attorney: Allison F. Zuckerman, Esq., Id. No.309519, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVEL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: O ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: ❑ Other Professional: Pa.R. C.P. 205.5 Updated 01/01/2011 4q[ P 0l 0T,4 2013 JUL 2.6 AH 10: d � CU.MBERLANo COUNTY PENNs YLVANIA PHELAN HALLINAN, LLP Allison F. Zuckerman, Esq.,'Id. No.309519 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 SOVEREIGN BANK, N.A. 824 NORTH MARKET STREET COURT OF COMMON PLEAS SUITE 100 WILMINGTON, DE 19801 CIVIL DIVISION Plaintiff TERM V. NO. 0 KAREN J. COOK MARTIN L. COOK CUMBERLAND COUNTY 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE v3 79od alb C l ?ag,p File #: 312357 1. Plaintiff is SOVEREIGN BANK, N.A. 824 NORTH MARKET STREET SUITE 100 WILMINGTON, DE 19801 2. The name(s) and last known address(es) of the Defendant(s) are: KAREN J. COOK MARTIN L. COOK 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/06/2000 KAREN J. COOK made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNITED MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1617, Page 232. By Assignment of Mortgage recorded 06/07/2000 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book 645, Page 1088.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. Sovereign Bank is now known as SOVEREIGN BANK, N.A. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2012 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File #: 312357 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage as of 06/17/2013: Principal Balance $168,101.52 Interest $20,823.81 02/01/2012 through 06/17/2013 Late Charges $2,599.08 Property Inspections $155.25 Non Sufficient Funds Charge $30.00 Escrow Deficit $2,859.67 TOTAL $194,569.33 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated, because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 312357 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $194,569.33, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HA P By: 11 ucke , Esq., Id. No.309519 orn for PI 'tiff File #: 312357 LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #208, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of five hundred ninety -four and forty -four one - hundredths (594.44) feet West of the intersection of the North side of Dorset Drive and the West side of Chippenham Road; thence by the line of Lot No. 209 South forty-three degrees zero minutes West (S 43° 00' W) a distance of one hundred forty-nine and forty-two one - hundredths (149.42) feet to a point at line of Lot No. 202; thence by same and Lot No. 203 North forty-nine degrees twenty -seven minutes forty seconds West (N 49° 27' 40" seconds W) a distance of one hundred eighty -one and thirty -nine one- hundredths (181.39) feet to a point in PP &L Co. Right -of -Way; thence by same North sixty -five degrees thirty -two minutes twenty seconds East (N 65° 32' 20" E) a distance of one hundred eight -four and thirty -eight one - hundredths (184.38) feet to a point on the West side of Chippenham Road; thence South thirty-six degrees thirty-seven minutes fifty -four seconds East (S 36° 37' 54" E) a distance of thirty -three and seventy -one one - hundredths (33.71) feet to a point at a curve; thence by same and a curve to the left having a radius of four hundred thirty- three and zero one - hundredths (433.00) feet an arc length of seventy -seven and eighty -one one- hundredths (77.81) feet to the place of BEGINNING. CONTAINING 23,206.06 square feet and being known and numbered as 3803 Chippenham Road. File #: 312357 UNDER AND SUBJECT, NEVERTHELESS to Declarations of Covenant, Easements, Restrictions, Equitable Servitudes, Charges and Liens dated November 9, 1988 and recorded November 10, 1988 in Cumberland County Miscellaneous Book 356, Page 1095. UNDER AND SUBJECT, also, to all easements and restrictions of record and as set forth on recorded plan described above. UNDER AND SUBJECT, also to a fifty (50') foot right of way to PP &L Company as more fully appears on the above - referenced plan. The access easement for the Homeowner's Association between Lot No. 220 and Lot No. 221 as shown on said plan has been eliminated in favor of a 10 foot (10') bike path easement to Hampden Township centered on the lot line between Lot No. 220 and Lot No. 221. The Recreation Area shown on the Final Plan of Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, will be eliminated and developed as building lot. BEING the same premises which David S. Lohr and Katie Jo Lohr, by deed dated November 24, 1997, and recorded December 1, 1997, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 166, Page 770, granted and conveyed unto Michael I. Muul and Amy F. Muul, husband and wife. PROPERTY ADDRESS: 3803 CHIPPENHAM ROAD, MECHANICSBURG, PA 17050- 9127 PARCEL # 10 -16- 1056 -166. File #: 312357 0 VERIFICATION hereby states that he /she is I U reel os1 -1,C of SOVEREIGN BANK, N.A, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: Nfe: Title: S are A SOVEREIGN BANK, N.A File #: 312357 Name: COOK File #: 312357 FORM 1 IN THE COURT OF COMMON PLE�§ SOVEREIGN BANK, N.A. OF CUMBERLAND COUNTY, PENNSYBVA14 __4 Plaintiffs) M M � i M z� r � rn vs. r r.) :;73t:3 to C KAREN J. COOK <CD 1-° CD -� MARTIN L. COOK C-) =' Defendant(s) Civil C ? C i "= 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 Mid'enn 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 represaitative 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 a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed 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 tomeet with a representative of your lender in an attempt to work out reasonable arguments 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: lwn "-� ' Date V Ili . Z c an, Esq., Id. .309519 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOM Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: -- Zip : Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER 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 #l: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles boats motorcycles)• Model: Year: Amount owed: - Value Monthly Income Name of Employers: I • Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3 • Monthly Gross Monthly Net 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 nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 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 ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use /refer this information to my 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 counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) J ' 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 plaintiff. 