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HomeMy WebLinkAbout13-5901 For Prothonotary Use Only. Suplrem a Court of Pennsylvania C(.% u ; P lea s it C4 Wit. j Docket No. and The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of leadin s or other papers as required bh lmv oi- rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Cenlar FSB Lead Defendant's Name: Alexander P. Liffick, Sr. T Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney (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 ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) ❑ Slander/Libel/ Defamation ❑ Employment Dispute: 1:1 Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other I" D = ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS El Toxic Waste ❑Other: ❑ Ejectment 13 Common Law /Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage a e Foreclosure: Commercial El Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title El Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 F 1 LE0 - 0` lam ; LCF T PR OT'-'I t�Tt•e 2 013 OCT 10 AM 10: 2c CUMBERLAND C0U'41'�' PEINNSY! VANIA McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 Cenlar FSB Cumberland County 425 Phillips Boulevard Court of Common Pleas Trenton, NJ 08618 n / Number V. Alexander P. Liffick, Sr. 282 St. John's Drive Camp Hill, PA 17011 COMPLAINT IN MORTGAGE FORECLOSURE 1 03 7s�c ��� iggso9 g h� aq u wo File # 68276 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisions de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR P A P E L A S U ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION HIRE A LAWYER, THIS OFFICE MAY BE ACERCA DE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH S I USTED NO PUEDE INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 File # 68276 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Cenlar FSB, duly organized and doing business at the above - captioned address. 2. The Defendant is Alexander P. Liffick, Sr., who is the mortgagor and owner ofthe mortgaged property hereinafter described, whose last -known address is 282 St. John's Drive, Camp Hill, PA 17011. 3. On March 30, 2007, Alexander P. Liffick, Sr., mortgagor, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee for Taylor, Bean & Whitaker Mortgage Corp. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1987, Page 372 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On October 24, 2012, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., as Nominee for Taylor, Bean & Whitaker Mortgage Corp. to Cenlar FSB, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201233653, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 104 North 21 st Street, Camp Hill, Pennsylvania 17011. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due April 1, 2012 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File # 68276 Page 3 7. The following amounts are due on the mortgage: Principal Balance $ 127,011.48 Interest through September 30, 2013 $ 13,048.69 (Plus $22.93 per diem thereafter) Pre - Accelerated Late Charges $ 171.28 Attorney's Fee $ 1,650.00 Escrow Advance $ 6,102.61 Property Inspections $ 156.00 GRAND TOTAL $ 148,140.06 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to the Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $148,140.06, together with interest at the rate of $22.93 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. MCCABE7 BERG & CONWAY, P.C. 2� f BY: �l [ ] Terrence f. McCabe, Esquire [ arc S. Wei erg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph L Foley, Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff File # 68276 Page 4 VERIFICATION - l -C`f - 6o I�e y , hereby states that he /she is Fprec lowt ��o.n� LeaA of Cenlar FSB, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 6e,ZA A , b"- - /7 Name: }an Ile y q -Z- U DATE: w� �j Title: F rec 65'i r-Q Tpo en L 0 , File #: 68276 Name: Cenlar FSB v. Alexander P. Liffick, Sr. File # 68276 Page 5 ..�a... ;:::..:. SCHEDULE 0 PROPMYDNCMFWN i l rofam9d in We Comm M ot �t ewe at jok; mm p bounded t o **I kwd � � , . c-0 Ghwc 1 mot* vt jw . bk W, awn U* w :Of #Mac � i� ft chump � ' or fonme k nww n and pumbtrW as 104 N oM 21 .ft 0. B ERG iKnawn m 104 Noft 21 Gt Mmtt Cp p PA 17011. doW do .uat 4 O Cenlar FSB IN TI -IE COIJRT OF COMMON PLEAS OF c Plaintiff CtJMBERLAND COUNTY, PENNSY VA20A .