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HomeMy WebLinkAbout05-0627 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) S63-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. oS - 1&,;2.7 elU~ l~1 v. CUMBERLAND COUNTY SUSAN A. HANFT 7 HIDDEN MEADOWS DRIVE CARLISLE, PA 17013 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the 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 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 109161 File #: 10916\ IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. I. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: GREENPOINT MORTGAGE CORPORATION 2300 BROOKSTONE CTR PKWY COLUMBUS, GA 31904 2. The name(s) and last known addressees) of the Defendant(s) are: SUSAN A. HANFT 7 HIDDEN MEADOWS DRIVE CARLISLE, P A 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 02/10/2004 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office ofthe Recorder of CUMBERLAND County, in Mortgage Book: 1854, Page: 1033. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2004 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 109161 6. The following amounts are due on the mortgage: Principal Balance Interest 08/01/2004 through 02/02/2005 (Per Diem $83.0 I) Attorney's Fees Cumulative Late Charges 02/10/2004 to 02/02/2005 Cost of Suit and Title Search Subtotal $403,982.79 15,439.86 1,250.00 425.82 $ 550.00 $ 421,648.47 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $ 421,648.47 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant( s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 10. Plaintiff hereby releases MICHAEL J. HANFT from liability for the debt secured by the mortgage. II. By virtue of the death of MICHAEL J. HANFT on or about 8/2004, SUSAN A. HANFT became sole owner of the mortgaged premises as surviving tenant by the entireties. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 421.648.47, together with interest from 02/02/2005 at the rate of$83.01 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP ~~~ By: IsIFrancis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File#: 109161 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in Dickinson Township, Cumberland County, Pennsylvania, bounded'and described in accordance with the land Subdivision for Hidden Meadows prepared by Carl Bert and Associates, professional land surveyor, dated November 8, 1999 and recorded in the hereinafter Recorder's Office in Plan Book 82, Page 58 as follows: BEGINNING at an iron pin the western right-of-way line of 60 feet wide Hidden Meadows Drive at the dividing line between Lots Nos. 6 and 7; thence along the western right-of-way line of60 feet wide Hidden Meadows Drive, by a curve to the right having a radius of 40.00 feet an arc distance of38.87 feet to an iron pin; thence by same by a curve to the left having a radius of 60.00 feet an arc distance of91.16 feet to an iron pin at the dividing line between Lots Nos. 6 and 12: thence along the dividing line between Lots Nos. 6 and 12, South 09 degrees 00 minutes 25 seconds West a distance of 126.69 feet to an iron pin; thence by same South 31 degrees 36 minutes 03 seconds East a distance of275.45 feet to a concrete monument in the dividing line between Lots Nos. Sand 6 at the southwest corner of Lot No. 12; thence along the dividing line between Lots Nos. 5 and 6, South 47 degrees 06 minutes 25 seconds West a distance of 611.98 feet to a concrete monument in the dividing line between Lots. Nos. 4 and 6; thence along said dividing line between Lots Nos. 4 and 6, North 39 degrees 07 minutes 05 seconds West a distance of211.48 feet to an iron pin at the southeast comer of Lot No.2; thence along the dividing line between Lot Nos. 2 and 6, North 41 degrees 49 minutes 42 seconds West a distance of 158.41 feet to an iron pin in the dividing line between Lots Nos. 6 and 7; thence along the dividing line between Lots Nos. 6 and 7, North 39 degrees 59 minutes 58 seconds East a distance of775.98 feet to an iron pin in the western right-of-way line of 60 feet wide Hidden Meadows Drive, the Place of BEGINNING. BEING all of Lot No.6 as shown on the Land Subdivision for Hidden Meadows recorded in Plan Book 82, Page 58 and containing 6.32992 acres. BEING a portion of the same premises which Julia P. Kinnard, by Deed dated January 24,1963 and recorded January 24, 1963 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book 'T', Volume 20, Page 154, granted and conveyed to Wallace Hobbie and Helen T. Hobbie, his wife, The said Wallace Hobbie having died title to the same