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 REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 312357 SHERIFF'S OFFICE OF CUMBERLAND COUNTY o Ronny R Anderson Sheriff Jody S Smith Chief Deputy CIO Richard W Stewart Solicitor CD Sovereign Bank vs. Case Number Karen J Cook(et al.) 2013-4368 SHERIFF'S RETURN OF SERVICE 08/06/2013 Ronny RAnderson, Sheriff, being duly sworn according law, states he made diligent inquiry for the within named Defendant to wit: Karen J Cook, 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 3803 Chippenham Road, Hampden Township, Mechanicsburg, PA 17050.This Office was informed by co-defendant that Karen J. Cook does not reside at this address, he was unable to provide a good address for the defendant. 08/06/2013 04:15 PM- Ronny R.Anderson, Sheriff, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by"personally"handing atrue copy to a person representing themselves to be the Defendant, to wit: Martin L. Cook at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA17O13. R'dNNV'-R.ANDERSON, SHERIFF SHERIFF COST: sOO.30 SO ANSWERS, August O7. 2U13 Rumm/ R ANDERSON, SHERIFF SOVEREIGN BANK, N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 13-4368 CIVIL TERM ' MARTIN L. COOK, w me a z0 a Defendant =rn ra t<> fY'► O PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Defendant, Martin L. Cook, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT,P.C. 4 Douglas GbfilleZ Esquire Supreme Court I.D.No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717)249-2353 Date: August 26, 2013 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date:set forth below: ALLISON F. ZUCKERMAN, ESQUIRE 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Date: August 26, 2013 IRWIN &McKNIGHT, P.C. Douglas . Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717)249-2353 PHELAN HALLINAN,LLP M3 AUG An 10. 53 Meredith Wooters,Esq.,Id.No.307207 1617 WK Boulevard,Suite 1400 11CUMBERLAN Q One Penn Center Plaza ��5 UUNTY Philadelphia,PA 141.03 YLVAt�IA Meredith.Wooters @phelanhallinan.com 215-563-7000 SOVEREIGN BANK,N.A. COURT OF COMMON PLEAS Plaintiff : : CIVIL DIVISION VS. CUMBERLAND COUNTY KAREN J. COOK No. 13-4368 CIVIL MARTIN L. COOK Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN,LLP By: Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Date: /mig, Svc Dept. File#806119 V%�t5° � SHERIFF'S OFFICE OF CLIMBERLANDrG9,�,YV : f �';G' Ronny R Anderson Sheriff Jody S Smith 3 SEP I I AV' Y Chief Deputy 0&iBERLAIRD COW Richard W Stewart Solicitor OFF CE OF THE$MERIFF Sovereign Bank Case Number vs. 2013-4368 Karen J Cook(et al.) SHERIFF'S RETURN OF SERVICE 09109/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Karen J Cook, 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 1431 Timber Brook Drive, Hampden Township, Mechanicsburg, PA 17050. Current tenant, Karen Cook, states that the defendant does not reside at this address. SHERIFF COST: $44.30 SO ANSWERS, September 09,2013 RbNW R ANDERSON, SHERIFF (c)CountySuilc Sheriff,Toleosoft,Inc. SOVEREIGN BAND,N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION-LAW 13-4368 CIVIL TERM M�- C:) MARTIN L.COOK, Defendant -v - REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28,2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows; 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property,which is Defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities E A Ad,tA h Signature o efendant's Counsel/Appointed Date Legal Representative Signatur of Defendant Date Signature of Defendant Date CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: ALLISON F. ZUCKERMAN, ESQUIRE 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Date: October 4, 2013 IRWIN& McKNIGHT, P.C. "��01-ALAA - Douglas . Miller,Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff atIiitr at eltJaaos/.; Jody S Smith Chief Deputy ti . Richard W Stewart • Solicitor OFF CE OF mE SkERIFF Sovereign Bank vs. Case Number Karen J Cook(et al.) 2013-4368 SHERIFF'S RETURN OF SERVICE 09/09/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Karen J Cook, 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 1431 Timber Brook Drive, Hampden Township, Mechanicsburg, PA 17050. Deputies were advised by the current tenant that the defendant does not reside at this address. SHERIFF COST: $44.30 SO ANSWERS, September 09, 2013 RONNY R ANDERSON, SHERIFF LrT''e C.3 (c)CountySWte Sheriff,Teleosoff.Inc. K:1 ...EO-OF F]" PHELAN HALLINAN,LLP 2-fl13 OCT 24 AM 10'- 01 Adam H.Davis,Esq.,Id.No.203034 CUMBERLAND COUNTY 1617 JFK Boulevard,Suite 1400aE1SY1 VA# 1A One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 SOVEREIGN BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY KAREN J. COOK No. 13-4368 CIVIL MARTIN L. COOK Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN, LLP By: :owe --& / Adam H. Davis, Esq., Id. No.203034 / Attorney for Plaintiff Date: /knm, Svc Dept. File# 74) o� Ag 7 311 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i �,�.�3ttr of s:stai�tr�tt�� Jody S Smith Chief Deputy . �� x .+ �..