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Home My WebLink About13-6929 Supreme Co Pen nsylvania Con f ,Colmrn0 leas For Prothonotary Use Only: C •1 ! , v�r She t t 'F Docket No: Cu . erlarid t' S COUIItIy I V l The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and sendce ofpleadings or other papers as required by law or rules of court. Commencement of Action: S 8 Complaint ® Writ of Summons 0 Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Caliber Home Loans, Inc. f /k/a Vericrest Financial, Inc. Daniel J. Rasy and Shannon T Rasy T Dollar Amount Requested: ©within arbitration limits I Are money damages requested? 0 Yes EM No (check one) ®x outside arbitration limits O N Is this a Class Action Suit? © Yes S No Is this an MDJAppeal? ( Yes [ @ No A Name of Plaintiff /Appellant's Attorney: Craig Oppenheimer, Esquire 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 0 Intentional © Buyer Plaintiff Administrative Agencies ® Malicious Prosecution Debt Collection: Credit Card Board of Assessment ® Motor Vehicle E3 Debt Collection: Other Board of Elections n Nuisance Dept. of Transportation n Premises Liability Statutory Appeal: Other S ® Product Liability (does not include E mass tort) Employment Dispute: © Slander/Libel/ Defamation Discrimination t C 0 Other: Employment Dispute: Other 0 Zoning Board T © Other: I ® Other: O MASS TORT 0 Asbestos N [3 Tobacco Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Other: El Ejectment 13 Common Law /Statutory Arbitration ® B Eminent Domain/Condemnation ® Declaratory Judgment ® Ground Rent n Mandamus ® Landlord/Tenant Dispute F3 Non- Domestic Relations F1 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY [I Mortgage Foreclosure: Commercial 13 Quo Warranto Dental El Partition Q Replevin 0 Legal ® Quiet Title © Other: ® Medical ® Other: Other Professional: Updated 1/1/2011 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire n , Kevin P. Diskin, Esquire l r13 PoV 22 A1 tg 9 Craig Oppenheimer, Esquire .. X111 ID. Nos. 04267 / 86727 / 313264 , Y D pjJ TY One Jenkintown Station, Suite 104 a dlA 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886 -8790 Fax: 215- 886 -8791 Caliber Home Loans, Inc. f/k/a Vericrest IN THE COURT OF COMMON PLEAS Financial, Inc., CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: PLAINTIFF, CIVIL ACTION V. MORTGAGE FORECLOSURE Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS COMPLAINT - CIVIL ACTION NOTICE TO DEFEND 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 1 S / CAL -188F FHLMC /KG )V51H of 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 - 249 -3166 and 800 - 990 -9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 CAL -188F FHLMC /KG 2 Liberty Avenue Carlisle, PA 17013 717- 249 -3166 and 800 - 990 -9108 3 CAL -188F FHLMC /KG Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886 -8790 Fax: 215-886-8791 Caliber Home Loans, Inc. f /k/a Vericrest IN THE COURT OF COMMON PLEAS Financial, Inc., CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO: V. CIVIL ACTION Daniel J Rasy 210 Roxbury Road MORTGAGE FORECLOSURE Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 1. Plaintiff, Caliber Home Loans, Inc. f /k/a Vericrest Financial, Inc., is a corporation, limited partnership, limited liability company, trust, federal savings bank, federal credit union, or national banking association under and pursuant to the National Banking Act 4 CAL -188F FHLMC /KG (13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 13801 Wireless Way, Oklahoma City, Ok 73134. 2. Defendants, Shannon T Rasy and Daniel J Rasy, are the real owners, mortgagors, and grantees in the last Deed of record to the real property located at 210 Roxbury Road Shippensburg, PA 17257 including any /all improvements and detached structures thereon as well as any /all riparian/water rights appertaining thereto (hereinafter collectively referred to as `Premises'] . 3. On August 19, 2005, Defendants made, executed, and delivered a Mortgage to Washington Mutual Bank, FA (hereinafter referred to as `Originating Lender'3 as security for Defendants' payment and other obligations in consideration of a mortgage loan made to Defendants by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, and was recorded on September 21, 2005 in Mortgage Book 1923, Page 4193, and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The mortgage has been assigned to the Plaintiff by two (2) Assignments of Mortgage, the first from Federal Deposit Insurance Corporation, as Receiver of Washington Mutual Bank f/k/a Washington Mutual Bank, FA to JPMorgan Chase Bank, N.A., recorded on November 29, 2012, Instrument No. 201236919; the second from JPMorgan Chase Bank, N.A. to Vericrest Financial, Inc., recorded on July 10, 2013, Instrument No. 201322723 and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 5. A true and correct copy of the Legal Description is attached hereto, made part hereof, and marked as Exhibit `A ". 6. The address of the Premises is 210 Roxbury Road, Shippensburg, PA 17257. 5 CAL-188F FHLMC/KG 7. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid Mortgage have not been made from October 1, 2012 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 8. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendants shall be liable for, inter alia, Plaintiffs costs, corporate advances, escrow advances, and attorneys' fees. 9. The following amounts are due as of November 15, 2013: Principal $ 72,069.76 Accrued Interest through November 15, 2013 $ 5,104.42 Late Fees $ 266.05 Property Inspections $ 99.00 Escrow Advances $ 4,528.25 Attorneys' Fees to date $ 3,603.49 Total $ 85,670.97 plus additional pre judgment and post - judgment interest at the per diem rate of $11.76 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, additional attorneys 'fees and court costs, and any /all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage. 10. If the Mortgage is reinstated prior to a sheriff % sale, the attorneys fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys "fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys 'fees of 6 CAL -188F FHLMC /KG up to five percent (5 %) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff 1 sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. 