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HomeMy WebLinkAbout13-5520 Supreme Court of Pennsylvania Court rov ommon Pleas 0 %k , .. v:N For Prothonotary Use Only: Civll'Cef Sheet CUMBERLAND r "' ° � county Docket No: The information collected on this forni is used solely for court administration proposes. This form does not supplement or replace thefiling and service ofl2leadings 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: PNC BANK, NATIONAL Lead Defendant's Name: ERIC J. SHAFFER T ASSOCIATION I Are money damages requested? El Yes Z No Dollar Amount Requested: El within arbitration limits (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes 0 No A Name of Plaintiff /Appellant's Attorney: Melissa J. Cantwell, Esq., Id. No.308912, 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) CIVIL 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: Q ❑ 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 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ED 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 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 S Aio3. �s r��L "� 43 (/'Zft,g y 02 'IS88 File #: 929765 ' E FFIC" E 20i3 0 21 ) 20 AIM 10: e9 CUMBERLAND BERLAND COUNT Y PENNSYLVANIA PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Melissa. Cantwell @phelanhallinan.com 215 -563 -7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION C/O WELLS FARGO BANK, N.A. CIVIL DIVISION 3476 STATEVIEW BOULEVARD / `-�- FORT MILL, SC 29715 NO.: 13 - S-5;.ZO Plaintiff, vs. ERIC J. SHAFFER 903 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 -2884 Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes PNC BANK, NATIONAL ASSOCIATION, by its attorneys, Phelan Hallinan, LLP and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is PNC BANK, NATIONAL ASSOCIATION, C/O WELLS 062 -PA -V3 e ' FARGO BANK, N.A., 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendant, ERIC J. SHAFFER, is an individual whose last known address is 903 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 -2884. 3. PNC BANK, NATIONAL ASSOCIATION, directly or through an agent, has possession of the Promissory Note. PNC BANK, NATIONAL ASSOCIATION is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A ", attached hereto and made a part hereof. 4. On or about December 20, 2007, ERIC J. SHAFFER made, executed and delivered to PNC MORTGAGE, LLC a Mortgage in the original principal amount of $107,000.00 on the premises described in the legal description marked Exhibit "B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 200746963. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded May 14, 2013, the mortgage was assigned to PNC BANK, NATIONAL ASSOCIATION which Assignment is recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201315773. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. ERIC J. SHAFFER is record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due March 1, 2013. 062 -PA -V3 8. As of 09/06/2013, the amount due and owing Plaintiff on the mortgage is as follows: Principal Balance $99,527.74 Interest $3,614.58 02/01/2013 through 09/06/2013 Escrow Deficit $592.91 TOTAL $103,735.23 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 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). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. 062 -PA -V3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $103,735.23, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date: Melissa J. Cantwell, Es Attorney for Plaintiff 062 -PA -V3 Exhibit "A" NOTE DECEMBER 20, 2007 [Date] [City] [State] 903 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ * * ** *107,000.00 (this amount is called "Principal "), plus interest, to the order of the Lender. The Lender is PNC MORTGAGE, LLC I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.083 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning on FEBRUARY 01, 2008 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note, Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on JANUARY 01, 2038 , I still owe amounts under this Note, I wilt pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments atWELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ * ** *647.24 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. MULTISTATE FIXED RATE NOTE - Single Family- Fannie Mae/Freddie Mac UNIFORM INSTRUMENT AN (000s) Form 3200 1/01 VM P MORTGAGE FORMS - (800)521 -7281 Pape 1 of 3 Initial.. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit, and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8 OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. Form 32001/1 -6N poo5) Pape 2 of 3 InRlelx 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts 1 owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. (Seat) (Seal) J SHAFFER - borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower [Sign Original Only] aN r000s> Page 3 of 3 Form 3200 1101 Exhibit "B" LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Mechanicsburg, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly describe as follows: ALL THAT CERTAIN unit in the property known, named and identified in the Declaration referenced to below as 'Walnut Villas Condominium' located in the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. Cons. State.Ann 3101, et seq. (Purdon Supp. 1985) by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, dated July 31, 1985, and recorded on August 14, 1985 in Miscellaneous Book Vol. 308, Page 147, being and designated in such Declaration as Unit No. 903, as more fully described in such Declaration, together with a proportionate undivided interest in the common Elements as such Condominium as set forth in such Declaration and any amendments thereto hereafter recorded in the aforesaid office. BEING the same premises which John N. Pikulin and Edna Pikulin by Deed dated October 5, 1999, and recorded October 6, 1999 in Cumberland County Deed Book 209 -243, granted and conveyed unto John N. Pikulin. PROPERTY ADDRESS: 903 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 -2884 PARCEL #18-22- 0519- 001.- U -M903- Filet 929765 f VERIFICATION Steve DeFurio hereby states tha he he is Vice President Loan Documentation of WELLS FARGO BANK, N.A., mortgage servicing agent for plaintiff in this matter tha he he 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 ofeiher 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. Further, due to its mortgage servicing agency relationship with plaintiff, WELLS FARGO BANK, N.A. is in possession and control of all documents and records supporting the statements in the foregoing pleading and, therefore, the undersigned, rather than an officer or employee of plaintiff, is the appropriate individual to make this Verification pursuant to Pa.R.C.P. 1024(c). �0 e Name: Steve DeFurio Title: Vice President Loan Documentation Company: Wells Fargo Bank N.A. Date: 09/11/2013 085 -PA -V2 File #929765 FORM 1 PNC BANK, NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. ERIC J. SHAFFER Defendant(s) Civil 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 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 to meet 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: S E P 17 2013 Date Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff 2 r n y � •../ n� C.d CD V d_ i CD "�4 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Date Financial Worksheet 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 t the best of your knowledge: o CUSTOM ER/PRIMARY A Borrower name(s): Property Address: City: Is the property for sale? Yes ❑ No State: Zip: Realtor Name: ❑ Listing date: Price: $ Borrower Occupied? Realtor Phone: Yes _ Mailing Address (if different): ❑ No [] City: Phone Numbers: State: Zip: Home; Office: Email: Cell: Other: # of people in household: How long? M Mailing Address: City: Phone Numbers: H State: Zip: ome: Office: Email: Cell: Other: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Date You Closed Your Loan: Type of Loan: - -- Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: -- ---- -- Included Taxes & Insurance: Primary Reason for Default Is-the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile 42 : Model: Year: Amount owed: Value: Other transportation (automobiles boats motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: I • Monthly Gross Monthly Net 2• Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): I • monthly amount: 2• monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child 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) SHERIFF'S OFFICE OF CUMBERLAND COUNTY _;,,i - Ronny R Anderson 1 1 a Sheriff Jody S Smith '' �'''- 2 t� � `k Chief Deputy Richard W Stewart �'r ,aSyU' ,! Solicitor r ,,F THE Si EERi PNC Bank National Association vs. Case Number Eric J. Shaffer 2013-5520 SHERIFF'S RETURN OF SERVICE 09/30/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Eric J. Shaffer, 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 903 Old Silver Spring Road, Mechanicsburg Borough, Mechanicsburg, PA 17055-2884. Residence is vacant, deputies were advised that the defendant moved out approximately three months ago and to this date Mechanicsburg Postmaster has not provided a good address for the defendant. SHERIFF COST: $44.30 SO ANSWERS, October 24, 2013 RONNY R ANDERSON, SHERIFF .. %our;vSure Sheriff Tel,osc't..