� � o i vs. rq fi Alexander P. Liffick, Sr. �' Civil '� © �' Defendant 7" c �. :4 C? CD NOTICE OF RESIDENTIAL MORTGAGE FORECLOS E DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. f Respectfully su I t nA� l Date [Signature of Counsel for Plaintiffy 68276 Page 2 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/PRI M ARV APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ 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 91: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2n Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuft. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑No❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑No❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff tr of CarIri pi,/ Jody S Smith Chief Deputy � 6;.� OCT C7 AM I: r.:! Richard W Stewart �` Solicitor :}F . ..3 T f;04;k111,—; _ t� BERLAihii,�J j,v(�:+ F E NNS``i L`YA IA Cenlar FSB Case Number vs. Alexander P Liffick, Sr. 2013-5901 SHERIFF'S RETURN OF SERVICE 10/11/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Alexander P Liffick, Sr., 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 104 N. 21 Street, Camp Hill Borough, Camp Hill, PA 17011. Residence is vacant. 10/11/2013 08:52 PM - Deputy Shawn Gutshall, 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: Alexander P Liffick, Sr. at 282 St. John's Drive, Hampden Township, Camp,air,. PA 17011`. "tol GUTSHALL, DEPUTY SHERIFF COST: $61.90 SO ANSWERS, October 14, 2013 RONNY ANDERSON, SHERIFF :;cu-hrs.Snenf` Te eoseft • McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 U• THE PttO THOND TAW; ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 2013 DEC 12 AM I!: 39 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 CUMBERLAND COUNTY BRIAN T. LAMANNA,ESQUIRE-ID#310321 PENNSYLVANIA ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Cenlar FSB CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Alexander P. Liffick, Sr. Number 13-5901 Civil Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Alexander P. Liffick, Sr., in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civi l Procedure,and assess damages as follows: Amount Due $ 148,140.06 Interest from 10/01/13 to 12/09/13 $ 1,605.10 Total $ 149,745.16 McCABE,WEISBERG AND CONWAY,P.C. BY: / / � [ ] Terre /e J. cCabe,Esq. [ ]Marc S. Weisberg, Esq. [ ]Edward D. Conway,Esq. [ ]Margaret Gairo, Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak, Esq. [ ]Marisa J. Cohen,Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna,Esq. [ ]Ann E. Swartz, Esq. [ ] Joseph F. Riga,Esq. [ ]Joseph I. Foley, Esq. \� [ ] Celine P. DerKrikorian, Esq. N]Jennifer L. Wunder, Esquire l.l,`�` Q y [ ] Lena Kravets,Esquire C.- ap.) ^O`I Attorneys for Plaintiff 0)'j ss n AND NOW,this 1 day of �' ,2013,Judgment is entered in favor of Plaintiff,Cenlar FSB, we& and against Defendant, Alexander P. Liffick, Sr., in rem only and not in personam, and damages are assessed in the amount of$149,745.16,plus interest and costs. BY THE OTHO STA McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 Cenlar FSB CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Alexander P.Liffick, Sr. Number 13-5901 Civil Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,A Iexander P.Liffick, Sr., is not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C.App.§501,et seq.;and that the Defendant,Alexander P. Liffick,Sr.,is over eighteen(18)years of age,and resides as follows: Alexander P.Liffick, Sr., 282 St. John's Drive Camp Hill,PA 17011 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED vv BY: /` BEFORE ME THIS DAY Terrenabe Esq. Marc S. Weisberg, Esq. [ ]Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. OF ,2013 [ ]Andrew L. Markowitz, Esq. [ ]Heidi R. Spivak, Esq. • [ ] Marisa J.Cohen,Esq. [ ] Christine L. Graham, Esq. .