11. Notice of Intention to Foreclose pursuant to Act 6 and /or Act 91 was sent in accordance with Pennsylvania law more than 34 days ago. WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendants, Shannon T Rasy and Daniel J Rasy, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 9., namely $85,670.97, plus additional pre judgment and post judgment interest at the per diem rate of $11.76 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, additional attorneys 'fees and court costs, any /all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & ASSOCIATES LLC By: Richard M. ire, Esq. (PA I.D.# 04267) , evin P. Diskin, Esq. (PA I.D. # 86727) c/ Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215- 886 -8790 215- 886 -8791 (fax) rsquire@squirelaw.com kdi skinAsquirelaw. com c_ppenheimerAsquirelaw. com Attorneys for Plaintiff Date: A'ova�kw 7 CAL -188F FHLMC /KG UNLESS YOU NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE /PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 8 CAL -188F FHLMC /KG Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215- 886 -8791 Caliber Home Loans, Inc. f/k/a Vericrest IN THE COURT OF COMMON PLEAS Financial, Inc., CUMBERLAND COUNTY, PLAINTIFF, PENNSYLVANIA V. DOCKET NO: Daniel J Rasy CIVIL ACTION 210 Roxbury Road Shippensburg, PA 17257 MORTGAGE FORECLOSURE Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS VERIFICATION hereby states that he /she is employed as a Default Service Officer of Caliber Home Loans, Inc. f /k/a Vericrest Financial, Inc., Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Complaint are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Caliber Home Loans, Inc. f/k/a Ver'crest Financial, Inc. Name: rn� �iir au DATE: �` r J 3 Title: oe�1 ate \N se '('r 1 G ee Ov(i File #: CAL -188F FHLMC 9 CAL -188F FHLMC /KG Name: Shannon T Rasy and Daniel J Rasy 1 CAL -188F FHLMC /KG Exhibit `h" Legal Description ALL THAT CERTAIN WROVBD LOT OR GROUND SITUATE ON THE 'WEST SIDE OF THE ROXSURY ROAD IN THE BOROUGH OF SHIPPBNSBURG, cumsERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN IN THE CENTER OF A JOINT PRIVATE DRIVEWAY ADJACENT TO LAND NOW OR POPMBRLY OF BOYD L SINGISTER THENCE WITH THE SAID DRIVEWAY WESTWARDLY BY SAID LAN, ONE HUNDRED NINETY -THREE (193) F.EST TO LW OF LAND NOW OR FORMERLY OF THE SPRING ML CEMETERY ASSOCIATION; THENCE WII'H THE SAME NORTHWARDLY FORTY- TWO(42) FEET TO LINE OF LAND NOW OR FORMERLY OF CLIARLES RALL.ING. 7FIENCE BY SAID LAND ESTWARDLY ONE HUNDRED NINETY -THREE _(191)- FE=0_M MOMM AT THE ROXBURY ROAD; THENCE WfM'THE SAID ROXBURY ROAD SOUTHWARDLY FORTY -TWO (42) )FEET TO THE PLACE OF BEGM41NO. AND BB IIVIPROVED'WITH A FRAME SINGLE DWELLING HOUSE, TAX ID M. 34- 34 -24t7 -034 BY FEE SIMPLE DEED FROM WANDA S. RASY, UNMARRIED AS SET FORTH IN DEED BOOK. 265, PAQB 353 AND RECORDED ON 913/2004, CUMTjMdAND COUNTY RECORDS. THE SOURCE DEED AS STATED ABOVE IS THE LAST RECORD OF VESTING FILED FOR THIS PROPERTY, THERE HAVE BEEN NO VESTING CHANGES SINCE THE DATE OF THE ABOVE REFRRENCED SOURCE, Property Address: 210 Roxbury Road, Shippensburg, PA 17257 10 CAL -188F FHLMC /KG FORM 1 Caliber Home Loans, Inc. C. f /k /a Vericrest Financial, Inc. IN THE COURT OF COMMON PLEAS M CUMBERLAND COUNTY, PENNSYL, M PIaintiff(s) rn r� VS. -y N --i ✓ Daniel J. Rasy and ✓!� ¢ ;r �C r r ' . Shannon T. Rasy . � �� Defendant(s) Civil C__ �;. 7 x, NOTICE OF RESIDENTIAL MORTGAGE FORECLOStRE -1 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. Respec su fitted: Date [Signature of Cou ] for Plaintiff] FORM 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: lV1 3 RLN4ARY APPLI CANT CUSTONflll Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No F Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes E] No ❑ Mailing Address (if different): City: State: zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORINIA110N First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No n 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 #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): I . monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: I Monthly Expensesc (Please only include expenses you are currently paying) i EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mort a e Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med..not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child S ort/Alim. Spending Mone Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes © No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No R If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, ---, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation f(jr possible mortgage options. I[We understand that 1 /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and 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 FORM 3 Caliber Home Loans, Inc. ; IN THE COURT OF COMMON PLEAS OF f /k /a vericrest Financial, Inc. ; CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Daniel J. Rasy and Shannon T. Rasy Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated _ 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant. has been served with a "Notice of Residential Mortgage Foreclosure Diversion. Program" and `has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 1.8 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 Caliber Home Loans, Inc. f /k /a Vericrest Financial, Inc. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) CIVIIL ACTION VS. Daniel J. Rasy and NO Shannon T. Rasy Defendant(s) CASE MANAGEMENT ORDER AND NOW, this day of , 20 ; the defendant/borrower in the above - captioned. residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation. Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the'Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential. Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon. which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within. the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must i either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the a plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation. Conference, k the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiffllender at the rescheduled i Conciliation Conference. i i 4. At the Conciliation. Conference, the parties and their counsel. shall be prepared to discuss and explore all available resolution options which shall include: bringing the k ! mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; i agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; I i entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. 