remained vested in Helen T. Hobbie, his wife by operation oflaw, Robert G. Frey and Debra L. Frey, husband and wife, join in the conveyance of the within described tract to convey all of their right, title and interest in the premises by virtue of an Installment Sales Agreement between them and Helen Hobbie dated August 28, 1998 and recorded August 28,1998 in the above mentioned Recorder's Office in Miscellaneous Record Book 586, Page 1113. UNDER AND SUBJECT, nevertheless, to building and use restrictions, easements and construction notes as set forth in the abovementioned Land Subdivision for Hidden Meadows and as set forth on the Land Subdivision Plan for Helen T. Hobbie dated February 18, 1994 and recorded in the abovementioned recorder's Office in Plan Book 70, Page 3. FURTHER under and subject, nevertheless, to the Declaration of Building and Use Restrictions dated November , 200 I and recorded , 200 I in Miscellaneous Record Book , Page Being NO.7 Hidden Meadows Drive File #: 109161 . . VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifications to authorities. ~41~ ;;;~ Francis S. Hallinan, Esquire Attorney for Plaintiff DATE:#- 2-0-5 0 ~ ((;) "P v-, ~ v, ~ r-> V< C::',:), .:..,r'I .l::. 0 --n rq -- C> ~ ,;.J .... D - \ ..r::.. ~,.) ).J ..c::. ~ 1 !::: ~ e -"" ..J) c..J' \j',) SHERIFF'S RETURN - REGULAR CASE NO: 2005-00627 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HANFT SUSAN A JODY SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HANFT SUSAN A the DEFENDANT , at 1500:00 HOURS, on the lOth day of Februar 2005 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to SUSAN HANFT a true and attested copy of COMPLAINT - MORT FORE togethe with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 .00 .00 10.00 .00 28.00 ~~.~""""~(f-:/ _?"~~ ,,:t,;:/~~':'\.5;'~of,'~,:" /../-;:<" ~,:;,'" ._J~;::::""" . /7".~''''.t:.''''''''-~ R. Thomas Kline 02/10/2005 PHELAN HALLINAN SCHMIEG me this day of D Sworn and Subscribed to before By: A.D. --t ~~u PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney 1.0. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION SUSAN A. HANFT NO. 05-627 CIVIL TERM Defendant MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, LLP, petitions this Honorable Court tpr an Order directing service of the Notice of Sale upon the above-captioned Defendant, SUSAN A. HANFT ,by certified mail and regular mail to 310 F AIRVIEW STREET, qARLISLE, PA 17013 and 7 HIDDEN MEADOWS DRIVE, CARLISLE, PA 17013, and in sppport thereof avers the following: I. A Sheriffs Sale of the mortgaged property involved herein has been scheduled for SEPTEMBER 7, 2005. 2. Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 3129.2 requires that the Defendant be served with a notification of Sheriffs Sale at least thirty (30) days prior to the scheduled sale date. 3. Attempts to serve Defendant with the Notice of Sale have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". 4. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to 310 'FAIRVIEW STREET, CARLISLE, PA I 70 13 and 7 HIDDEN MEADOWS DRIVE, CARLISLE, PA 17013. PHELAN HALLINAN & SCHMIEG. LLP rJc"c,tY1 J.t[L" DANIEL G. SCHMI~, ESQUIRE Attorney for Plaintiff By: AFFIDAVIT OF SERVICE PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY PJT No. 2005-00687 CIVIL TERM DEFENDANT(S) SERVE SUSAN A. HANFT AT 7 HIDDEN MEADOWS DRIVE CARLISLE, PA 17013 SUSAN A. HANFI' ACCT. #1976691950 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 7, 2005 SERVED Serv~d and made known to . Defendant, on the day of , 200-J at . o'clock _,In., at , Commonwealth of Pebnsylvania. in the manner descrihed below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside{ s). Agent or person in charge of Defendant( s)'s office or usual place ofbusiness. an officer of said Defendant(s)'s company. Other: Description; , Age_ Height_ Weight_ Race_Sex_ Other I, . a competent adult, being duly sworn according to law, depose and state that I personally handed a true.l~d correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the anpress indicated above. Swonj to and subscribed before me this _ day of .200_. Notut: By: PiLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. On the f7 ~aYOf ~~ l NOT SERVED ~ . 200-L at 6: I 7 o'clock f'm., Defendant NOT FOUND because; Vacant "f.-... O{t.t. "- - ~ i Moved Unknown No Answer I" A~empt: / I Time: 2nd Attempt: / / 3rd Aittempt: / ( Time: 111; 5 'O-~~V'ess- Swornfoand sub=i\>ed U "OC:~L f\ \l '5 ?~g~~ B'~i/Jfrc ~ ~~~~~kf:e:'::;:~~SqUire -I,D. No. 62205 VfV(-- Time: ~ s ?