�°_ f ,_, f Richard W Stewart Solicitor OF T#E����t�- P E iH SYU8 rr,�'s1'' Sovereign Bank Case Number vs. Karen J Cook(et al.) 2013-4368 SHERIFF'S RETURN OF SERVICE 10/25/2013 08:56 PM - Deputy Ronald Hoover, being duly sworn according to law, 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: Karen J Cook at 1266 Timber View Drive, Hampden Township, Mechanicsburg, PA 17050. RONALD HOOVER, DEPUTY SHERIFF COST: $31.80 SO ANSWERS, October 28, 2013 RON R ANDERSON, SHERIFF SOVEREIGN BANK,N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUBERLAND COUNTY, PENNSYLVANIA: -' -11-- :; j c -1 vs. : CIVIL ACTION cn~ -- NO. 13-4368 CIVIL cm -- MARTIN L. COOK, : c. Defendants ` LL — C ? CASE MANAGEMENT ORDER AND NOW,this �7 day of December, 2013, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised Conciliation Conference on 4,1, p/iito o? f t aoly , at //:30 q.m. in i Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, AAL Kevi, . Hess, P.J. llison F. Zuckerman, Esquire 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 For the Plaintiff D uglas Miller, Esquire 60 West Pomfret Street Carlisle, PA 17013 For the Defendant •rlm C O ' .L �, i es C//03 SOVEREIGN BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION NO. 13-4368 CIVIL MARTIN L. COOK, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this -z'/' day of January, 2014, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay in this case is VACATED effective February 25, 2014. BY THE COURT, Kevi A. Hess, P.J. ./ � . Troy Sellars, Esquire 126 Locust Street Harrisburg, PA 17101 F// Plaintiff or the Plainti �OUglas Miller, Esquire 60 West Pomfret Street Carlisle, PA 17013 For the Defendant rnw t^- r Am u)r-- -<> ' •. �� �wyYt Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FROTI-1ON0 TT;w: APR -3 rkii W.• 12 CUIIBELI-\NO COUNTY PENNSYLVOIA Attorney For Plaintiff SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 13-4368 CIVIL PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, NA. as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: By amendment of its Articles of Association, Sovereign Bank, N.A. changed its name to Santander Bank, N.A. Kindly amend the information on the docket accordingly. Date: tf7-2'9' By: Adam H. Davis, Esq., Id. No.2030 4 Attorney for Plaintiff PH # 806119 aitivt 4 61.9eia CL# Nei9e96 R--# 363812G Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 Attorney For Plaintiff SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 13 -4368 CIVIL ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A.. Date: W2/7<1. PH # 806119 PHELAN HALLINAN, LLP By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff SOVEREIGN BANK, N.A. Plaintiff V. KAREN J. COOK MARTIN L. COOK Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 13-4368 CIVIL CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Plaintiffs Praecipe for Substitution of Party Plaintiff and Entry of Appearance were served by regular mail on the person(s) on the date listed below: DOUGLAS G. MILLER, ESQUIRE WEST POMFRET PROFESSIONAL BUIL, 60 WEST POMFRET STREET CARLISLE, PA 17013-3222 KAREN J. COOK 1266 TIMBER VIEW DR MECHANICSBURG, PA 17050-9148 Date -ramr PHELAN HALLINAN, LLP By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP APR - 3 MI 10; 20 Adam H. Davis, Esq., Id. No.203034 r „Aopl 0 1617 JFK Boulevard, Suite 1.400 r't•-/F,-)1".t.,\IP, CtilUA.141-1/ One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 Attorney for Plaintiff SANTANDER BANK, N.A., FORMERLY : CUMBERLAND COUNTY KNOWN AS SOVEREIGN BANK, N.A. : : COURT OF COMMON PLEAS vs. : CIVIL DIVISION KAREN J. COOK MARTIN L. COOK : No. 13-4368 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against KAREN J. COOK and MARTIN L. COOK, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $194,569.33 TOTAL $194,569.33 I hereby certify that (1) the Defendants' last known addresses are 1266 TIMBER VIEW DRIVE, MECHANICSBURG, PA 17050-9148 and 3803 CHIPPENHAM ROAD, MECHANICSBURG, PA 17050-9127, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date tWPIC Adam H. Davis, Esq., Id. No.203034 Attorney f 'lain DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PH 806119 PROTHONOTARY IL-11- NO 8,3 'ke, 806119 .0 pft Sb1V621 r/In.,: I., I PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. VS. KAREN J. COOK MARTIN L. COOK Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS • : CIVIL DIVISION : No. 13-4368 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) KAREN J. COOK and MARTIN L. COOK are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant KAREN J. COOK is over 18 years of age and has last known addresses at 1266 TIMBER VIEW DRIVE, MECHANICSBURG, PA 17050-9148 and 3803 CHIPPENHAM ROAD, MECHANICSBURG, PA 17050-9127. (c) that defendant MARTIN L. COOK is over 18 years of age and resides at 3803 CHIPPENHAM ROAD, MECHANICSBURG, PA 17050-9127. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date 1(70/7/4f Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 806119 Department of Defense Manpower Data Center Results as of : Apr-02-2014 12:0524 AM SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: COOK First Name: MARTIN Middle Name: L Active Duty Status As Of: Apr-02-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA —, No N . NA This response reflects the individuals' active dutY status based on the Active Duty Status Date • Left Active Duty Within 367 Days of Active Duty Status Oats Active Duly Start Dale Active Duly End Date Status Service Component NA , I ,IJA 1 No _ NA This response reflects Where the individual left active dttly status within 367 days preceding the Active Duty Status Dale The Member or His/Her Unit Was Notified of a flute e Call-Up to Active Duly on Active Duty Status Dale Order Notification Start Dale Order Notification End Date Status Service Component NA NA 'N. ' ,. ,No - . NA This response reflects whether the individual or his/her unit has received early notification to report for active duty , o' Upon searching the data banks of the Department of Defense ManpoWer,DkaCenter, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center ,Status Report Pursuant to Servic Last Name: COOK First Name: KAREN Middle Name: J Active Duty Status As Of: Apr -02 -2014 Results as of : Apr -02 -2014 12:05:16 AM embers Civil Relief Act SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .... '•�". NA This response reflects the indiJiduats' active duty status based on the -4.,,' ctive Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ' 1 1. - o t . NA This response reflects /vh.ere the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HisiHer Unit Was Notified of a Future Cull-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Dale Status Service Component NA NA ,.,,'�. . „+�%C.No _. .