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 AN 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 OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET. CARLISLE, PA 17013 1- 800 - 990 -9108 717 - 249 -3166 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff cat CH/fiber!,� Jody S Smith Chief Deputy '; EC 1 7 Ati r: Richard W Stewart Solicitor " R L N €,w! r' 1 PENNSYLVANIA Caliber Home Loans, Inc. Case Number vs. Daniel J Rasy(et al.) 2013-6929 SHERIFF'S RETURN OF SERVICE 12/05/2013 06:06 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 handing a true copy to a person representing themselves to be Shannon Rasy, Wife,who accepted as"Adult Person in Charge"for Daniel J Rasy at 210 Roxbury Road, Shippensburg B.ro gh, Shippensburg, PA 17257. ID/4 ta S 7 r TSHA, DEPUTY 12/05/2013 06:06 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: Shannon Rasy at 210 Roxbury Road, Shippensburg Borough, Shippensb • P• 7257. Awirwr/ 1111r TSHAL T PUTY SHERIFF COST: $66.60 SO ANSWERS, December 06, 2013 RONNK ANDERSON, SHERIFF -,,s 0f. Richard M. Squire & Associates; LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Attorneys for Plaintiff Fax: 215-886-8791 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 2013-6929 CIVIL ACTION C) mm zrn MORTGAGE FORECLOSURE vzi -<)=. >c `--) >c DEFENDANTS. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Kindly issue a Writ of Execution in the above matter. Amount Due $ 89,093.13 Interest From 9/03/14 to 12/03/14 @ $11.76 per diem . 1070.16 Total: $ 90,163.29 * plus fees and costs Date: September 3, 2014 440Ze. so ?ci_ icALI 66. 1.c> Cas+ 163.75 „ `1 c2l5..3S '1 11 �( . sc.) kk cV- 3 V/ P— .3/61.88 CAL -188F FHLMC/DM1 By: Richard M. Squire, Esq. (`A I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) Morris Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin(a?,squirelaw. com mscott(a,squirelaw. com Attorneys for Plaintiff Docket No.2013-6929 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., Plaintiff, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 Defendants. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Filed: Richard M. Squire, Esquire Kevin Diskin, Esquire v• -"Morris Scott, Esquire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff ill0f/i 5 5(17,14 Attorney for Plaintiff CAL -188F FHLMC/DM1 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire ID. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff fL.ED -OFFCr ,• THE PRO T f�ONO^T/ 'I ?1714 SEP -5 AtiII:214 CUMBERLAND COUNTY PENNSYLVANIA Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 210 Roxbury Road, Shippensburg, PA 17257 Parcel No. 34-34-2417-034: 1. Name and last known address of Owner(s) or Reputed Owner(s): Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 2. Name and last known address of Defendant(s) in the judgment: Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 F:\Clients\Vericrest\Rasv-1 AAF FHLMC\Writ package 3-9-14.wpd 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. 13801 Wireless Way Oklahoma City, OK 73134 Portfolio Recovery Associates, LLC c/o Robert N. Polas, Jr. Esq. 140 Corporate Blvd Norfolk, VA 23502 Portfolio Recovery Associates, LLC c/o Carrie Brown, Esq. 120 Corporate Blvd Norfolk, VA 23502 4. Name and address of last recorded holder of every mortgage of record: Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. 13801 Wireless Way Oklahoma City, OK 73134 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. 3701 Regent Blvd., Ste 200 Irving, TX 75063 JPMorgan Chase Bank, NA 700 Kansas Lane MC 8000 Monroe, LA 71203 Washington Mutual Bank, FA 9451 Corbin Avenue Northridge, CA 91324 Washington Mutual Bank, FA 2273 N. Green Valley Pkw. Suite 14 Henderson NV 89014 5. Name and address of every other person who has any record lien on the property: None other. F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013-3014 Tax Claim Bureau One Courthouse Square, Room 106 Carlisle, PA 17013-3339 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn : Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 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: Tenant/Occupant 210 Roxbury Road Shippensburg, PA 17257 F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd Shannon Tenielle Rasy c/o Philip Charles Briganti, Esq. 74 West Pomfret Street Carlisle, PA 17013 VERIFICATION I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: Date: . September 3, 2014 F:\Clients\Vericrest\Rasy-] 88F FHLMC\Writ package 3-9-14.wpd Richard M. Squire, Esquire Kevin P. Diskin, Esquire V e Morris Scott, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. HE HOTHON° �. ?H f 4 SEP -5 Ail f) : 21; UNBERLAE4O COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION CERTIFICATION Richard M. Squire, Esquire/Kevin Diskin, Esquire/Morris Scott, Esquire, hereby verifies that he is an attorney for the Plaintiff in the above captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X ) An FHA Mortgage Non -owner occupied Vacant Act 91 Procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: September 3, 2014 By: Richard M. Squire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) Morris Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdi skin(squirel aw. com mscott(squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff '4__ of THE i'RO THO j? 2014 SEP —5 Al is 24 CtUMDEf?LAND .COUNTY PENNSYLVANIA Caliber Home Loans, Inc. f/k/a Vericrest IN THE COURT OF COMMON PLEAS Financial, Inc. CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. Date: September 1, 2014 DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE To: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF' SALE OF REAL PROPERTY OWNER(S): Shannon T Rasy and Daniel J Rasy PROPERTY: 210 Roxbury Road Shippensburg, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff Sale December 3, 2014 at 10:00 A.M., Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on 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 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. ;-. uFFICL 2014 SEP -5 AH11:21.1 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION AFFIDAVIT OF LAST KNOWN ADDRESSES I, Richard M. Squire, Esquire/Kevin Diskin, Esquire/Morris Scott, Esquire, being duly sworn according to law, hereby depose and say that I am one of the attorneys for Plaintiff in the above matter and that the last known address for the Defendants herein is as follows: Defendants: Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 Date: September 3, 