-IJ U,t0ilN\\Vc.,,~ ~ V'd-c.a-~ \- \(,~, ~ ~ \{",,--'S,', J.<:ol'-'Q.~ I 1 NOTARIAL SEAL UICIlE H, CARTY. KolaIY PullIIG TOWI'IlIhIp, FIII1IdIn CountY My ll!\ El\phI Nov. 10, 7JKJ7 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PJT No. 2005-00687 CIVIL TERM DEFENDANT(S) SUSAN A. HANFT ACCT. #1976691950 SERVE SUSAN A. HANFT AT 310 FAlRVlEW STREET CARLISLE, PA 17013 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 7, 2005 SERVED Serv~d and made known to . Defendan~ on the day of , 200~ at . o'clock_.m., at , Co1jJInonweallh of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendanl(s) reside(s). Name and Relationship is Adull in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)ls company. Other: Desd;iption: Age_ Heighl_ Weighl_ Race Sex Other I, \ . a compelenladuIt, being duly sworn according 10 law, depose and state thaI I pe~Uy handed a true and correcl copy of the Notice of Sheriff's Sale in the manner as sel forth herein. issued in the captiqned case on the date and al the address indicated above. Sworj110 and subscribed before me \his _ day of .200_. Nonur: Dy: i PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. ~ NOT SERVED Onth. )6 daYOf~_'200~1~: 'S"o'c!oCk-t.m.,DefendanINoTFOUNDbecanse: ----J Moved Unknown No Answer Vacanl ..:f::- o~l~Y'. 2nd Attempt: 1 tJ ~ I j~ \c,O i'- ~. 5"~: ~ (~I<7t->f.lc- 0"'-' \J'S ;;l ~ ~,o \::>0~ doE'S 1 31 #- Time: r=a\~VI~W ~"''<. ,vefe'\<.-t y f'J"-' ~ I i v" \,,^C've.. si-. 1" Attempt: 1 1 Time: \ 3rd ~ttempt: I 1 Time: SwomllO and subscnb,ed ben e me this --1J.!!Iday of ",.\ ,200S; /;() . ~n Nola: . W BY;~ . L ) =: ~~;:;~:.,,,,,'1.~_ y: 0'-. NOTARIAl. SEAL LUCIllE H. CARTY. ::In NIle ~J=:Nov.1~ " SKN Data Research Inc. AFFIDA VIT OF GOOD FAITH INVESTlGA TlON File Number: Attorney Firm: Subject: 14-1383 PHELAN HALLINAN & SCHMIEG, LLP Susan A. Hanft Current Address: 7 Hidden Meadows Drive Carlisle PAl 70 I 3 Property Address: 7 Hidden Meadows Drive Carlisle P A 17013 Mailing Address: 7 Hidden Meadows Drive Carlisle PA 17013 I, Scott Nulty, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct. Susan A. Hanft - 188-56-8633 B. EMPLOYMENT SEARCH Susan A. Hanft- A review of the credil reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of credilors indicated that Susan A. Hanft residers) at: 7 Hidden Meadows Drive Carlisle PA 17013. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH On 4/27/2005 our office contacted directory assistance which indicated that Susan A. Hanft residers) at: 7 Hidden Meadows Drive Carlisle PA 17013. Our office made a telephone call to the mortgagor's phone number and received the following infonnalion: 717-249-7451; spoke with subjecl who confirmed address. III. INQUIRY OF NEIGHBORS On 4/27/2005 our office attempted to contact neighbors; they were not able to verify that Susan A. Hanft residers) at: 7 Hidden Meadows Drive Carlisle PA 170\3. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 4/27/2005 we reviewed the National Address database and found the following infonnation, Susan A. Hanft - 7 Hidden Meadows Drive Carlisle P A 17013 B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: No addresses on file. V. DRIVER LICENSE INFORMATION A. MOTOR VEHICLE & DMV OFFICE Per lhe P A Department of Motor Vehicles, we were unable to obtain address infonnation on Susan A. Hanft. VI. OTHER INQUIRIES A. DEATH RECORDS As of 4/2712005 Vital Records and all public databases have no death record on file for Susan A. Hanft. B. COUNTY VOTER REGISTRATION The Cumberland County Voter registration was unable to confinn a registration for Susan A. Hanft residing at: last registered address. C. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.) Our office conducted a search for public licenses and found the following: No records on file. VII. ADDITIONAL INFORMATION ON SUBJECT A. DATE OF BIRTH Susan A. Hanft - 1962 B. AKA. None . All accessible public databases have been cbecked and cross-referenced for tbe above- named individual(s). .Please be advised all database information indicates the snbject resides at the current address. The undersigned understands that this statement herein is made subject (0 lhe penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. [ hereby verifY that the statements made herein are true and correct to the best of my knowledge. information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Presidenl Sworn to an subscribed to me thiS~ day of (~J 2005 N~~~~L1~ M0~ Notarial Sea! l Margaret E Nulty. Notary PublIC I East Goshen T wp. Ch~)Sler County \ My CommissIOn Expires Dee I B cOOS ~ Member, Pennsylvania Association Of Notaries The above infonnation is obtained from available public records; and we are only liable for the cost of the affidavit PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney I.D. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION .sYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION SUSAN A. HANFT NO. 05-627 CIVIL TERM Defendant PLAINTIFF'S MEMORANDUM OF LAW Pursuant to Pennsylvania Rule of Civil Procedure, Rule 3129.2, it is necessary in ~ foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the $ale of the mortgaged premises. Specifically, Pa.R.C.P., Rule 3129.2 (c) provides in applicable p~rt as follows: The written notice 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 shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402 (a) for the service of original process upon a defendant, or (B) by the plaintiffmaijing a copy of the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in the 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. Because the whereabouts of Defendant, SUSAN A. HANFT , are unknown, a ~easonable investigation of their last known address was made in accordance with Pa.R.C.P. ! ~30(a). Pennsylvania Rule of Civil Procedure, Rule 430 (a) provides as follows: ( 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 the defendant and the reasons why service cannot be made. Note: A Sheriffs Return or Affidavit of Service of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs.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 (I) inquiries 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 ofthe defendant and (3) examinations oflocal telephone directories, voter registration records, local tax records and motor vehicle records. As indicated by the attached Affidavit of Return of Service, marked hereto as Ekhibit "A", the Process Server has been unable to serve the Notice of Sale. , A good faith effort to discover the whereabouts of the Defendant has been made a~ evidenced by the attached Affidavit of Reasonable Investigation, marked as Exhibit "B". ! WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to 310 FAIRVIEW STREET, CARLISLE, PA 17013 and 7 HIDDEN MEADOWS DRIVE, CARLISLE, P A 17013. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP By: ANIEL G. SCHMIE , ESQUIRE Attorney for Plaintiff VERIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby states that he is the attorney for the Plaintiff in this action, that he is authorized to take the verification and that the statements made in the foregoing Motion for Service of Notice of Sale pursuant to Special Order of Court are true land correct to the best of his knowledge, information and belief. The undersigned also understands that this statement herein is made subject to the ~enalties of 18 Pa. Sec. 4904 relating to unsworn falsification to authorities. pate: May 6, 2005 PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney 1.0. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRA nON SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION SUSAN A. HANFT NO. 05-627 CIVIL TERM Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy ofthe foregoing Motion for Service of Notice ~f Sale Pursuant to Special Order of Court, Proposed Order, Memorandum of Law, Certification ~f Service and Verification in the above captioned matter was sent by first class mail, postage n,repaid to the following interested parties on the date indicated below. $USAN A. HANFT ~10 FAIRVIEW STREET <f:ARLlSLE, PA 17013 ~nd 1 HIDDEN MEADOWS DRIVE ~ARLlSLE, P A 17013 .-/~J Daniel G. Schmieg, Es uire Attorney for Plaintiff Ilate: Mav 6. 2005 r: ~< ~, <. .~.) ;: ~ () -n G :-'" C', rJ ~r:. .< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CIVIL DIVISION RECEIVED MAY 11 2005 r Plaintiff v. NO. 05-627 CIVIL TERM SUSAN A. HANFT Defendant ORDER AND NOW, this -...!.L day of ,...,,,\ ' 2005, upon consideration of Plaintiffs Motion for Service of Notice of Sale Pursuant to Special Order of Court and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above-captioned Defendant, SUSAN A. HANFT, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to 310 F AIRVIEW STREET, CARLISLE, P A 17013 and 7 HIDDEN MEADOWS DRIVE, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. J. ~-t r- -s; r - "J ~ '>~ \' ~ t\~\ t c': ",';: "';" ('''1 ;', l.I i', SGGZ ( PHELAN HALLINAN & SCIDvHEG, LLP By: DANIEL SCHMIEG, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY No.: 05-627 CIVIL TERM vs. SUSAN A. HANFT AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to SUSAN A. HANFT, on 6/1/05 at 7 HIDDEN MEADOWS DRIVE, CARLISLE, PA 17013 and 310 FAIRVIEW STREET, CARLISLE, PA 17013, in accordance with the Order of Court dated 5/13/05. The undersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. ~ (o? J ? Date: June 10, 2005 ~ ~ ~ ~ - e,..) -;;;f>> ::;: -q .r;:- C' ~ ::(.