� NA This response reflects whethe the individual or his/her unit had received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 SANTANDER BANK, N.A., FORMERLY KNOWN COURT OF COMMON PLEAS AS SOVEREIGN BANK, N.A. CIVIL DIVISION Plaintiff V. KAREN J. COOK MARTIN L. COOK Defendant(s) TO: KAREN J. COOK 1266 TIMBER VIEW DRIVE MECHANICSBURG, PA 17050-9J48 DATE OF NOTICE: NO. 13-4368 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WTTHOUT 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. * • ()face of the Prothonotary " Cumberland County Courthouse • • 1 Courthouse Square ' Carlisle, PA 17013 (717) 240-6195 By: PH # 806119 . CUMBERLAND COUNTY BAR,'. • • ASSOCIATION CUMBERLAND COUNTYCOURTHOUSE ° -• 2 LIBERTY AVENUE CARLISLE, PA 17013 717) 249-3166 Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) TO: KAREN J. COOK 3803 CHE'PENHAM ROAD MECHANICSB U1 G, PA 17050-9127 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 13-4368 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE, OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEB OR NO FEE. •.Office of the Prothonotary CumbeilandCouniy Courthouse .1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH#806119 By: Emily M. Phelan, Esq., Id, No.3 5250 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 • • CUMBERLAND COUNTY BAR • - • ASSOCIATION: • :• CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) TO: MARTIN L. COOK 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 DATE OF NOTICE: 1 COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -4368 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. • IF YOU CANNOT AFFORD TO HIRE, A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE-YOU WITH INFORMATION ABOUT AGENCIES THAT MAY ORFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NOFEE. Office of fhe Prothonotary Cumberland•County Courthouse • 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 806119 CUMBERLAND COUNTY BAR. • ASSOCIATION • CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 Emily. M. hell .q., Id. No.315250 Attorney for Plaintiff Phelan Ha]linan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) TO: MARTIN L. COOK C/O DOUGLAS G. MILLER, ESQUIRE 60 WEST POMFRET STREET CARLISLE, PA 17 ;.. 3222 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -4368 CIVIL CUMBERLAND COUNTY /2.,6 IP( THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. :IMPORTANT_NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DA'Z'E 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: • CUMBERLAND COUNTY BAR . • • - . • ASSOCIATIQN CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (Rule of Civil Procedure No. 236) - Revised SANTANDER BANK, N.A., FORMERLY : CUMBERLAND COUNTY KNOWN AS SOVEREIGN BANK, N.A. vs. KAREN J. COOK MARTIN L. COOK : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 13 -4368 CIVIL Notice is give that a Judgment in the above captioned matter has been entered against you on )3 l7 By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 806119 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. Plaintiff V. Karen J. Cook Martin L. Cook Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13-4368 CIVIL : CUMBERLAND COUNTY $194,569.33 Interest from 04/04/2014 to Date of Sale $4,892.94 ($31.98 per diem) TOTAL Note: Please attach description of property. PH # 806119 f36 tc:o C:OE $199,462.27 Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff At.D,as )1,41) Pit3D3FG) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. Plaintiff v. Karen J. Cook Martin L. Cook Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Filed: jGC.....■-- Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Address where papers may be served: Karen J. Cook 1266 Timber View Drive Mechanicsburg, PA 17050 -9148 Martin L. Cook 3803 Chippenham Road Mechanicsburg, PA 17050 -9127 LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #208, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of five hundred ninety-four and forty-four one-hundredths (594.44) feet West of the intersection of the North side of Dorset Drive and the West side of Chippenham Road; thence by the line of Lot No. 209 South forty-three degrees zero minutes West (S 43 degrees 00 minutes W) a distance of one hundred forty-nine and forty-two one-hundredths (149.42) feet to a point at line of Lot No. 202; thence by same and Lot No. 203 North forty- nine degrees twenty-seven minutes forty seconds West (N 49 degrees 27 minutes 40 seconds W) a distance of one hundred eighty-one and thirty-nine one-hundredths (181.39) feet to a point in PP&L Co. Right-of-Way; thence by same North sixty-five degrees thirty-two minutes twenty seconds East (N 65 degrees 32 minutes 20 seconds E) a distance of one hundred eight-four and thirty-eight one-hundredths (184.38) feet to a point on the West side of Chippenham Road; thence South thirty-six degrees thirty-seven minutes fifty-four seconds East (S 36 degrees 37 minutes 54 seconds E) a distance of thirty-three and seventy-one one-hundredths (33.71) feet to a point at a curve; thence by same and a curve to the left having a radius of four hundred thirty- three and zero one-hundredths (433.00) feet an arc length of seventy-seven and eighty-one one-hundredths (77.81) feet to the place of BEGINNING. CONTAINING 23,206.06 square feet and being known and numbered as 3803 Chippenham Road. UNDER AND SUBJECT, NEVERTHELESS to Declarations of Covenant, Easements, Restrictions, Equitable Servitudes, Charges and Liens dated November 9, 1988 and recorded November 10, 1988 in Cumberland County Miscellaneous Book 356, Page 1095. UNDER AND SUBJECT, also, to all easements and restrictions of record and as set forth on recorded plan described above. UNDER AND SUBJECT, also to a fifty (50 foot) foot right of way to PP&L Company as more fully appears on the above-referenced plan. The access easement for the Homeowner's Association between Lot No. 220 and Lot No. 221 as shown on said plan has been eliminated in favor of a 10 foot (10 foot) bike path easement to Hampden Township centered on the lot line between Lot No. 220 and Lot No. 221. The Recreation Area shown on the Final Plan of Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, will be eliminated and developed as building lot. TITLE TO SAID PREMISES IS VESTED IN Martin L. Cook and Karen J. Cook, h/w, by Deed from Karen J. Cook and Martin L. Cook, dated 06/07/2000, recorded 06/13/2000 in Book 223, Page 272. PREMISES BEING: 3803 Chippenham Road, Mechanicsburg, PA 17050-9127 PARCEL NO. 10-16-1056-166. ritTi3 F PHELAN HALLINAN, LLP THE RROTHONOTAH Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 LUI PR -3 AM ID; 28 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION V. : NO.: 13-4368 CIVIL Karen J. Cook Martin L. Cook Defendant(s) : CUMBERLAND County CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non-owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. Plaintiff V. Karen J. Cook Martin L. Cook Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -4368 CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 3803 Chippenham Road, Mechanicsburg, PA 17050 -9127. Name and address of Owner(s) or reputed Owner(s): Name KAREN J. COOK MARTIN L. COOK 2. Name and address of Defendant(s) in the judgment: Name KAREN J. COOK MARTIN L. COOK Address (if address cannot be reasonably ascertained, please so indicate) 1266 TIMBER VIEW DRIVE MECHANICSBURG, PA 17050 -9148 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 Address (if address cannot be reasonably ascertained, please so indicate) 1266 TIMBER VIEW DRIVE MECHANICSBURG, PA 17050 -9148 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 Cr) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) ERIC H. WITTE ERIC H. WITTE C/O MICHAEL L. SOLOMON, ESQUIRE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION PENNSYLVANIA STATE EMPLOYEES CREDIT UNION C/O MELISSA L. VAN ECK, ESQUIRE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION C/O STEVEN C. COURTNEY, ESQUIRE PH # 806119 2221 BUTTONWOOD CIRCLE HARRISBURG, PA 17110 240 NORTH 3RD STREET 7TH FLOOR HARRISBURG, PA 17101 ONE CREDIT UNION PLACE HARRISBURG, PA 17110 4431 NORTH FRONT STREET FLOOR 3 HARRISBURG, PA 17110 2215 FOREST HILLS DRIVE SUITE 36 HARRISBURG, PA 17112 FORD MOTOR CREDIT COMPANY FORD MOTOR CREDIT COMPANY C/O ANDREW SKLAR, ESQUIRE JONATHAN M. WITTE, ADMINISTRATOR OF THE ESTATE OF ERIC H. WITTE JONATHAN M. WITTE, ADMINISTRATOR OF THE ESTATE OF ERIC H. WITTE C/O MICHAEL L. SOLOMON, ESQUIRE CITIBANK SOUTH DAKOTA, N.A. CITIBANK SOUTH DAKOTA, N.A. C/O DEREK BLASKER, ESQUIRE COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF COMPLIANCE P.O. BOX 6508 MESA, AZ 85216 -6508 1200 LAUREL OAK ROAD SUITE 102 VOORHEES, NJ 08043 820 SOUTH PROGRESS AVENUE HARRISBURG, PA 17110 240 NORTH 3RD STREET 7TH FLOOR HARRISBURG, PA 17101 701 EAST 60TH STREET NORTH SIOUX FALLS, SD 57117 1060 ANDREW DRIVE SUITE 170 WEST CHESTE, PA 19380 DEPARTMENT 280948 HARRISBURG, PA 17128 -0948 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 280946 DEPARTMENT OF REVENUE BUREAU OF HARRISBURG, PA 17128 -0946 COMPLIANCE KINGSWOOD HOMEOWNERS ASSOCIATION C/O EDMUND G. MYERS, ESQUIRE MOFFITT HEART & VASCULAR GROUP, PC C/O GAIL GUIDA SOUDERS, ESQUIRE MOFFITT HEART & VASCULAR GROUP, PC KINGS WOOD HOMEOWNERS ASSOCIATION 301 MARKET STREET P.O. BOX 109 LEMOYNE, PA 17043 111 LOCUST STREET HARRISBURG, PA 17101 1000 NORTH FRONT STREET SUITE 300 WORMLEYSBURG, PA 17043 301 MARKET STREET LEMOYNE, PA 17043 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Address (if address cannot be reasonably ascertained, please indicate) KINGSWOOD HOMEOWNERS ASSOCIATION PH #806119 301 MARKET STREET LEMOYNE, PA 17043 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT KAREN J. COOK C/O MARLIN L. MARKLEY, ESQUIRE DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE INTERNAL REVENUE SERVICE ADVISORY U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING MARTIN L. COOK C/O DOUGLAS G. MILLER, ESQUIRE 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050-9127 3920 MARKET STREET SUITE 303 CAMP HILL, PA 17011 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 WEST POMFRET PROFESSIONAL BUIL 60 WEST POMFRET STREET CARLISLE, PA 17013-3222 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.A. § 4904 relating to unsworn falsification to authorities. Date: 174/z/Pf PH # 806119 By: ■r/ .2; j Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 `r! Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION • vs. : NO.: 13-4368 CIVIL Karen J. Cook Martin L. Cook : CUMBERLAND ,Gou Defendant(s) : c-- - ■ ril .-r:: "'CI ■ i NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ..-- TO: Karen J. Cook Martin L. Cook 1266 Timber View Drive 3803 Chippenham Road : Mechanicsburg, PA 17050-9148 Mechanicsburg, PA 17050-9127 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 3803 Chippenham Road, Mechanicsburg, PA 17050-9127 is scheduled to be sold at the Sheriff's Sale on 09/03/2014 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $194,569.33 obtained by Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215 -563 -7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-4368 CIVIL Santander Bank, N.A., Formerly Known as Sovereign Bank, NA. V. Karen J. Cook Martin L. Cook owner(s) of property situate in HAMPDEN TOWNSHIP, CUMBERLAND County, Pennsylvania, being 3803 Chippenham Road, Mechanicsburg, PA 17050-9127 Parcel No. 10-16-1056-166. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $194,569.33 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #208, Kingswood, Phase B, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of five hundred ninety-four and forty-four one-hundredths (594.44) feet West of the intersection of the North side of Dorset Drive and the West side of Chippenham Road; thence by the line of Lot No. 209 South forty-three degrees zero minutes West (S 43 degrees 00 minutes W) a distance of one hundred forty-nine and forty-two one-hundredths (149.42) feet to a point at line of Lot No. 202; thence by same and Lot No. 203 North forty- nine degrees twenty-seven minutes forty seconds West (N 49 degrees 27 minutes 40 seconds W) a distance of one hundred eighty-one and thirty-nine one-hundredths (181.39) feet to a point in PP&L Co. Right-of-Way; thence by same North sixty-five degrees thirty-two minutes twenty seconds East (N 65 degrees 32 minutes 20 seconds E) a distance of one hundred eight-four and thirty-eight one-hundredths (184,38) feet to a point on the West side of Chippenham Road; thence South thirty-six degrees thirty-seven minutes fifty-four seconds East (S 36 degrees 37 minutes 54 seconds E) a distance of thirty-three and seventy-one one-hundredths (33.71) feet to a point at a curve; thence by same and a curve to the left having a radius of four hundred thirty- three and zero one-hundredths (433.00) feet an arc length of seventy-seven and eighty-one one-hundredths (77.81) feet to the place of BEGINNING. CONTAINING 23,206.06 square feet and being known and numbered as 3803 Chippenham Road. UNDER AND SUBJECT, NEVERTHELESS to Declarations of Covenant, Easements, Restrictions, Equitable Servitudes, Charges and Liens dated.November 9, 1988 and recorded November 10, 1988 in Cumberland County Miscellaneous Book 356, Page 1095. UNDER AND SUBJECT, also, to all easements and restrictions of record and as set forth on recorded plan described above. UNDER AND SUBJECT, also to a fifty (50 foot) foot right of way to PP&L Company as more fully appears on the above-referenced plan. The access easement for the Homeowner's Association between Lot No. 220 and Lot No. 221 as shown on said plan has been eliminated in favor of a 10 foot (10 foot) bike path easement to Hampden Township centered on the lot line between Lot No. 220 and Lot No. 221. The Recreation Area shown on the Final Plan of Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, will be eliminated and developed as building lot. TITLE TO SAID PREMISES IS VESTED IN Martin L. Cook and Karen J. Cook, h/w, by Deed from Karen J. Cook and Martin L. Cook, dated 06/07/2000, recorded 06/13/2000 in Book 223, Page 272. PREMISES BEING: 3803 Chippenham Road, Mechanicsburg, PA 17050-9127 PARCEL NO. 10-16-1056-166. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Vs. NO 13 -4368 Civil Term CIVIL ACTION — LAW KAREN J. COOK MARTIN L. COOK 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: $194,569.33 L.L.: $.50 Interest FROM 4/4/2014 TO DATE OF SALE ($31.98 PER DIEM) - $4,892.94 Atty's Comm: Atty Paid: $318.15 Plaintiff Paid: Date: 4/3/14 (Seal) REQUESTING PARTY: Name: ADAM H. DAVIS, ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215 -563 -7000 Supreme Court ID No. 203034 Due Prothy: Other Costs: David D. Buell, Prothonota Deputy FILEO-OFFICE OF THE PROTHONOTARY 2014 APR 21 PM 2: t+ii CUMBERLAND COUNTY PENNSYLVANIA PHELAN HALLINAN, LLP BY: D. Troy Sellars Esquire Identification No.: 210302 126 Locust Street Harrisburg, PA 17101 Telephone: (215) 563-7000, Ext. 1360 E-mail: troy.sellars@phelanhallinan.com SOVEREIGN BANK, N.A. 824 NORTH MARKET STREET SUITE 100 WILMINGTON, DE 19801 Plaintiff VS. KAREN J. COOK MARTIN L. COOK 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050-9127 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. CIVIL DIVISION : NO. 2013-4368-CIVIL SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: Defendants, Karen J. Cook and Martin L. Cook, filed Chapter 13 Bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania to Docket No.: 14-bk-00575 on February 12, 2014. A copy of the Bankruptcy Docket aq attached hereto, made part hereof and marked as Exhibit "A." Date: PH#806119 By: D. Troy Se s, Esquire Attorney for Plaintiff Exhibit "A" USBC PAM - LIVE - VERSION 5.1 Page 1 of 5 FMDueD, 2002, CREDS U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:14 -bk- 00575 -MDF Date filed: 02/12/2014 Assigned to: Mary D France 341 meeting: 04/24/2014 Chapter 13 Deadline for filing claims: 06/25/2014 Voluntary Deadline for filing claims (govt.): 08/11/2014 Asset Debtor represented by Gary J Imblum Martin L. Cook Imblum Law Offices, P.C. 4902 Carlisle Pike 4615 Derry Street Suite 362 Harrisburg, PA 17111 Mechanicsburg, PA 17050 717 238 -5250 CUMBERLAND -PA Fax : 717 558 -8990 SSN / ITIN: xxx -xx -0234 Email: gary.imblum@imblumlaw.com aka Marty Cook aka Marty L. Cook Trustee Charles J. DeHart, III (Trustee) 8125 Adams Drive, Suite A Hummelstown, PA 17036 717 566 -6097 Asst. U.S. Trustee United States Trustee 228 Walnut Street, Suite 1190 Harrisburg, PA 17101 717 221 -4515 Filing Date # Docket Text 04/11/2014 Receipt of Payment of Fee (Amendment to Schedule D, E, F or an Amended List of Creditors) (1:14 -bk- 00575 -MDF) [misc,payamdfe] ( 30.00) filing fee. Receipt number 6894050, amount $ 30.00. (RE: related document(s) 19 ). (U.S. Treasury) (Entered: 04/11/2014) 19 Payment of Fee (Amendment to Schedule D, E, F or an Amended List of Creditors). (There is no image or paper document associated with this https: / /ecf.pamb.uscourts. gov /cgi- bin/DktRpt.pl ?637276213416698 -L_1 _0 -1 4/16/2014 USBC PAM - LIVE - VERSION 5.1 Page 2 of 5 04/11/2014 entry.) Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook (RE: related document(s)18). (Imblum, Gary) (Entered: 04/11/2014) 04/11/2014 18 (2 pgs; 2 docs) Order filing fee due in the amount of $ 30.00 for 95 Creditors Uploaded without docket entry being made. Fee due on: 4/18/2014. (Gambini, Christopher) (Entered: 04/11/2014) 04/10/2014 17 (2 pgs; 2 docs) Affidavit of disbursement of Trustee funds upon Dismissal and/or Conversion prior to confirmation Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook. (Attachments: # 1 Certificate of Service) (Imblum, Gary) (Entered: 04/10/2014) 04/10/2014 16 (12 pgs) Chapter 13 Plan (Includes no Motion(s) to Avoid Liens and no Motion(s) to Value Collateral) Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook (RE: related document(s) 1). (Imblum, Gary) (Entered: 04/10/2014) 04/10/2014 15 (9 pgs) Employee Income Records Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook. (Imblum, Gary) (Entered: 04/10/2014) 04/10/2014 14 (249 pgs; 3 docs) Schedules A -J and Summary of Schedules, Statement of Financial Affairs, Chapter 13 Statement of Current Monthly Income and Calculation of Commitment Period and Disposable Income - Form 22C ., Statement of Disclosure of Compensation of Attorney for Debtor , Notice to Individual Consumer Debtor , Statement of Services Rendered pursuant to Local Bankruptcy Rule 2016 -1 Filed by Gary 3 Imblum of hnbium Law Offices, P.C. on behalf of Martin L. Cook (RE: related document(s)1). (Attachments: # 1 Main Document # 2 Main Document) (Imblum, Gary) (Entered: 04/10/2014) 03/21/2014 13 (3 pgs) BNC Certificate of Mailing of Rescheduled 341 Meeting (RE: related document(s)12). Notice Date 03/21/2014. (Admin.) (Entered: 03/22/2014) 12 (2 pgs; 2 docs) Meeting of Creditors Rescheduled from previously set date for failure to file documents. Notice sent to all creditors. 