2014 F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd By: Richard M. quire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) Morris Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff LF THE P ROTKC diJT,*: 2011i SEP —5 AM H : 24 CUMBERLAND COUNTY PENNSYLVANIA Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE Richard M. Squire, Esquire/Kevin Diskin, Esquire/Morris Scott, Esquire, hereby verifies that he is one of the attorneys for the Plaintiff in the above -captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 2003, as amended. (b) that Defendants are over 18 years of age and reside at 210 Roxbury Road, Shippensburg, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: September 3, 2014 F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd By: Richard M. Squire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) Morris Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff r ILE[)- OF IC, THE PROTHONOTARY oh SEP —S fall I1: 2t, CUMBERLAND COUNTY PENNSYLVANIA Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Your house (real estate) at 210 Roxbury Road, Shippensburg, PA 17257 is scheduled to be sold at Cumberland County Sheriff Sale, December 3, 2014at 10:00 A.M., Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $ 89,093.13 plus interest to the sale date obtained by Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. 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 back to Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, Kevin P. Diskin, or Morris Scott, Esquire at (215) 886-8790. F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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. 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 the Cumberland Sheriffs Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Clients\Vericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Puf brii."4.t7 tict. s a-/ y . Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO, 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 • Your house (real estate) at 210 Roxbury Road, Shippensburg, PA 17257 is scheduled to be sold at Cumberland County Sheriff Sale, December 3, 2014 at 10:00 A.M., Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $ 89,093.13 plus interest to the sale date obtained by Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. 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 back to Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, Kevin P. Diskin, or Moms Scott, Esquire at (215) 886-8790. F:ClientsWericrestaasy-1 88F FHLMC \Writ package 3-9-14.wpd 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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. 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 the Cumberland Sheriffs Office at 717-240-6100. 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. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAClientsWericrest\Rasy-188F FHLMC\Writ package 3-9-14.wpd LEGAL DESCRIPTION ALL THAT CERTAIN improved lot or ground situate on the west side of the Roxbury Road in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin in the center of a joint private driveway adjacent to land now or formerly of Boyd L. Singister thence with the said driveway westwardly by said land, one hundred ninety-three (193) feet to line of land now or formerly of the Spring Hill Cemetery Association; thence with the same northwardly forty-two (42) feet to line of land now or formerly of Charles Railing: Thence by said land eastwardly one hundred ninety-three (193) feet to an iron pin at the Roxbury Road; thence with the said Roxbury Road southwardly forty-two (42) feet to the place of beginning and being improved with a frame single dwelling house. Known as 210 Roxbury Road, Shippensburg, PA 17257 Parcel No. 34-34-2417-034 Being the same premises which Wanda S. Rasy granted and conveyed unto Daniel J. Rasy and Shannon T. Rasy by Deed dated August 27, 2004 and recorded September 3, 2004 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 265, Page 353. FAClientsWericrestaasy-188F FI-ILMC\ Writ package 3-9-14.wpd THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net CALIBER HOME LOANS, INC. F/K/A VERICREST FINANCIAL, INC. Vs. NO 13-6929 Civil Term CIVIL ACTION — LAW DANIEL J. RASY SHANNON T. RASY WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $89,093.13 L.L.: $.50 Interest FROM 9/3/14 TO 12/3/14 @ $11.76 PER DIEM - $1070.16. Atty's Comm: Due Prothy: $2.25 Atty Paid: $215.35 Other Costs: Plaintiff Paid: Date: 9/5/14 Did D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MORRIS SCOTT, ESQ. Address: RICHARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 Attorney for: Plaintiff Telephone: 215-886-8790 Supreme Court ID No. 83587 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Shannon T Rasy and Daniel J Rasy, Defendants, for their failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiffs damages as follows: As set forth in the Complaint Interest from 11/16/2013 to 9/3/14 Total $ 85,670.97 $ 3,422.16 $ 89,093.13 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. fr/1..:o PclAily ex4 231.1-0 R4 3,c87 Mo -it n2.11fra:(., RICHARD M. S IRE & S i CIATES, LLC By: Ric d . quire, sq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D. # 86727) Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquireasquirelaw.com kdi skin(cr�,squirel aw. com mscotta,squirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 3 PROTHONOTARY Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Moths A. Scott, Esquire ID. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2013-6929 CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys for the Plaintiff in the above -captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) address at 210 Roxbury Road, Shippensburg, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richard . Squire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D. # 86727) V Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff 4 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act. Last Name: RASY First Name: DANIEL Middle Name: J Active Duty Status As Of: Sep -03-2014 Results as of : Sep -03-2014 08:08:51 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA L ` . = -- -- — —. No'. NA This response refledsthe Ind'Mduels;-active duty statushased on the Active'Duty Status Date Lea Active Duty Within 367 Days 01 Active Duly Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA '- -�' _ .. NA This response reflects where the Individual lea active duty status wt hln 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 Ni.