-T\ \'1"\ r: -0 v:; ~O""r "go --< ,,-"-i _"_ -f ., C) -:;" _./C) t:t' -.-\ J.:: ~ ........ SALE DATE: SEPTEMBER 7, 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 05-627 CIVIL TERM VS. SUSAN A. HANFT AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the n:al property located at: 7 HIDDEN MEADOWS DRIVE. CARLISLE. P A 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sa Ie has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy ofthe Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by th.e U.S. Postal Service is attached for each notice. August 4, 2005 SQUIRE CUMBERLAND COUNTY MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 05-627 CIVIL TERM vs. SUSAN A. HANFT AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.2) Plaintiff in the above action, by its attorney, DANIEL SCHMIEG, EsqlJl:'. ,ets forth as of the date the Praecipe for the Writ of Execution was filed the folJowing int'" :i'. i 'm concerning the real property located at 7 HIDDEN MEADOWS DRIVE, CARLISL V. . ~ 17013: 3. Name and last known address of every judgment creditor whose judgment is a reco"" non the real property to be sold: Name Last Known Address (if address ca" " reasonably ascertained, please indie". , .., " 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address Ci!i ,'" reasonably asc,ertained, please incl. ELBERT L P 5 SOUTH HANOVER STREET CARLISLE, P A 17013 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably as,:ertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably as(;ertained, please indicate) None. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relati to unsworn falsification to authorities. , ESQUIRE aintiff August 4, 200S MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMlaERLAND COUNTY Plaintiff, COURT OF COMMON PII-.'. S v. CIVIL DIVISION SUSAN A. HANFT NO. 0:5-627 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC.. Plaintiff in the "h.:e action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe fi" ;1" Writ of Execution was filed the following information concerning the real property located at ..JJ.n DDEN MEADOWS DRIVE. CARLISLE. PA 17013. I. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannel. he reasonably ascertained, please indicate) SUSAN A. HANFT 310 FAIRVIEW STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a rev, " 'n the real property to be sold: Name Last Known Address (if address c,,,' reasonably asceliained, please indi.. ' , RAYMOND E. DIEHL AND GENEVIVE A. DIEHL 401 MYERS ROAD BOILING SPRINGS. PA 17007 4. Name and address of last recorded holder of every mortgage of record: Name ELBERT. L.P.. A PENNSYLVANIA LIMITED PARTNERSHIP CIO AMERICAN HOME BANK. NA Last Known Address (if address cannot be reasonably ascertained, please indicate) 805 ESTELLE DRIVE. SUITE 101 P.O. BOX4454l LANCASTER, PA 17604-4454 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name OMNIUM WORLDWIDE. INC. COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTENTION: JOHN MURPHY INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM Last Known Address (if address cannot be reasonably ascertained, please indicate) 7171 MERCY ROAD. SUITE 400 P.O. BOX 6618. OMAHA. NE 68106 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 P.O. 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" .. .. ~ o a o . >- ~ .. ~ ~'t-<.fS 1'Os?--1~ Q'" ~ ~(l.~~~-- I' ~ """'V' - I'ITNEYBOWE5 02 1A $ 02.700 0004300311 APR 0 7 2005 MAILED FROM ZIP CODe 1 91 03 L1J LUI (") ....., Q = fF c'" "'" \:)iSJ ~ ~ rnn, c:: -". "1; G') ~~ Z c~. , (j)l'~ ... ~:: \D E,;:Cj -1: ,., $(") > ?~ :!J ~O :J: 6~ c ~ --l (J1 ?b N -< Mortgage Electronic Registration Systems, Inc. VS Susan A. Hanft The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-627 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 13,2005 at 3:15 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Susan A. Hanft, by making known unto Susan A. Hanft, personally, at 7 Hidden Meadows Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on July 05, 2005 at 4:40 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Susan A. Hanft, located at 7 Hidden Meadows Drive, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit; Susan A. Hanft, by regular mail to her last known address of 7 Hidden Meadows, Drive, Carlisle, PA 17013. This letter was mailed under the date of July 01, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Schmieg. Sheriffs Costs: Docketing 30.00 Poundage 22.84 Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1. 