+.. ] Brian T. LaManna, Esq. [ ]Ann E. Swartz, Esq. NOT 'Y 'UBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I. Foley, Esq. retttosn..V`AN1A [ ] Celine P.DerKrikorian, Esq. [u] Jennifer L. Wunder, Esquire Lena Kravets,Esquire ww ROiRRtL SE Notary public Attorneys for Plaintiff t::,��v;sy Lynn R1oC h a I'hila.County Commission jt�ExP�res Sopte,�ber 7,2018 Results as of:Dec-09-2013 06:39:05 Department of Defense Manpower Data Center SCRA 3.0 Af Status Report Pursuant to Servicemembers Civil Relief Act Last Name: LIFFICK, SR. First Name: ALEXANDER Middle Name: P Active Duty Status As Of: Dec-09-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. + + . f f � Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOM Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: U67EEE90D0FDPF0 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Cenlar FSB COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Number 13-5901 Civil Alexander P.Liffick, Sr. Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last-known mailing address of the Defendant is: Alexander P. Liffick, Sr. 282 St.John's Drive Camp Hill,Pennsylvania 17011 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: �-�- BEFIRE ME THIS DAY [ ] Terrenc . Mc abe,Esq. [ ] Marc S. Weisberg. Esq. [ ] Edward D. Conway,Esq. [ ] Margaret Gairo, Esq. OF u . ,2013 [ ]Andrew L. Markowitz,Esq. [ ] Heidi R. Spivak, Esq. / / [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. (t ti- �`'Cy' [ ]Brian T. LaManna,Esq. [ ]Ann E. Swartz, Esq. A` NOT RY P BLI [ ]Joseph F.Riga,Esq. [ ] Joseph I. Foley, Esq. � [ ]Celine P.DerKrikorian,Esq. [y] Jennifer L. Wunder, Esquire J [ ]Lena Kravets,Esquire Attorneys for Plaintiff corava'+9eoyF•pixk!or PENNSYLVANIA NOR ITAL SEAL Quh;ic r,;1I'cC i�r'a .t1ry Kimberly Lr p�'' ( Ot 1"i111:.'w'.�x�'�4aM�..1—ii�f�:,L•:^an'y Cii 2016 My Commission�;��sr�s��.nre;r; r�, McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-1D#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 Cenlar FSB CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 13-5901 Civil Alexander P.Liffick, Sr. Defendant CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED � 6,A._---..._BY: i BEFO' ME THIS DAY [ ]Terrence .Mc abe,Esq. [ ] Marc S. Weisberg, Esq. [ ] Edward D. Conway,Esq. [ ]Margaret Gairo, Esq. OF .0 �,r ,2013 [ ]Andrew L. Markowitz,Esq. [ ] Heidi R. Spivak, Esq. G [ ]Marisa J.Cohen,Esq. [ ] Christine L. Graham, Esq. �4 � [ ] Brian T. LaManna,Esq. [ ]Ann E. Swartz, Esq. N•TA, Y PUB C [ ]Joseph F.Riga, Esq. [ ] Joseph I. Foley, Esq. [ ]Celine P.DerKrikorian, Esq. [X]Jennifer L. Wunder, Esquire [ ] Lena Kravets,Esquire Attorneys for Plaintiff COMP:`oNWEALTh OF PENNIYLVANIA F CTARiAL SEAL Kimberly LynnicCioake�a Notary Public City of Phila ial-,l-sa Phl e County Commission Expires September 7,2016 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the infbnnation from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE,WEISBERG AND CONWAY,P.C. BY: ] Terrenc . Mc abe, Esq. [ ] Marc S. Weisberg, lsq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, l;sq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, [ ] Brian T. LaManna,Esq. [ ]Aim E. Swartz, Esq. [ ] Joseph F. Riga,Esq. [ ] Joseph I.Foley, Esq. [ ] Celine P.DerKrikorian,Esq. [}Q]Jennifer L. Wunder, Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff Cenlar FSB v.Alexander P.Liffick, Sr. Cumberland County;Number: 13-5901 Civil • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 17013 Curt Long �J �- Prothonotary 1 v November 4, 2013 To: Alexander P. Liffick, Sr. 282 St. John's Drive Camp Hill, Pennsylvania 17011 Cenlar FSB Cumberland County Court of Common Pleas vs. Number 13-5901 Civil Alexander P. Liffick, Sr. NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT I' BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERTY ACCION DEBIDA DENTRO I)E DIEZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTB PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE INMEDIATAMENTE. SI USTED NO TIF.NE A UN ABOGADO,VA A 0 TO PROVIDEYOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association S I USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SEE CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ISLI:SGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO, Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,WEISBERG AND CONWAY,P.C. B B . [ ]Terrence J.McCabe,Esquire [ arc S.Weisberg,Esquire [ ]Edward D. Conway,Esquire i ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] Marisa J.Cohen,Esquire [-1—Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff hm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Alexander P. Liffick, Sr. 282 St.John's Drive Camp Hill, Pennsylvania 17011 Cenlar FSB COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Alexander P.Liffick, Sr. No. 13-5901 Civil Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGME has b enter the above pros. =•ing as indicated below. p a:•r.