- r,rNo it; 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. 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 Soldiersand 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/PCO9SLDR.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(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: PC4FCBBFZ02ELOO Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: RASY First Name: SHANNON Middle Name: T Active Duty Status As Of: Sep -03-2014 Results as of : Sep -03.2014 08:10:59 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA ../ - _ — No NA This response refect the Individuals' active duty status based or.; the Attire Dut}+ Status Date Left Active Duty Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA ±. NA .— _ -..� . _ No-^" 5' I NA This response reflects where the Individual left active duty status vdthln 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 t• NA '`1 ' •• �' :No%/ ! NA This response reflects whether the Individual or his/her unit has received earty notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: SC51ABBFP030740 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 86727 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. TO: Daniel J Rasy 210 Roxbury Road Shippensburg PA 17257 DATE OF NOTICE: August 21. 2014 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 86727 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. TO: Shannon T Rasy 210 Roxbury Road Shippensburg PA 17257 DATE OF NOTICE: August 21, 2014 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Caliber Home Loans, Inc. f/lcia Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on Wspy , a judgment(decree)(order) was entered against you in this office in the ijoceecIing as indicated above. Deputy Prothonotary Date Mailed: 91/S -Ar' 5 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on 9/S7/Se , a judgment(decree)(order) was entered against you in this f office in the p eedi as incia ed above. • Deputy Prothonotary Date Mailed: 6 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Robert Cusick, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 PLAINTIFF, DEFENDANTS. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DOCKET NO: 2013-6929 NOTICE OF POSTPONEMENT OF SHERIFF'S SALE TO: PROTHONOTARY OF CUMBERLAND COUNTY 1 Courthouse Square Carlisle PA 17013-3387 The real property located at 210 Roxbury Road, Shippensburg, PA 17257 previously scheduled to be sold at Sheriffs Sale on December 3, 2014 at 10:00 A.M. Cumberland County Courthouse, 1 Courthouse Square , Carlisle, PA 17013 HAS BEEN POSTPONED TO March 4, 2015 By: Date: November 7, 2014 Richard M. Squire, Esquire Robert Cusick, Esquire 'Morris Scott, Esquire Attorneys for Plaintiff, Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert Cusick, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue < Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, PLAINTIFF, DEFENDANTS. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW DOCKET NO: 2013-6929 CERTIFICATION OF SERVICE I, Morris Scott , Esquire being counsel for Plaintiff, Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., in the above -captioned matter, do hereby certify that I caused a true and correct copy of NOTICE OF POSTPONEMENT OF SHERIFF'S SALE to be served upon the Sheriff of Cumberland County and on the following individuals, by first-class mail, postage pre -paid: SHERIFF OF CUMBERLAND COUNTY 1 Courthouse Square Carlisle PA 17013-3387 Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 By: Date: November 7, 2014 Richard M. Squire, Esquire Robert Cusick, Esquire Morris Scott, Esquire Attorneys for Plaintiff, Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. -2- Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE PLAINTIFF'S MOTION FOR ALTERNATIVE SERVICE OF THE NOTICES OF SHERIFF'S SALE AND NOW, comes Plaintiff, Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., by its undersigned attorney and moves this Honorable Court for an Order permitting alternative service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 210 Roxbury Road, Shippensburg, PA 17257; and (2) posting a true and correct copy thereof on the mortgaged premises at 210 Roxbury Road, Shippensburg, PA 17257 by any competent adult. In support thereof, Plaintiff avers the following: 1. The Defendants could not be served with the Notices of Sheriff's Sale at the mortgaged premises. A true and correct copy of the Return of Service is attached hereto as Exhibit "A" and made a part hereof. 2. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to locate Defendants. An Affidavit of Good Faith Investigation, which sets forth the specific inquiries made and the results thereof, is attached hereto as Exhibit "B" and made a part hereof.' Notably, the Affidavit of Good Faith Investigation does not reflect any other possible current addresses for Defendants. See Ex. "B." 3. A Request for Change of Address or Boxholder [hereinafter referred to as "Request"], pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Cumberland, Pennsylvania Postmaster indicates that Defendants received mail at the mortgaged premises as of the date thereof A true and correct copy thereof is attached hereto as Exhibit "C" and made a part hereof. 4. Despite Plaintiffs good faith efforts to locate Defendants, it appears more likely than not that he/she/they is/are avoiding and/or evading service of the Notices of Sheriff's Sale. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 210 'Social security numbers and dates of birth have been omitted in observance of federal privacy laws. Roxbury Road, Shippensburg, PA 17257; and (2) posting a true and correct copy thereof on the mortgaged premises at 210 Roxbury Road, Shippensburg, PA 17257 by any competent adult. Dated: November 11, 2014 Respectfully submitted, RICHARD M. SQUIRE & ASSO IATES, LLC By: Richard M. Squire, Esq. (PA LD.# 04267) Kevin P. Diskin, Esq. (PA LD. # 86727) Morris A. Scott, Esq. (PA LD.