00 Mileage 8.00 Certified Mail 4.30 Levy 15.00 Surcharge 20.00 Law Journal Patriot News Share of Bills 599.00 415.91 18.20 $1,164.75 Sworn and subscribed to before me so~s .b~ ~ "A<~ , . R. Thomas Kline, Sheriff BY \ h rLi~JVY\iL~ Real Estate ergeant 2005, A.D. r 1::,1[) c..n. ~J 0(,1 Ru-. I (, 9'.lf.,J MORTGAGE ELECTRONIC REGISTRA nON' SYSTEMS,INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION SUSAN A. HANFT NO. 05-627 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .7 HIDDEN MEADOWS DRIVE, CARLISLE. PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) SUSAN A. HANFT 310 FAIRVIEW STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) RAYMOND E. DIEHL AND GENEVIVE A. DIEHL 401 MYERS ROAD BOILING SPRINGS. P A 17007 4. Name and address oflast recorded holder of every mortgage of record: Name ELBERT. LoP.. A PENNSYL VANIA LIMITED PARTNERSHIP CIO AMERICAN HOME BANK, NA Last Known Address (if address cannot be reasonably ascertained, please indicate) 805 ESTELLE DRIVE. SUITE 101 P.O. BOX 4454 LANCASTER, PA 17604-4454 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name OMNIUM WORLDWIDE, INC. COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTENTION: JOHN MURPHY INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM Last Known Address (if address cannot be reasonably ascertained, please indicate) 7171 MERCY ROAD. SUITE 400 P.O. BOX 6618 OMAHA, NE 68106 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be . reasonably ascertained, please indicate) Tenant/Occupant 7 HIDDEN MEADOWS DRIVE CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department ofWeIfare PO Box 2675 Harrisburg, P A 17105 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 of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. April}, 200S DATE ~ /.-f~ DANIEL G. SCHMIEG, ESQ~ Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. CUMBERLAND COUNTY Plaintiff, No. 05-627 CIVIL TERM v. SUSAN A. HANFT Defendant(s). April I, 2005 TO: SUSAN A. HANFT 310 FAIRVIEW STREET CARLISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at , 7 HIDDEN MEADOWS DRIVE, CARLISLE, P A 17013. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 7. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $426,463.05 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale tlrrough other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN 101 of ground situate in Dickinson TowllShip, Cumberland County, Peoosylvaoia., boooded llIItI described in accordance with the land SlIbdlYilllon for Hidden Meadows prepared by Carl Bert and Associates, promsional land surveyor. dated November 8, 1999 and recorded in the hereinafter Reoorder's Office in Plan Book 82, Page 58 as follows: BEGINNING at an iron pin the Western rlgbt-of-way line of 60 feet wide Hidden Meadows Drive at the dividing line between loIS Nos. 6 and 7; thence along the Weslern right-of-way line of 60 feet wide Hidden Meadows Drive, by a curve to tbe right baving a radius of 40.00 fee( an arc distance of 38.87 feet to an iron pin; thence by same by a curve to the left baving a radius of 60.00 feet an arc distance of 91.16 feet to an iron pin at the dividing line between Lots Nos. 6 and 12; thence along the dividiug line between Lots Nos. 6 and 12, Sollth 09 degrees 00 milllllell 2:i seconds West a distance of 126.69 feet to an iron pin; thence by same South 31 degrees 36 minutes 03secoods East a distance of 275.45 feet to a concrete monument in the dividing line between Lots Nos. 5 and 6 at the Southwest corner of Lot No. 12; thence along the dividing line between Lots Nos. 5 and 6 South 47 degrees 06 minutes 25 lleC()ods West a distance of 611.98 feet to a COfl.Cfefe monument in the dividing line between Lots. Nos. 4 and 6; thence along said dividing line between Lots Nos. 4 and 6, North 39 degrees rn minutes 05 seconds West a distance of 211.48 feet to an iron pin at the Southeast corner of Lot No.2; thence along the dividing line between Lois Nos. 2 and 6, North 41 degrees 49 minutes 42 IleC()nds West a dislllriCe of 158.41 feet to an iron pin in the dividing line between Lots Nos. 6 and 7; thence alODg the dividing line between Lots Nos. 6 and 7, North 39 degrees.59 minutes 58 seoonds East a distance of 77j.98 feet to an iron pin in the Western right-of-way line of 60 feet wide Hidden Meadows Drive, the place of beginning. BEING all of Lot No. 6 as shown on the Land Subdivision for Hidden Meadows recorded in Plan Book . 