•. 4/41 X Judgment by Default '1 \?-\\ Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe, Weisberg and Conway, P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 13-5901 Civil Term Cenlar FSB V. AMOUNT DUE: $149,745.16 -r, Alexander P.Liffick,Sr. INTEREST: from 12/10/13 - -;-- $4,357.74 at$24.62 co ATTY'S COMM.: a tr_ + Z N G + U) -.-I COSTS: <77 { ' Zp s ' TO THE PROTHONOTARY OF SAID COURT: 71 The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based t �r a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 og 1•`966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 104 North 21 st Street Camp Hill Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishees)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: i BY: [ ]Terrence J.McCabe,Esq. [ arc S.Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. o [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. a [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. C�f Attorneys for Plaintiff I v �• S �< <� Firm:MCCABE,WEISBERG AND CONWAY < <� Address:123 S.Broad Street,Suite 1400 Sv Philadelphia,PA 19109 Attorney for: Plaintiff a S Telephone: 215 790 1010 Supreme Court ID No. i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-5901 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENLAR FSB Plaintiff(s) From ALEXANDER P.LIFFICK,SR. (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $149,745.16 L.L.: $.50 Interest FROM 12/10/13-$4,357.74 AT$24.62 Atty's Comm: Due Prothy: $2.25 Atty Paid: $210.65 Other Costs: Plaintiff Paid: Date: 1/28/14 f J hA:&cLZ- ! David D.Buell,ProthonotaDiL (Seal) Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address:MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 i LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill,County of Cumberland, and State of Pennsylvania,more particularly bounded and described as follows: BOUNDED on the East by Church Street(21'Street); on the West by land formerly of Captain Moore now or formerly of Jacob Wolf,on the South by land now or formerly of Isaac Wolf; containing 51 feet,more or less, in front on Church Street and extending back 120 feet,more or less,to lands now or formerly of Jacob Wolf. HAVING THEREON ERECTED a 2 story frame house known and numbered as 104 North 2l'Street, Camp Hill,Pennsylvania. BEING known as 104 North 21'Street,Camp Hill,PA 17011. BEING the same premises which MARY L. WEST,A SINGLE INDIVIDUAL by deed dated March 14,2007 and recorded April 12,2007 in the office of the Recorder in and for Cumberland County in Deed Book 279, Page 1888, granted and conveyed to Alexander P.Liffick, Sr., a single individual,fee. TAX MAP PARCEL NUMBER: 01-21-0271-204 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,'ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 ` ~� BRIAN T.LaMANNA,ESQUIRE-ID#310321 ' ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 ` JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 c,Lca " y.C) � Philadelphia,Pennsylvania 19109 d �r .--C S 215 790-1010 n ?a Cenlar FSB CUMBERLAND COUNTY -� COURT OF COMMON PLEAS Plaintiff V. NO: 13-5901 Alexander P.Liffick, Sr. Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 104 North 21st Street,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Alexander P.Liffick,Sr. 282 St.John's Street Camp Hill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Alexander P.Liffick,Sr. 282 St.John's Drive Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 104 North 21st Street Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite 4204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax. Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: [ ]Terrence J.McCabe,Esq. [ arc S.Weisberg,Esq. DATE [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph 1.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 s HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 - Y � v BRIAN T.LaMANNA,ESQUIRE-ID#310321T ° ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 y CD A€ JOSEPH I.FOLEY,ESQUIRE-ID#314675 .• -.