341(a) meeting to be held 4/24/2014 https: / /ecf.pamb.uscourts. gov /cgi- bin /DktRpt.pl ?637276213416698- L_1_0 -1 4/16/2014 USBC PAM - LIVE - VERSION 5.1 Page 3 of 5 03/19/2014 at 09:00 AM at Federal Bldg, Trustee Hearing Rm, Rm 1160, 1 lth Fl, 228 Walnut St, Harrisburg, PA 17101. (dehart, III(jr), Charles) (Entered: 03/19/2014) 03/11/2014 10 (29 pgs; 3 docs) Adversary case 1:14-ap-00057. Complaint Filed by Gary J Imblum on behalf of Martin L. Cook against Cumberland County Tax Claim Bureau, Kingswood Homeowners Assoc, Sovereign Bank, PSECU, Citibank of South Dakota, PA Department of Revenue, Ford Motor Credit, Moffitt Heart & Vascular Group, Estate of Eric H. White, Karen Cook. Filing Fee due in the amount of $ 293.00. (Attachments: # 1 Exhibit A # 2 Proposed Order) 31 (Approval of sale of property of estate and of a co-owner - 363(h)) (Imblum, Gary) (Entered: 03/11/2014) 03/07/2014 9 (2 pgs) BNC Certificate of Mailing (RE: related document (s)8). Notice Date 03/07/2014. (Admin.) (Entered: 03/08/2014) 03/05/2014 8 (2 pgs; 2 docs) Order Granting Motion to Extend Time to file Schedules, Statements and other Documents Required by FRBP 1007(b). (RE: related document (s) 7). Clerks Office Follow-Up Due by 4/10/2014. (Gambini, Christopher) (Entered: 03/05/2014) 02/25/2014 7 (4 pgs; 3 docs) Motion to Extend Time to file Schedules, Statements and other Documents Required by FRBP 1007(b). Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook. (Attachments: # 1 Certificate of Service # 2 Proposed Order) (Imblum, Gary) (Entered: 02/25/2014) 02/24/2014 6 (2 pgs) Request for Notice under 2002 Filed by AmeriCredit Financial Services, Inc. dba GM Financial. (AmeriCredit Financial Services) 4 (Entered: 02/24/2014) 02/15/2014 5 (4 pgs) BNC Certificate of Mailing of 341 Meeting Notice (Chapter 13) (RE: related document(s)3). Notice Date 02/15/2014. (Admin.) (Entered: 02/16/2014) 4 (2 pgs; 2 docs) Notice of Incomplete ancVor Deficient Filing. Request submitted to BNC for mailing. (RE: related document(s)1). (Gambini, Christopher) https://ecfpamb.uscourts.gov/cgi-bin/D1ctRpt.pl?637276213416698-L_I_O-1 4/16/2014 USBC PAM - LIVE - VERSION 5.1 Page 4 of 5 02/14/2014 (Entered: 02/14/2014) 02/12/2014 11 Creditors were uploaded by Attorney G. Imblum. This entry has been made by the Clerks Office because the entry Creditor List Uploaded was not docketed by the filing party. (There is no image or paper document associated with this entry.) (RE: related document(s)1). (Gambini, Christopher) (Entered: 03/11/2014) 02/12/2014 FeeDueBK flag removed. (CashReg) (Entered: 02/13/2014) 02/12/2014 3 (3 pgs; 2 docs) Meeting of Creditors and Notice of Appointment of Trustee Charles J. DeHart, III (Trustee), with 341 (a) meeting to be held on 03/27/2014 at 09:00 AM at Federal Bldg, Trustee Hearing Rm, Rm 1160, 1 lth Fl, 228 Walnut St, Harrisburg, PA 17101. Proofs of Claim due by 06/25/2014. Government Proofs of Claim due by 08/11/2014. Objections to Dischargeability due by 05/27/2014. (Docketer, Automatic) (Entered: 02/12/2014) 02/12/2014 Receipt of Chapter 13 Voluntary Petition - case upload(1:14 -bk- 00575) [caseupld,1305u] ( 281.00) filing fee. Receipt number 6805590, amount $ 281.00. (RE: related document(s)1). (U.S. Treasury) (Entered: 02/12/2014) 02/12/2014 2 (1 pg) Certificate of Credit Counseling for Debtor Filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook (RE: related document(s) 1). (Imblum, Gary) (Entered: 02/12/2014) 02/12/2014 1 (8 pgs) Chapter 13 Voluntary Petition. Filing fee due in the amount of $ 281.00 filed by Gary J Imblum of Imblum Law Offices, P.C. on behalf of Martin L. Cook. (Imblum, Gary) (Entered: 02/12/2014) PACER Service Center Transaction Receipt 04/16/2014 13:04:50 PACER (!Client https : / /ecf.pamb.uscourts.gov /cgi- bin /DktRpt.pl ?637276213416698- L_1_0 -1 4/16/2014 USBC PAM - LIVE - VERSION 5.1 Login: fp0039 Code: Description: Docket Report Search Criteria: 1:14-bk-00575-MDF Fil or Ent: filed Doc From: 0 Doc To: 99999999 Term: included Format: html Page counts for documents: included Billable Pages: Cost: 0.30 Page 5 of 5 https://eelpamb.uscourts.gov/cgi-bin1IRtRpt.pl?637276213416698-L_1_0-1 4/16/2014 PHELAN HALLINAN, LLP BY: D. Troy Sellars Esquire Identification No.: 210302 126 Locust Street Harrisburg, PA 17101 Telephone: (215) 563 -7000, Ext. 1360 E -mail: troy.sellars @phelanhallinan.com SOVEREIGN BANK, N.A. 824 NORTH MARKET STREET SUITE 100 WILMINGTON, DE 19801 Plaintiff vs. KAREN J. COOK MARTIN L. COOK 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050 -9127 Defendants Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. • • : CIVIL DIVISION : NO. 2013-4368-CIVIL CERTIFICATION OF SERVICE TO THE PROTHONOTARY: Service was made by sending a true and correct copy of the Suggestion of Bankruptcy by U.S. First Class Mail on persons at the addresses and on the date listed below: Douglas G. Miller, Esquire West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013 -3222 Date: 11/7/JY PH #806119 Gary J. Imblum, Esquire 4615 Derry Street Harrisburg, PA 17111 By: D. Troy Sellars, Esquire Attorney for Plaintiff SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK, Defendants IN THE COURT OF COMMON PEAS OF CUMBERLAND COUNT PENNSYLVANIA "' `z' ,_... c co Case No. 13 -4368 CIVIL SUGGESTION OF BANKRUPTCY Defendant, Martin L. Cook, has filed a petition for relief under Title 11, United States Code, in the United States Bankruptcy Court for the Middle District of Pennsylvania that has been assigned case number 1:14 -bk- 00575 -MDF and suggests that the above action has been stayed by the operation of Title 11 U.S.C. §362. As of April 7, 2014 the