82, Page 58 and containing 6,32992 aeres. TITLE TO SAID PRBMlSI3S IS VI3STED IN Susan A. Hanft, widow by reason of the following: BEING the same premises which Helen T, Hobbie, widow and Robert G. Frey and Debra L. Frey, husband and wife by Deed dated 1211012001 and recorded 12121/2001 in the Cou1lly of Cumberland in Record Boolc 7A9 Page 3623 conveyed unto Michael J. Hanft and Susan A. Hanft, husband and wife. AND THE SAID Michael 1. Hanft depaJ1ed this life on the 11th Day of Aug A.D. 2004 whereby title to said premises became vested in Susan A. Hanft by Right of Survivorship. TAX PARCEL # 08-09-525-169 PREMISES BEING: 7 HIDDEN MEADOWS DRIVE, CARLISLE, P A 17013 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-627 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Mortgage Electronic Registration Systems, Inc. Plaintiff (s) From Susan A. Hanft (I) You are directed to levy upon the property of the defendant (s)and to sell see legal description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued: (b) lhe garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirn/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $426,463.05 L.L.$.50 Interest from 4/1105 to September 7, 2005 (per diem - $70.10) $11,145.90 and Costs Atty's Conun % Due Prothy $1.00 Any Paid $110.00 Other Costs Plaintiff Paid Date: April 5, 2005 CURTIS R. LONG (Seal) ProthOn2 .~ '" I2c, o 2. 7/(0l/?/Y' Deputy ~ REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale #13 On May 04, 2005 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 7 Hidden Meadows Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 04, 2005 ByJ6CYG( Jmii~ Real Estate Deputy L G :b d q - lldV ~OOl Vd '),lHlll.;..) L_,1 \j".:'.;~:c.I!':,!J .:I.:II83H5 3HJ. .:10 3JI.:1.:W ~ ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: July 15, 22, 29, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. , \, REAL ESTATE SALE NO. 13 e, Editor Writ No. 2005-627 Civil Mortgage Electronic Registration Systems, Inc, VS. Susan A. Hanft Atty.: Daniel Schmieg LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in Dickinson Township, Cumberland County. Pennsylvania, bounded and described in accor- dance with the land Subdivision for Hidden Meadows prepared by Carl Bert and Associates, professional land surveyor, dated November 8, 1999 and recorded in the hereinaf~ ter Recorder's Office in Plan Book 82. Page 58 as follows: BEGINNING at an iron pin the Western right-of-way line of 60 feet wide Hidden Meadows Drive at the dividing line between Lots Nos. 6 and 7; thence a):>z:~ _the 'Y:s~~~~ o AND SUBSCRIBED before me this day of Julv. 2005 NO SEAL LOIS E. SNYDER, Notary Public Car.sle Boro, Cumberland County My Commission Expires March 5, 2009 ter Recorder's Office in Plan Book 82, Page 58 as follows: BEGINNING at an iron pin the Western right -of-way line of 60 feet wide Hidden Meadows Drive at the dividing line between Lots Nos. 6 and 7; thence along the Western right-of-way line of 60 feet wide Hid- den Meadows Drive, by a curve to the right having a radius of 40.00 feet an arc distance of 38.87 feet to an iron pin; thence by same by a CUIVe to the left having a radius of 60.00 feet an are distance of 91.16 feet to an iron pin at the dividing line between Lots Nos. 6 and 12; thence along the dividing line be- tween Lots Nos. 6 and 12, South 09 degrees 00 minutes 25 seconds West a distance of 126.69 feet to an iron pin; thence by same South 31 degrees 36 minutes 03 seconds East. a distance of 275.45 feet to a concrete monument in the dividing line between Lots Nos. 5 and 6 at the Southwest comer of Lot No, 12; thence along the dividing line be- tween Lots Nos. 5 and 6 South 47 degrees 06 minutes 25 seconds West a distance of 6 I 1.98 feet to a concrete monument in the dividing line between Lots Nos. 4 and 6; thence along said dividing line be- tween Lots Nos. 4 and 6, North 39 degrees 07 minutes 05 seconds West a distance of 211.48 feet to an iron pin at the Southeast corner of Lot No 2; thence along the divid- ing line between Lots Nos. 2 and 6, North 41 degrees 49 minutes 42 seconds West a distance of 158.41 feet to an iron pin in the dividing line between Lots Nos. 6 and 7; thence along the dividing line be- tween Lots Nos. 6 and 7. North 39 degrees 59 minutes 58 seconds East a distance of 775.98 feet to an iron pin in the Western right-of-way line of 60 feet wide Hidden Mead- ows Drive, the place of beginning. BEING all of Lot No. 6 as shown on the Land