�.:. CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Cenlar FSB COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Alexander P.Liffick, Sr. Number 13-5901 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Alexander P.Liffick,Sr. 282 St.John's Drive Camp Hill,Pennsylvania 17011 Your house(real estate)at 104 North 21st Street,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on June 4,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$149,745.16 obtained by Cenlar FSB against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Cenlar FSB the back payments,late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C.at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 1.7013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Cenlar FSB Plaintiff v. Alexander P. Liffick, Sr. Defendant Mi' E3-3 .ICS 0TH3NJTA 2�l1 APR 16 Ate 10: 54 CUMBERLAND CGULNT Y PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 13 -5901 AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 10th day of April, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF , 2014 NOTARY ' BL C V +u ONWEAL OP PENNSYLV NOTARIAL SEAL BARBARA J. FOYER, Notary Public ComPhiladelphia, Phila Cou my 12 2018 A McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Te ence McCabe, Esquire [ ] Edward I Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ 1 Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff [ ] Marc S. Weisberg, Esquire ,f.]- Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Cenlar FSB Plaintiff v. Alexander P. Liffick, Sr. Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 13 -5901 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 104 North 21st Street, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Alexander P. Liffick, Sr. 282 St. John's Street Camp Hill, Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Alexander P. Liffick, Sr. 282 St. John's Drive Camp Hill, Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: File #68276 Page 1 Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants /Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division' Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Address 104 North 21st Street Camp Hill, Pennsylvania 17011 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 PO BOX 280948 Harrisburg PA 17128 -0948 File #68276 Page 2 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 U.S. Dept. of Justice, Rm 4400 950 Pennsylvania Avenue, NW Washington, DC 20530 U.S. Dept. of Justice, Rm 5111 950 Pennsylvania Avenue, NW Washington, DC 20530 File #68276 Page 3 8. Name and address of Attorney of record: Name None Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE McCABE, WEISBERG & CONWAY, P.C. BY: 42.t/ [ ] Terrence J/McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff Re: Cenlar FSB v. Alexander P. Liffick, Sr. et al. Cumberland County; Number: 13 -5901 [ ] Marc S. Weisberg, Esquire [/]"Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire File #68276 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Cenlar FSB Plaintiff v. Alexander P. Liffick, Sr. Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 13 -5901 DATE: April 10, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Alexander P. Liffick, Sr. PROPERTY: 104 North 21st Street, Camp Hill, Pennsylvania 17011 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $149,745.16 The above - captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on June 4, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. • Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 2080 Philadelphia,•PA 19109 ATTN:D. DellaPenna -68276 o Certified r M V O Recorded Delivery (International) 0 COD 0 Registered Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 signature Confirmation °1��`ed �• V, U.S. : 9 - United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 10 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 11 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 12 Commonwealth of PA Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriff's Sales 13 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 14 United States of America Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 15 United States of America c/o Atty General of the United States U.S. Dept. of Justice, Rm 4400 950 Pennsylvania Avenue, NW Washington, DC 20530 16 United States of America c/o Atty General of the United States U.S. Dept. of Justice, Rm 5111 950 Pennsylvania Avenue, NW Washington, DC 20530 Total Number of Pieces Listed by Sender 16 Total Number of Pieces Received at Post Office Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF 7E4i UF!FF itsFILED-OFFICE THE PROTHONOTARY 20411 4JUL 25 PM 2: 34 CUMBERLAND COUNTY PENNSYLVANIA Cenlar FSB vs. Alexander P Liffick, Sr. Case Number 2013-5901 SHERIFF'S RETURN OF SERVICE 04/01/2014 07:07 PM - Deputy Brian Grzyboski, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 104 North 21st Street, Camp Hill - Borough, Camp Hill, PA 17011, Cumberland County. 