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.corn kdiskin@squirelaw.com mscott@squirelaw.corn Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION I, Morris Scott, Esquire, hereby state that I am one of the attorneys for Plaintiff, a corporation unless designated otherwise; that I am authorized to make this Verification; that I have personal knowledge of the facts averred in the foregoing Motion; and that the statements made in the foregoing Motion are true and correct to the best of my knowledge, information and belief The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. RICHARD M. SQUIRE & ASSOCIAT , LLC Dated: By: Richard M. Squire, Esq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Morris A. Scott, Esq. (PA I.D.# 83587) Attorneys for Plaintiff Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Morris Scott, Esquire, hereby certify that, on this date, I served or caused to be served a true and correct copy of the foregoing Plaintiff's Motion for Alternative Service of the Notice of Sheriff's Sale, Brief/Memorandum of Law, Verification, and proposed form of Order upon the following person via regular mail, postage prepaid: Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Dated: November 1 , 2014 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, RICHARD M. SQUIRE & ASSOCIATE LLC By: Ri and " quire, Esq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc., PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257, part: DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE BRIEF/MEMORANDUM OF LAW With respect to service of a Notice of Sheriff's Sale, Pa. R.C.P. 3129.2(c) provides, in pertinent (c) The [Notice of Sheriff's Sale] shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the [Notice of Sheriff's Sale] shall be made (i) upon a defendant in the judgment who has not entered an appearance and upon the owner of the property. (A) by the sheriff or by a competent adult who is not a party to the action in the manner prescribed by Rule 402(a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court; and [...] Pa. R.C.P. 430(a) provides, in pertinent part: (a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of defendant and the reasons why service cannot be made. Official Note A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As reflected on the attached Return of Service, Plaintiff's multiple attempts to have Defendants served with the Notices of Sheriffs Sale, in accordance with Pa. R.C.P. 3129.2(c)(1)(i)(A), have been unsuccessful. See Ex. "A." A Request for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Shippensburg, Pennsylvania Postmaster indicate that Defendants received mail at the mortgaged premises as of the date thereof. See Ex. "C." Good faith efforts to discover the whereabouts of Defendants have been made, as evidenced by the numerous inquiries set forth in the attached Affidavit of Good Faith Investigation. See Ex. "B." In particular, inquiries have been made to the following persons and entities: 1. Directory Assistance, White Pages, and On -Line Telephone Records; 2. County Tax Assessment; 3. Federal Aviation Administration; 4. United States Drug Enforcement Administration; 5. Pennsylvania Department of State -Uniform Commercial Code filings; and 6. Pennsylvania Department of Corrections. See id. Also searched were United States Bankruptcy Court records, sexual offenders database, nationwide professional licenses, federal firearms and explosives licenses, and civil proceedings filed in the Commonwealth of Pennsylvania. See id. Notably, the Affidavit of Good Faith Investigation does not reflect any other possible current addresses for Defendants. See id. Based on the foregoing, it is more likely than not that Defendant(s) is/are avoiding and/or evading service of process. For all of the foregoing reasons, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 210 Roxbury Road, Shippensburg, PA 17257; and (2) posting a true and correct copy thereof on the mortgaged premises at 210 Roxbury Road, Shippensburg, PA 17257 by any competent adult. Dated: November 11, 2014 Respectfully submitted, RICHARD M. SQ RE & AS O ,- TES, LLC i2/ d I -//:* By: -4" i% . Richard M. Squire, sq. (PA I.D.# 04267) / Kevin P. Diskin, Esq. (PA I.D. # 86727) V Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. PLAINTIFF, v. Daniel J Rasy 210 Roxbury Road Shippensburg, PA 17257 Shannon T Rasy 210 Roxbury Road Shippensburg, PA 17257 DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM NO: 2013-6929 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF PRESENTATION Kindly take notice that the Plaintiff's Motion for Alternative Service of the Notices of Sheriffs Sale will be presented to Motions Court/Judge, Courtroom , CUMBERLAND County Court of Common Pleas, 1 Courthouse Square, Carlisle, PAA 17013-3387 on , 20_ at m or as soon thereafter as counsel (or local counsel) may be heard. Richard M. Squire & Associ. es, C Dated: By: . quire, Esq. PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) s u" e • sluirelaw.com kdiskin • ssuire aw.com mscott 0 souire aw.com Attorneys for Plaintiff Exhibit "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart '4,4; Solicitor Orttee Of THE WERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY 10-9 01 atinztert Caliber Home LoansInc. vs. Daniel J Rasy (et al.) Case Number 2013-6929 SHERIFF'S RETURN OF SERVICE 09/30/2014 01:48 PM Deputy Dennis Frybeing dly sworn accordinto law, states service was performedhy posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled achon, upon the property located at 210 Roxbury Road, Shippensburg - Borough, Shippensburg, PA 17257, Cumberland County. 10/88/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Daniel J. Rasy, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 210 Roxbury Road, Shippensburg, PA, property is Vacant, defendant did not leave a forwarding address with the Post Office. cab. 10/09/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Shannon Rasy, but was unable to locate the Defendant in his bailiwick, He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 210 Roxbury Road, Shippensburg, PA, property is Vacant, defendant did not leave a forwarding address with the Post Office. cab. SHERIFF COST: $976.24 SO ANSWERS, October 09, 2014 RON R ANDERSON, SHERIFF Exhibit "B": Affidavit of Good Faith Investigation AFFIDAVIT OF GOOD FAITH INVESTIGATION Commonwealth of Pennsylvania County of Montgomery SS: I, Rosemary McGrory Sweet, an Owner of Rosemary McGrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSE THE FOLLOWING: 1) I HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: DANIEL) RASY JR DOB:9/21/1980 2. THE PROPERTY ADDRESS IS 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPORT IS BELIEVED TO: "1 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY (Jun 1991 -Oct 2013) Name Associated with Address: DAN RASY Current Residents at Address: SHANNON TENIELLE LEGGETT DANIEL! RASY JR 717-532-6103- EDT RASY DAN 3. DIRECTORY ASSISTANCE, WHITE PAGES, AND OTHER ON-LINE TELEPHONE RECORDS '!210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY (Jun 1991 - Oct 2013) Name Associated with Address: DAN RASY Current Residents at Address: SHANNON TENIELLE LEGGETT DANIEL! RASY JR 717-532-6103 - EDT RASY DAN 4. ADDRESS HISTORY SEARCH Address Summary: ica '11210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY (Jun 1991 - Oct 2013) 802 E POPLAR ST APT, MC CONNELLSBURG PA 17233-1209, FULTON COUNTY (Mar 2011) 13454 MONGUL RD, NEWBURG PA 17240-9615, FRANKLIN COUNTY (Mar 2000 - Mar 2011) 13134 PEN MAR RD APT 1, WAYNESBORO PA 17268-8785, FRANKLIN COUNTY (Jan 2003 - Apr 2004) RR 16 BOX 12993, BLUE RIDGE SUMMIT PA 17214, FRANKLIN COUNTY (Feb 2002) 210 ROCKS BERRY RD, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Sep 1998) 21 ROXBURY RD, SHIPPENSBURG PA 17257-1114, CUMBERLAND COUNTY 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: mai Property: Parcel Number- 34-34-2417-034 Book -265 Page - 353 Owner Name: DANIEL J RASY Owner Name 2: SHANNON T RASY Property Address: - 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Land Usage - RESIDENTIAL (NEC) Total Market Value -$137,500 Assessed Value - $137,500 Land Value - $27,200 Improvement Value - $110,300 Land Size -8,276 Square Feet Year Built -1900 Legal Description - LAND LESS THAN 1 ACRE Data Source - A Property: Parcel Number - 34-2417-0034-0000000-34 Book -265 Page - 353 Owner Name: DANIEL) RASY Owner Name 2: SHANNON T RASY Property Address: - 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Land Usage - RESIDENTIAL (NEC) Total Market Value - $137,500 Assessed Value - $137,500 Land Value - $27,200 Improvement Value - $110,300 Land Size - 8,276 Square Feet Year Built -1900 Legal Description - LAND LESS THAN 1 ACRE Data Source - A Property: Parcel Number - 34-2417-034 Book -265 Page - 353 Owner Name: DANIEL J RASY Owner Name 2: SHANNON T RASY Property Address - 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Seller Name: RECORD OWNER Data Source - A 6. UNIFORM COMMERCIAL CODE FILINGS UCC Filings: Original Filing Number: 2005042101791 Original Date: Apr 20, 2005 Filing Agency: SECRETARY OF STATE/UCC DIVISION Filing Agency Address: 308 NORTH OFFICE BUILDING, HARRISBURG PA 17120 Filing State: PA Debtor(s): Debtor Name: DANIEL I RASY Debtor Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124 Secured(s): Secured Name: NMTC INC D/B/A MATCO TOOLS Secured Address: 4403 ALLEN RD, STOW OH 44224-1033 Filing(s): Filing Type: CONTINUATION Filing Number: 2009111901004 Filing Status: Date Filed: Nov 18, 2009 Filing Expiration Date: 4/20/2015 Filing Type: INITIAL FILING Filing Number: 2005042101791 Filing Status: Date Filed: Apr 20, 2005 Filing Expiration Date: 4/20/2010 7. FEDERAL BANKRUPTCY COURT NO RECORD FOUND 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS NO RECORD FOUND 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS- PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND 13. PROFESSIONAL LICENSES (NATIONWIDE) NO RECORD FOUND 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATIONWIDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16 CORPORATIONS AND BUSINESS ' AND POSSIBLE EMPLOYERS People at Work: Maximum 50 People at Work records returned Name: DANIEL .1 RASY Title: PRIN Company: DANIEL 1 RASY Address: SHIPPENSBURG PA Dates: Dec 15, 2008 - Nov 4, 2012 17 OTHER INFORMATION NO RECORD FOUND 3) I DECLARE THAT THE FOREGOING IS TRUE AND CORRECT. October 22, 2013 SIGNATURE: SWORN TO AND SUBSCRIBED BEFORE ME THIS 22nd Day of October, 2013 NOTARY PUBLIC COMMONWEALTH OFPENNSYLVANIA NOTARIAL SEAL. My Commission Expires June 13, 2016 PATRICIA TARDITI, Notary Public City of Philadelphia, Phila. County AFFIDAVIT OF GOOD FAITH INVESTIGATION Commonwealth of Pennsylvania County of Montgomery SS: I, Rosemary McGrory Sweet, an Owner of Rosemary McGrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSE THE FOLLOWING: 1) I HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: SHANNON T RASY AKA SHANNON TENIELLE LEGGETT DOB:5/6/1977 2. THE PROPERTY ADDRESS IS 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPORT IS BELIEVED TO: '1210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY (Jun 1991 -Sep 2013) Name Associated with Address: SHANNON T RASY Current Residents at Address: SHANNON TENIELLE LEGGETT DANIELJ RASYJR 717-532-6103 - EDT RASY DAN 3. DIRECTORY ASSISTANCE, WHITE PAGES, AND OTHER ON-LINE TELEPHONE RECORDS Phones Plus(s): ism Phones Plus 1 Name: RASY, SHANNON Address: 210 ROXBURY R0, SHIPPENSBURG PA 17257-1124 Phone Number: 717-377-6825 - EDT Phone Type: Mobile Carrier: VERIZON WIRELESS -PA -( CHAMBERSBURG, PA ) Phones Plus 2 Name: RASY, SHANNON Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124 Phone Number: 717-552-5896 - EDT Phone Type: Mobile Carrier: SPRINT SPECTRUM LP-( CHAMBERSBURG , PA) Phones Plus 3 Name: LEGGETT, SHANNON Address: PO BOX 25, BLUE RIDGE SM PA 17214-0025 Phone Number: 717-765-8729 - EDT Carrier: CENTURYLINK - ( WAYNESBORO, PA ) 4. ADDRESS HISTORY SEARCH Address Summary: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY (Jun 1991 -Sep 2013) 802 E POPLAR ST APT, MC CONNELLSBURG PA 17233-1209, FULTON COUNTY (Mar 2011) PO BOX 25, BLUE RIDGE SUMMIT PA 17214-0025, FRANKLIN COUNTY (Sep 1997 -Dec 2008) 11863 OLD ROUTE 16 ST, WAYNESBORO PA 17268-9398, FRANKLIN COUNTY (Jul 2007) PO BOX 25, GLENVIEW KY 40025-0025, JEFFERSON COUNTY (Nov 1999 -Jun 2004) 13134 PEN MAR RD APT 1, WAYNESBORO PA 17268-8785, FRANKLIN COUNTY (Feb 2003) 606 RIDGE ST, ALBEMARLE NC 28001-3012, STANLY COUNTY (Sep 2000 -Jan 2001) 11 N CHURCH ST APT 25, WAYNESBORO PA 17268-1219, FRANKLIN COUNTY (Jun 2000 - Jan 2001) 11 S CHURCH ST APT 25, WAYNESBORO PA 17268-1539, FRANKLIN COUNTY (May 2000 - Aug 2000) 11 S CHURCH ST APT, WAYNESBORO PA 17268-1539, FRANKLIN COUNTY (May 2000 - Aug 2000) RR 16 BOX 12993, BLUE RIDGE SUMMIT PA 17214, FRANKLIN COUNTY (Feb 1999 - Dec 1999) 11 N CHURCH ST, WAYNESBORO PA 17268-1219, FRANKLIN COUNTY (Sep 1999) 12993 OLD RT 16, BLUE RIDGE SUMMIT PA 17214, FRANKLIN COUNTY (Jan 1999) 25467 MILAN RD, CASCADE MD 21719, WASHINGTON COUNTY (May 1996 -Jan 1999) 15515 JACOBS APT Al, BLUE RIDGE SM PA 17214, FRANKLIN COUNTY (Jun 1998 - Aug 1998) 14, CASCADE MD 21719, WASHINGTON