Subdivision for Hidden Meadows recorded in Plan Book 82, Page 58 and containing 6.32992 acres. TITLE TO SAID PREMISES IS VESTED IN Susan A. Hanft, widow by reason of the following: BEING the same premises which Helen T. Hobbie, widow and Rob- ert G. Frey and Debra L Frey, hus- band and wife by Deed dated 12/ 10/2001 and recorded 12(21( 2001 in the County of Cumberland in Record Book 249 Page 3623 con- veyed unto Michael J. Hanft and Susan A. Hanft, husband and wife. AND THE SAID Michael J. Hanft departed this life on the 11th Day of Aug A.D. 2004 whereby title to said premises became vested in Susan A. Hanft by Right of SllT"lrl- vorship. TAX PARCEL #08-09-525- 1 R'l PREMISES BEING: 7 HIDDEN MEADOWS DRNE. CARLISLE. PA 17013. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street. in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sundayl Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COpy SA L E #13 Sworn to and su c PUBLICATION IlEAL ESTATE SALE No. 13 _ No. 2OCJ6.4I27 CIvIITenn ~ Electronic Reg_ Sy8I8m8, Inc. v. '~,~..'..... ....... rut '_ ._(.!i._ AlL TIIAT CERTAIN IoC 01 grouod __ II -... Town-Ibip, CUmbaIOIld County, _ylYlllio, bouaded ODd desaibed ill lICCOIdm:ewilbdlelaDlilulHlivilioafcrllidden _ -'" by c.t Bert....-. pufcsoioooIllIIId_,_/lqw:lIlb<t8, 1999 0Dd_ ill dle ~ R&<udcr', OIIia:iIIP1mBoot82.PasesliosfolIowo: BEGlNNING 81 au iron pm on the ~ rip;-of.woy lioe of/i)!eel wide 1Iidden_ Drive.dledividiDsliDobetweeoLolsNos.6.... 1; lIm:e oloog dle w...m riBJIl-of...y liDo of 6Of"'widellidden_llrive,by.~ IDlborigllba'lingal3tiiuof40.00!eelanlllt _ of 38,81 "" to an iron pin; lIm:e by same by a curve to !be leftbaviDg a radius. of 60.00 feet IllIl'C disIaJl:e of91.16 feet to an iron pinatdledividiDsIiDebilrieenLoisN...6.... 12:.tI:Ienr2tiNur._dividiftg.1ineh8wf'ftiTllk CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 415.91 REAL I!STATE SALE No. 13 Writ No. 2OOli-t27 ClvtlTenn ~Electnmlc R8&_Sy_,lnc. v. ,\\.....- ..." a.IiI T.h II . ~__nun AIL 11IAT CERfAIN loc Of ground __ ill Dickinson rown-sbip, CUmberland CoonI}', Pennsylvania, bounded and described in o:c<J<IIonce wilh lhe land Su~ locHiddco MeadowsJl"P'lellbyc.IlkrtandAssocioles, J'OlessioooI land """yOC, dall:d November 8, 1999 and _ in lhe bereino1lfr RMordcr', Office in Plan Book 8~ Page 5li IS full..., BEGINNING at an iron pin on tbe Wmem rigbt-of-wny line olflOe.. wide HiddcoMoadows Driveaclhe dividing1ine between Lob Nos. 6 and 7; lhence nlong lhe _ right-ol-way line 01 flO e.. wide Hiddco -. Drive, by n ~ to lberlghtbaving aradiils of 40.00 feet an are disIlmce of 38..87 foet 10 an iron pin; lhence by same by a curve to the Jeft baving a radius of 60.00 feet an arc distaoce of91.16 feet to an iron pinnllhedividinglinebelweenLobNos. 6 and 12; lhence nlong die dividing line bctween Lob Nos. 6 and I~ Soulh 09 degrees OOminutlos 25 seconds West a distaace of 126.69 feet to an iron pin; lhenceby same Soulh31 degJm36nrinutes 03 seconds Ens!. disIlmceof 275.45'1", 10. """""~inlhedividinglinebetween Lob Nos. 5 and 6aclhe_"""" ofLoc No. 12; lhence nlong lhe dividing line bctween LobNos.5and6Soulh47~06_25 seconds West a distance of 611.98 feet to a -~inlhedividinglinebetween Lob Nos. 4 and 6; lhencenlong said IIividing line between Lob Nos. 4 and 6, Norlh 19 degJm rn minutes 05 seconds We.... disIlmce of 211.48 e.. to an iron pin at the Soutbi:ast comer of Lot No.2; lhencealong lhe dividing line between Lob Nos. 2 and 6, Norlh 41 des<ees 49 minutes 42 seconds WestadistaDceC1fl~8.41fctttoanironpioiIitbe dividing line between Lob Nos.. 6 and 7; lhence along lhe dividing line between Lob Nos. 6 and 7, Norlh 39 degJm 59 minu1ts 58 secondsEns!. ~of775.91 feet to an iron pin in tbe _ rigltt-oi-wny line of flO e.. wide Hiddco Meadows Drive, lhep1ooeofBEGlNNlNG. BEING aD of Lot No.6 as shown on the land Subdivision foc Hidden Meadows rc:axded in Plan Book 82. Page 58 and CODIaining 6.32992 acres. TI1LE TO SAID PREMISES is vested in Susan A. Honft. widow. by IeIISOIl 01 lhe loIlowing' BEING the same .premises which Helen T. Hoilbie, widow, and Robert G. FIey and Deln L. FIey, husband and'wife, by Deed dall:d 111101 2001 and recorded 12I21flOOI in lhe County of Cumberland in _ Book 249 Page 3623 conveyed unto Midule1 J. Hanft and Susan A. Honft.Iwsband and wife. , . AND TIlE SAID Micboel J. Hanft deponed this life onlhe 11th Day of Aog. AD. 2004 wlxleby title to said IRJDises became vested in Susan A. Hanft by Jijght 01 SoMvonlUp. . TAXPARCELoH08-09-525-169. PREMISES BEING: 7ltidden Meadow9 Drive, Carlide,PAI7013.