04/02/2014 02:42 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Alexander P Liffick, Sr. at 282 St. John's Drive, Hampden Township, Camp Hill, PA 17011, Cumberland County. 06/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of $1.00 to Attorney Terrance McCabe, on behalf of, Federal Home Loan Mortgage Corp., being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $910.68 SO ANSWERS, July 02, 2014 (c) CountySu to Sheriff, Telecsatt. Inc. RONNY R ANDERSON, SHERIFF W.00 pd. a 4 On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA, �:: Known and numbered as 104 North 21st Street, co • Camp Hill, as Exhibit "A" filed with this • Writ and by this Reference incorporated herein. Date: March 3, 2014 By: eJ, Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-5901 Civil Term Cenlar FSB vs. Alexander P. Liffick, Sr. Atty.: Terrence McCabe ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Camp Hill, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows: BOUNDED on the East by Church Street (21st Street); on the West by land formerly of Captain Moore now or formerly of Jacob Wolf, on the South by land now or formerly of Isaac Wolf; containing 51 feet, more or less, in front on Church Street and extending back 120 feet, more or less, to lands now or formerly of Jacob Wolf. HAVING THEREON ERECTED a 2 story frame house known and numbered as 104 North 21st Street, Camp Hill, Pennsylvania. BEING known as 104 North 21st Street, Camp Hill, PA 17011. BEING the same premises which MARY L. WEST, A SINGLE INDI- VIDUAL by deed dated March 14, 2007 and recorded April 12, 2007 in the office of the Recorder in and for Cumberland County in Deed Book 279, Page 1888, granted and con- veyed to Alexander P. Liffick, Sr., a single individual, fee. TAX MAP PARCEL NUMBER: 01- 21-0271-204. 76 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: April 18, April 25 and May 2, 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. isa Marie Coyne, Edi or SWORN TO AND SUBSCRIBED before me this 2 da of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 6-' The Patriot -News Co. ,2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotNews 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. la or by co fr< L THAT CERTAIN piece or ba arcel of land situate in the Borough no of Camp Hill, County of Cumberland, H. and State of Pennsylvania, more a particularly bounded and described nu as follows: C< BOUNDED on the East by Church BI Street (21st Street); on the West by St--r,..-s,,vri.= - -- BEING the same premises which MARY L WEST, A SINGLE INDIVIDUAL by deed dated March 14, 2007 and recorded April 12, 2007 in the office of the Recorder in and for Cumberland County in Deed Book 279, Page 1888, granted and conveyed to Alexander P. Liffick, Sr., a single individual, fee. TAX MAP PARCEL NUMBER: 01- 21-0271-204 PURLICATIONT rw 2013-5901 Civil Term Cenlar FSB Vs Alexander P Uffick, Sr. Atty: Terrance McCabe This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 Swor and s bscribed before me this 0 gioMay, 2014 A.D. COMM':NWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn W?rfel, Notary Pubic Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOUATTON OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal Home Loan Mortgage Corp is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 28th day ofJanuary, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 5901, at the suit of Cenlar FSB against Alexander P. Liffick Sr. is duly recorded as Instrument Number 201416263. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,P-5 0) day of JA( , A.D. l:AV_ )3A/10 (Jk bCpU Recorder of Dei Weider of Deeds, Cumberland County, Cattlek,1% My Commission Expires the First Monday of Jan, 2011