COUNTY (Aug 1995 -Aug 1998) PO BOX 14, CASCADE MD 21719-0014, WASHINGTON COUNTY (Jul 1995 -Jan 1997) 550 MILITARY RD, CASCADE MD 21719, WASHINGTON COUNTY (May 1995) 11 NRTH CHURCH STRT APT 25, WAYNESBORO PA 17268, FRANKLIN COUNTY (May 1995) 17676 MILITARY RD, CASCADE MD 21719, WASHINGTON COUNTY 12993 OLD 16, BLUE RIDGE SUMMIT PA 17214, FRANKLIN COUNTY 11 NRTH CHURCH STRT 25, WAYNESBORO PA 17268, FRANKLIN COUNTY 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: Property: Parcel Number - 34-34-2417-034 Book - 265 Page -353 Owner Name: SHANNON T RASY Owner Name 2: DANIEL I RASY Property Address: - 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Land Usage- RESIDENTIAL (NEC) Total Market Value - $137,500 Assessed Value - $137,500 Land Value - $27,200 Improvement Value - $110,300 Land Size - 8,276 Square Feet Year Built -1900 Legal Description - LAND LESS THAN 1 ACRE Data Source - A Property: Parcel Number- 34-2417-0034-0000000-34 Book -265 Page - 353 Owner Name: SHANNON T RASY Owner Name 2: DANIEL 1 RASY Property Address: -210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Land Usage - RESIDENTIAL (NEC) Total Market Value -$137,500 Assessed Value - $137,500 Land Value- $27,200 Improvement Value - $110,300 Land Size - 8,276 Square Feet Year Built - 1900 Legal Description - LAND LESS THAN 1 ACRE Data Source - A Property: Parcel Number- 34-2417-034 Book - 265 Page -353 Owner Name: SHANNON T RASY Owner Name 2: DANIELJ RASY Property Address - 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Owner Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY Seller Name: RECORD OWNER Data Source - A 6. UNIFORM COMMERCIAL CODE FILINGS NO RECORD FOUND 7. FEDERAL BANKRUPTCY COURT NO RECORD FOUND 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS NO RECORD FOUND 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS - PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND 13 PROFESSIONAL LICENSES (NATIONWIDE) Professional License(s): Professional License 1 Name: RASY, SHANNON TENIELLE License Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY License State: Pennsylvania License Number: PN275861 License Type: LICENSED PRACTICAL NURSE Profession/Board: NURSING License Status: ACTIVE Issue Date: Mar 21, 2007 Expiration Date: Jun 30, 2010 Professional License 2 Name: RASY, SHANNON TENIELLE License Address: 210 ROXBURY RD, SHIPPENSBURG PA 17257-1124, CUMBERLAND COUNTY License State: Pennsylvania License Number: PN275861 License Type: PRACTICAL NURSE Profession/Board: NURSING License Status: ACTIVE Issue Date: Mar 21, 2007 Expiration Date: Jun 30, 2008 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATIONWIDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16. CORPORATIONS AND BUSINESS `AND POSSIBLE EMPLOYERS NO RECORD FOUND 17. OTHER INFORMATION NO RECORD FOUND 3) I DECLARE THAT THE FOREGOING IS TRUE AND CORRECT. October 22, 2013 SIGNATURE: SWORN TO AND SUBSCRIBED BEFORE ME THIS 22nd Day of October, 2013 NOTARY PUBLIC 3CLI-11-1--z.4---, 4`,/a -4 -,e4 -4 -11 -"- COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL PATRICIA TARD1TI, Notary Public. City of Philadelphia, Phila. County My Commission Expires June 13, 2016 Exhibi “Cl RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard M. Squire * Kevin P. Diskin A Craig A. Oppenheimer Also Admitted in Ml) ^ Also Admitted in NJ Postmaster Shippensburg, PA 17257 Dear Madam or Sir: Montgomery County Office One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com October 22, 2013 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Shannon T Rasy Address: 210 Roxbury Road, Shippensburg, PA 17257 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. v. Shannon T Rasy and Daniel J Rasy 4. The court in which the case has been or will be heard: Cumberland County Court of Common Pleas, Pennsylvania 5. The docket or other identifying number if one has been issued: Not yet issued 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC By: Ric and M. Squire, Esquire FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. Still receives mail at address given NEW ADDRESS or BOXHOLDER'S POSTMARK NAME and STREET ADDRESS CAL -188F / KG RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard M. Squire * Kevin P. Diskin A Craig A. Oppenheimer Also Admitted in MD * Also Admitted et NJ Montgomery County Office One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com October 22, 2013 Postmaster Shippensburg, PA 17257 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Dear Madam or Sir: Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Daniel J Rasy Address: 210 Roxbury Road, Shippensburg, PA 17257 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Caliber Home Loans, Inc. f/k/a Vericrest Financial, Inc. v. Shannon T Rasy and Daniel J Rasy 4. The court in which the case has been or will be heard: Cumberland County Court of Common Pleas, Pennsylvania 5. The docket or other identifying number if one has been issued: Not yet issued 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). i certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire /kC FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. Still receives mail at address given NEW ADDRESS or BOXHOLDER'S POSTMARK NAME and STREET ADDRESS CAL -188F / KG CALIBER HOME LOANS, INC. f/k/a VERICREST FINANCIAL INC., Plaintiff v. DANIEL J RASY and SHANNON T RASY, Defendants Countp:of dumberianb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 13- 44-6929 CIVIL ACTION IN RE: MOTION FOR ALTERNATIVE SERVICE OF THE NOTICES OF SHERIFF'S SALE 0\42. AND NOW, this 18' day of December 2014, upon consideration of the Motion ORDER OF COURT for Alternative Service of the Notices of Sheriffs Sale, and in reliance with the Good Faith Affidavit included therein, the Petition is GRANTED. Following Petitioner's described efforts to locate and serve the Defendants, Petitioner SHALL effectuate service upon Defendants by posting at a conspicuous location at the premises, 210 Roxbury Road, Shippensburg, Pennsylvania 17257 and by certified return receipt and regular mail to the same address. All further service of legal papers may be made in the same manner. Service of the aforementioned Sheriffs Sale Notices will be effective upon the date of mailing. Proof of Service SHALL be filed with the Prothonotary's Office by Plaintiff. Thoma > . Placey Distribution: LAaorris A. Scott, Esq. Daniel J. Rasy Shannon T. Rasy � JoZ.l/I l /