bankruptcy is still pending. Specifically, due to the filing of the bankruptcy, Santander Bank's Praecipe for In Rem Judgment, In Rem Judgment should not be entered. The undersigned certified that a copy hereof has been furnished to Adam H. Davis, Esquire, counsel for Plaintiff, by facsimile on this 2 i 4—day of April, 2014. I declare under penalty of perjury that the foregoing is true and correct. Respectfully submitted, Gary J. Imblum, ' squire Attorney I.D. No. 42606 4615 Deny Street Harrisburg, PA 17111 (717) 238 -5250; Fax (717) 558 -8990 Gary.Imbluni@imbiumlaw.com Attorney for Defendant, Martin L. Cook 1 l : HEPROTI OI f 0 I; 2014 AUG 26 4 tk. 9= 56 CUMBERLAND PENS YLVAjIANTY PHELAN HALLINAN, LLP Michael Dingerdissen, Esq., Id. No.317124 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael.Dingerdissen@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) Attorney for Plaintiff : CIVIL DIVISION : No.: 13-4368 CIVIL NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for 09/03/2014 at 10:00 AM in the above -captioned matter has been continued until 10/01/2014 at 10:00 AM. Date: 812.5n9 PH # 806119 Michael Dmgerdissen, Esq., Id. No.317124 Attorney for Plaintiff PHELAN HALLINAN, LLP Michael Dingerdissen, Esq., Id. No.317124 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael .Dingerdissen @ phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANTANDER BANK, N.A., FORMERLY KNOWN AS SOVEREIGN BANK, N.A. Plaintiff v. KAREN J. COOK MARTIN L. COOK Defendant(s) CERTIFICATION OF SERVICE Attorney for Plaintiff : CIVIL DIVISION : No.: 13-4368 CIVIL I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriffs Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: KAREN J. COOK 1266 TIMBER VIEW DRIVE MECHANICSBURG, PA 17050-9148 KAREN J. COOK 1431 TIMBER BROOK DR MECHANICSBURG, PA 17050-9163 Date: Wgipi PH # 806119 KAREN J. COOK 3803 CHIPPENHAM ROAD MECHANICSBURG, PA 17050-9127 MARTIN L. COOK C/O DOUGLAS G. MILLER, ESQUIRE WEST POMFRET PROFESSIONAL BUIL, 60 WEST POMFRET STREET CARLISLE, PA 17JJ 13-3222 Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff LL 144 4 PHELAN HALLINAN,LLP Attorney for Pla ff (�� c?8 Adam H.Davis,Esq., Id. No.203034 "'3ERL 4 t � r1 1617 JFK Boulevard, Suite 1400 PES&S�yL civ Froin°�T One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SANTANDER BANK,N.A.,FORMERLY KNOWN CUMBERLAND COUNTY AS SOVEREIGN BANK,N.A. Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION KAREN J.COOK No.: 13-4368 CIVIL MARTIN L.COOK Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit"A". Adam H.Davis,Esq.,Id.No.203034 Date: Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 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Oft .o F vs : ,,.. � ;', —.s � � icW ,... ...:.. „. ,.,-,. ........:.... ........ ... ..»v;.ra::......a,» .-„U�,.,,ro.aw«eo_. :,..-cern r, r-r.�3� '.,:. ze.,�"”.«�- ..».»., g.:l .sa<,u✓,. d �`., ..,, ,..w ara '�'x .,.a.�$/u„�;; ,. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ,SHERUFF«S OFFICE OF CUMBERLAND COUNTY i-71E0'oF-|cF `:TH-PROTHONOTARy 2014 OCT 114 M. 2:�� ^".`ww^ ,.. -_ ��� _''� ~�,`^'�° CUMBERLAND COUNTY CU����ML�fmu�uwn'` ~m�r w^� OFFICE OF ThE $.14:EPIP.P ----����|U���& ��NN�`�,,`.,^. Sovereign Bank vs. Karen J Cook (et al.) Case Number 2013-4368 SHERIFF'S RETURN OF SERVICE 06/19/2014 07:57 PM - Deputy Shawn Harrison, being duly sworn according tolaw, 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 actionupon the property located at 3803 Chippenham Road, Mechanicsburg, PA 17050, Cumberland County. 06V19%2014 07:57 PM - Deputy Shawn Harrison, 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 the Defendant, to wit: Martin L. Cook at 3803 Chippenham Road, Hampden Township, Mechanicsburg, PA 17050, Cumberland County. 06/24/2014 04:45 PM - Deputy Brian Grzyboski, 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 the Defendantto wit: Karen J Cook at 1266 Timber View Drive, Hampden Township, Mechanicsburg, PA 17050, Cumberland County. 08/27/2014 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriff's Sale Continued to 10/1/2014 08/15/2014 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/7/2015 09/26/2014 Ronny R Anderson, Shehff, being duly sworn according to |aw, states that this writ is returned "stayed", per Ietter of instruction from Attorney. SHERIFF COST: $5,143.86 SO ANSWERS, October 13, 2014 RONNYRANDERSON, SHERIFF gc. �� �� ��� u�~ �r wo0un*mmSheriff, Teleosu/nc, On May 19, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Known and numbered as, 3803 Chippenham Road, Wormleysburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 19, 2014 By: 6.-1--LdLt 51))/L,t_o_ka Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-4368 Civil SOVEREIGN BANK vs. KAREN J. COOK Atty.: Joseph Schalk By virtue of a Writ of Execution No. 13-4368 CIVIL. Santander Bank, N.A., Formerly Known as Sovereign Bank, N.A. v. Karen J. Cook, Martin L. Cook owner(s) of property situate in HAMPDEN TOWNSHIP, CUMBER- LAND County, Pennsylvania, being 3803 Chippenham Road, Mechanics- burg, PA 17050-9127. Parcel No. 10-16-1056-166. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $194,569.33. 34 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. Marie Coyne, Ed' o SWORN TO AND SUBSCRIBED before me this 5 da of July, 2014 Notary COMMONWEALTH OF PENNSYLVANIA martmeammwm.ter NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 400712111.1011IIIICIS. 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 hc Patriot Jews 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. 2013-4368 Civil Term SOVEREIGN BANK vs. KAREN J COOK Atty: Joseph Schalk By virtue of a Writ of Execution No. 13-4368 CIVIL Santander Bank, NA., Formerly Known as Sovereign Bank, N.A. v. Karen J. Cook Martin L. Cook owner(s) of property situate in HAMPDEN TOWNSHIP, Cumberland County, Pennsylvania, being 3803 Chippenham Road, Mechanicsburg, PA 17050-9127 Parcel No. 10-16-1056-166. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $194,569.33 Sworn to an This ad ran on the date(s) shown below: 07113/14 16--7210c subscribed before me this 20 day of August, 2014 A.D. COMMON EALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES