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HomeMy WebLinkAbout14-0550 • Supreme Co f-"' .p nnsylvania Cou � Alit m o leas For Prothonotary Use Only: � l rt Docket No: Cu , eland �Y County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S xi Complaint 0 Writ of Summons 0 Petition © Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Worthington Mortgage Keith M. Convery Dollar Amount Requested: 0 within arbitration limits I Are money damages requested? ED Yes x3 No (check one) ix outside arbitration limits ;O I N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? ( Yes Fil No A Name of Plaintiff /Appellant's Attorney: Kevin P. Diskin, Esquire © Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card El Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept. of Transportation S kJ Premises Liability 0 Statutory Appeal: Other 0 Product Liability (does not include 0 Employment Dispute: L'j mass tort) 0 Slander/Libel /Defamation Discrimination © C 0 Other: ® Employment Dispute: Other Zoning Board T ® Other: i I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: 0 Ejectment ® Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation © Declaratory Judgment 0 Ground Rent Q Mandamus 0 Landlord/Tenant Dispute 0 Non - Domestic Relations 9 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial ® Quo Warranto 0 Dental ® Partition ® Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical ® Other: 0 Other Professional: Updated 1/1/2011 Richard M..Squire & Associates, LLC Attorneys for Plaintiff lf, �� � F By: Richard M. Squire, Esquire 1 J f . 2$ Kevin P. Diskin, Esquire C(f,DL , 11- Craig Oppenheimer, Esquire PEN�LI' dD CCIJ T ID. Nos. 04267 / 86727 / 313264 YL VA,�IA ! One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215 - 886 -8791 Worthington Mortgage, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, (1 SSb bu DOCKET NO: � �( V. CIVIL ACTION Keith M. Convery 19 Nottingham Dr MORTGAGE FORECLOSURE Mechanicsburg, PA 17050, DEFENDANT 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 of relief requested by the plaintiff. You may lose money or property or other rights important to you. 1 S ?d «Fieldl» «Field94» 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 demands 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 provisioner 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 0 BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 - 249 -3166 and 800 - 990 -9108 2 ((Fieldl ))/«Field94» 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 Worthington Mortgage, IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: Keith M. Convery CIVIL ACTION 19 Nottingham Dr Mechanicsburg, PA 17050, MORTGAGE FORECLOSURE DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Worthington Mortgage, by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 1. Plaintiff, Worthington Mortgage, 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 (13 Stat. 99, 12 U.S.C. 1 et seq.), acting by and through its authorized agent and mortgage loan servicer, BSI Financial Services, Inc., with its principal place of business at c/o BSI Financial Services, Inc., 314 S. Franklin Street, Titusville, PA 16354. 3 ((Fieldl ))/s Field94» 2. Defendant, Keith M. Convery, is the surviving real owner, mortgagor, and grantee in the last Deed of record to the real property located at 19 Nottingham Dr Mechanicsburg, PA 17050 including any /all improvements and detached structures thereon as well as any /all riparian /water rights appertaining thereto (hereinafter collectively referred Was "Premises ") . 3. On December 10, 2004, Keith M. Convery and Carol A. Convery made, executed, and delivered a Mortgage to Franklin Security Bank, FSB (hereinafter referred to as "Originating Lender ") as security for their payment and other obligations in consideration of a mortgage loan made to them by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, and was recorded on December 16, 2004 in Cumberland County in Mortgage Book 1891, Page 2632, and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. Upon information and belief, Carol A. Convery departed this life on or about April 13, 2012, thereby vesting title in Keith M. Convery, her husband, by right of survivorship. 4. By Assignment of Mortgage, the Mortgage was assigned to Plaintiff, which Assignment is in process of being recorded. Plaintiff is the holder of the mortgage. 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 19 Nottingham Dr, Mechanicsburg, PA 17050. 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 June 1, 2013 through the present 4 ((Fieldl ))/cField94» 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, Defendant shall be liable for, inter alia, Plaintiff's costs, corporate advances, escrow advances, and attorneys' fees. 9. The following amounts are due as of January 27, 2014: Principal $ 129,847.75 Accrued Interest through January 27, 2014 $ 3,090.84 Late Fees $ 34.81 Escrow Advances $ 337.73 Attorneys' Fees to date $ 6,492.39 Total $ 139,803.52 plus additional pre - judgment and post - judgment interest at the per diem rate of $11.56 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's 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 up to five percent (5 %) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff's sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. 5 ((Field 1)) /«Field94» 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 Defendant, Keith M. Convery, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 9., namely $139,803.52, plus additional pre judgment and post judgment interest at the per diem rate of $11.56 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: chard M. Squire, Esq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) 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 kdiskin @squirelaw.com coppenheimer@sguirelaw.com Attorneys for Plaintiff Date: 6 ((Fieldl))/«Field94» 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. 7 ((Fieldl))/ «Field94u 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 Worthington Mortgage, IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: Keith M. Convery CIVIL ACTION 19 Nottingham Dr Mechanicsburg, PA 17050, MORTGAGE FORECLOSURE DEFENDANT VERIFICATION Kevin P. Diskin, hereby states that he is the attorney for the Plaintiff, a corporation, unless designated otherwise; that as such he is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 8 f Kevin P. Diskin, Esquire Attorney for Plaintiff Date: January 27, 2014 File #: BSI -263F FNMA Name: Keith M. Convery 9 ((Fieldl))/«Field94» Exhibit "A" M L THAT CBR'T M N plieoe or parcel of Ind sinnin in Silver Spring Township, G1mmhe clmd County, PennsyIva* more psrtion]arlybounded and desedW as follows, to wit BEOIl WM at a point on the wesbemright -of- way line of Nattingham Drive at the northeastern corner of Lot No. 1d -A as shown oaths hereinafter mentioned p1in of Jots; thence along Notdnghem Drivo by a cuaves btrvkg a radius of 175.00 feet an arc loWh of 33.67 feet too, point &a m South 08 degrees 01 minute 37 seeands East 19.47 feet to a point st the dividing line between LoMs. 14 -A and 14-8; thence Son& 81 degrees 58 minutes 23 sewads Wed 110.00 feet to a point at the dive t Ike between Lot Nos. 14-A and 23; tb nce along said line North 08 degrees 01 =twee 37 seconds West 30.00 feet to spoint; thence North 80 degrees 24 minutes 01 second Fast 106.61 feet to a point the place of J EOWNING. CONTAINING 5,630.10 agwnv fieot. UNDERAND SUBJECT to restrictions appearing in IV m. Book 481, Page 1063,2s recorded in the tike of the Recurdet of Deeds in and for Oberland County, Pennsylvania, and as shown on then sfaremendhmed plan. TOGETFMR wife all and ah%vlar the buildings, imptnvenients, ways, woods, warn, waftreourses, n$1f, des, P-UeVcs, barodiommats soul, appurtanonces to the same belonging or la anywise apperlaintng; and the reversion and reversions, remainder and remsindare, rents, issues andprofits thereof. and 6f ovary part and pmml thsr0o$ AND ALSO dift estate, right; title, interest, ore, possasslao, property, claim and demand whatsoever of the Grantor both in Tate and in equity, o$ is end to the premises luxain desca3bed and every part and parcel thereof with the appurtonaaees. TO HAVR AND TI0 HOLD all and dogalat the patmiees hmvk desrnr' bed together whh the hweditaaamts and appurtenances Unto the (3ra tees and to the Grantees' proper aw and benefit forever: Reparty knawa as: 19 Nottbggham Drive, Mechanicsburg, PA 17050. Tax ID M 38- 19-1621 -209 10 <(Fieldl))/«Field94» FORM 1 Worthington Mortgage ; IN THE COURT OF COMMON PLEAS O p _ ; CUMBERLAND COUNTY, PENNSYLc Plaintiff(s } T s �, - T 3" •� ice: vs. 00 -4 c_ Keith A. Convery �� - z c. 0' �� � Defendant(s) Civil °. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSI1RE 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. Respectfully submitted: J � Date [S' ature of Counsel for .Plaintiff] FORM Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket 4 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: c us'roim E R/1 INIA 10' A 1 1 1 1 1,1 CANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes Q No Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: of people in household: How long? Mailing Address: City: State: zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? a MUM M = h"i K11 tal 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 n No El If yes, provide names, location of court, case .number & attorney: Assets Amount Owed Value: Horne: $ $ 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): 1. monthly amount: 2. monthly amount: Borrower Fay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/Tuit. Other Ex penses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes M No Q 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 ❑ 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 for possible mortgage options. I/We understand that I /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 `+l Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 FORM 3 - i Worthington Mortgage. ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Keith M. Convery 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 laves in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that .false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 Worthington Mortgage IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. Plaintiff(s) CIVIL ACTION vs. Keith M. Convery NO. 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 1 Conference in person and an authorized representative of the plaintiffllender must either attend. the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the E plaintiff/lender who participates in the Conciliation Conference must possess the f actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. if the duly authorized representative of the plaintiff' /lender is not available by telephone during the Conciliation. Conference, the Court will schedule another Conciliation Conference and require the personal t attendance of the authorized representative of the plaintiff/lender at the rescheduled j Conciliation Conference. f � 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a i forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near feature in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson .�a 4_1 C!t w's Sheriff THE.: 'it iTHOHHi� Jody S Smith 20Ili FEB I I Pty 3: 14 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor ,E PENNSYLVANIA Worthington Mortgage Case Number vs. 2014-550 Keith Convery SHERIFF'S RETURN OF SERVICE 01/31/2014 11:35 AM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Keith Convery at 19 Nottingham Drive, Silver Spring, Mechanicsburg, PA 17050. J E DIMARTL I UTY SHERIFF COST: $39.30 SO ANSWERS, February 05, 2014 RONR ANDERSON, SHERIFF Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin 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 Att orneys for'Plairitiff� f i` tom. f� '-011' /PRc1 P1 c:36 �n`��''ERL�,FdD ,,. 'ENNS YLVANIA r i Worthington Federal Bank F /K/A Franklin Security Bank 314 S. Franklin Street Titusville, PA 16354, PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14 -550 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 Keith M. Convery, Defendant, for his failure to file an Answer to Plaintiff's 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 1/28/2014 to 4/14/2014 Total $ 139,803.52 $ 890.12 $ 140,693.64 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIATES, LLC 'chard M. Squire, Esq. (PA T.D.# 04267) anti PC if Kevin Diskin, Esq. (PA I.D. # 86727) n I' 31'�� Craig Oppenheimer, Esq. (PA I.D.# 313264) l� 2.#.3au cos ) �\ ce a a la; 115 West Avenue, Suite 104 Jenkintown, PA 19046 215- 886 -8790 215- 886 -8791 (fax) rsquire @squirelaw.com kdiskin @squirelaw.com coppenheimer@squirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT DATE: a1 ) L\ PROTHONOTARY Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin 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 Attorneys for Plaintiff Worthington Federal Bank F /K/A Franklin Security Bank 314 S. Franklin Street Titusville, PA 16354, PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14 -550 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 is 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 is over 18 years of age and resides or maintains an address at 19 Nottingham Dr, Mechanicsburg, PA 17050. 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: R$ hard M. Squire, Esq. (PA I.D.# 04267) V Kevin Diskin, Esq. (PA I.D. # 86727) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 Attorneys for Plaintiff (50 USC Appx. '5001 et seq. as amended] The services provided on this site are FREE Welcome to the Official Servicemembers Civil Relief Act (SCRA) Website Single Record Request Multiple Record Requests Users Guide Single Record Request Use this page to request a Certificate verifying Active Duty Status for an individual on a specified date. • Indicates a required field • SSN *Repeat SSN *Birth Date sliteiteo78 Allie,0078 MM/DDNYYY(e.g., 09/16/2012) SSN OR Birth Date Required • Last Name First Name Middle Name Active Duty Status Date Convery 'Keith M. MM/DINYYYY(Default will be today's date e.g., 04/11/2014) Clear Tips & Notes • Without a Social Security Number, DMDC cannot authoritatively assert that this is the same individual that your query refers to. Name and date of birth alone do not uniquely identify an individual. • Check your data entry before submitting it. • Response may take up to 15 seconds after clicking "Submit". Resources Download Adobe Reader Unexpected results? Privacy Notice SCRA 3.0 Department of Defense Manpower Data Center Results as of : Apr -11 -2014 04:00:37 AM SCRA 3.0 Status Report Pursuant t 'to Senlicemembers Civil Relief Act Last Name: CONVERY First Name: KEITH M. Middle Name: Active Duty Status As Of: Apr -11 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA'�'• 4' .-/ ~ "•ii. -: No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA -- NA .- - -' i ' i. •. No I NA This response reflects vttere the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA \NA , \\. - - �r ..._ - ;e ' ,No' : I" NA This response reflects wheth r the individual or his/her unit has recetved 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. r�. 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: N895PB2EUODD3D0 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013 -3387 717-240-1619 Date a.1 »il Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. NOTICE TO: Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on v; 1 Di, ao1 `l, a judgment(decree)(order) was entered agains ou in this office in the proceeding as4kndica abo Deputy Prothonotary Date Mailed: 4 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 Worthington Federal Bank F/K/A Franklin Security Bank, PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050, DEFENDANTS. TO: Keith M. Convery 19 Nottingham Dr Mechanicsburg PA 17050 DATE OF NOTICE: April 2, 2014 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 14 -550 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 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 Attorneys for Plaintiff Fax: 215-886-8791 ED-OFFICE OF THE PRO 3 HONG TAt 2i ti APR 25 PM 12: CUMBERLAND COUNTY PENNSYLVANIA Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14 -550 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Kindly issue a Writ of Execution in the above matter. Amount Due $ 140,693.64 Interest From 4/15/2014 to 9/3/2014 @ $11.56 per diem 1,641.52 Total: $ 142,335.16 * plus fees and costs Date: April 16, 2014 By: .$ag.so PAp 3q. 30 c!F 1b3.'15 ri IL,.5o i . Squire, Esq. (PA I.D.# 04267) 1$�; Kevin Diskin, Esq. (PA I.D.# 86727) 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 kdiskin@squirelaw.com cppenheimer@squirelaw.com Attorneys for Plaintiff BSI -263F FNMA/DM1 ta.95 Dueeo 60 Li. e531 a3! e3o6Do I�� t urn -kkw d Docket No.14-550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Worthington Federal Bank F/K/A Franklin Security Bank, Plaintiff, V. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 Defendant. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosu Filed: . Squire, Esquire Kevin Diskin, Esquire Craig Oppenheimer, 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 Attorney for Plaintiff BSI-263F FNMA/DM1 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267 / 86727 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886 -8790 Fax (215) 886 -8791 Attorneys for Plaintiff 7 F LE0 -OFD iCE C i fi i i O{ H0? OTA 20i .1,,P R 25 NI 12: 1 4.3 CUMBERLAND COUNTY PENNSYLVANIA Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA DOCKET NO: 14 -550 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Worthington Federal Bank F/K/A Franklin Security Bank, 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 19 Nottingham Drive, Mechanicsburg, PA 17050 Parcel No. 38 -19- 1621 -209: 1. Name and last known address of Owner(s) or Reputed Owner(s): Keith M. Convery 19 Nottingham Drive Mechanicsburg, PA 17050 2. Name and last known address of Defendant(s) in the judgment: Keith M. Convery 19 Nottingham Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Worthington Federal Bank F /K/A Franklin Security Bank c/o BSI Financial Services, Inc. 314 S. Franklin Street Titusville, PA 16354 F: \Clients \BSI Financial \Convery-263F FNMA \Writ package 4- 3- 14.wpd 4. Name and address of last recorded holder of every mortgage of record: Worthington Federal Bank F /K/A Franklin Security Bank c/o BSI Financial Services, Inc. 314 S. Franklin Street Titusville, PA 16354 Worthington Federal Bank F /K/A Franklin Security Bank 700 F. Airport Road, Huntsville, AL 35902 Franklin Security Bank, FSB 2809 S. Lynnhaven Road - Ste 200 Virginia Beach, VA 23452 GMAC Mortgage Corp. DBA DiTech.com 3200 Park Center Drive - Ste. 150 Costa Mesa, CA 92626 MERS P.O. Box 2026 Flint, MI 48501 -2026 MERS 1818 Library Street, Suite 300 Reston, VA 20190 -6280 5. Name and address of every other person who has any record lien on the property: None other. 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 F: \Clients \BSI Financial \Convery-263F FNMA \Writ package 4- 3- 14.wpd 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 H'tO RilTAR Y 2014 APR 23 P1.1 l2: 143 CUMBERLAND COUNTY PENNSYLVANIA 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 19 Nottingham Drive Mechanicsburg, PA 17050 Southfield Crossing 28 Warwick Road Mechsanicsburg, PA 17055 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: April 16, 2014 F: \Clients\BSI Financial \Convery-263F FNMA \Writ package 4- 3- 14.wpd R. . rd M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, 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 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 Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. Attorneys for Plaintiff r: ED_O..FFIC.E OF THE PROTHONOTART 214 APR 25 PM 12: 43 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14 -550 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN ADDRESSES I, Craig Oppenheimer, 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 Defendant herein is as follows: Defendant: Keith M. Convery 19 Nottingham Drive Mechanicsburg, PA 17050 Date: April 16, 2014 By: Richard -M. Squire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) 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 kdiskin@squirelaw.com coppenheimer@squirelaw.com F: \Clients\BSI Financial \Convery-263F FNMA \Writ package 4- 3- 14.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin 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 Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. Attorneys for Plaintiff FILED - OFFICE OF THE PROTHONO ='f 2OI!; APR 25 PM 12: 43 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14 -550 CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION OF NON - MILITARY SERVICE Craig Oppenheimer, 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 Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 2003, as amended. (b) that Defendant is over 18 years of age and resides at 19 Nottingham Dr, Mechanicsburg, PA 17050. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: April 16, 2014 B Richa d 1GI.- Squire, Esq. (PA I.D.# 04267) Kevin Diskin, Esq. (PA I.D.# 86727) % 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 kdiskin@squirelaw.com coppenheimer@squirelaw.com F: \Clients \BSI Financial \Convery-263F FNMA \Writ package 4- 3- 14.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin 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 Worthington Federal Bank F /K/A Franklin Security Bank PLAINTIFF, v. Attorneys for Plaintiff WED-OFFICE OF THE PROTHONOTARY 10Er; PR 25 Pry 12: i 3 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14 -550 Keith M. Convery 19 Nottingham Dr CIVIL ACTION Mechanicsburg, PA 17050 DEFENDANT. MORTGAGE FORECLOSURE CERTIFICATION Craig Oppenheimer, 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: 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: April 16, 2014 By: Richarf L Squire, Esq. (PA I.D.# 04267) y Kevin Diskin, Esq. (PA I.D.# 86727) VV 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 kdiskin @squirelaw.com coppenheimer@squirelaw.com Attorneys for Plaintiff 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 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff F1LED-OFFICE Cf: THE PROTHONOTARY 2011i APR 25 PH 12: 43 CUMBERLAND COUNTY PENNSYLVANIA Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, V. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Keith M. Convery 19 Nottingham Drive Mechanicsburg, PA 17050 Your house (real estate) at 19 Nottingham Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Cumberland County Sheriff Sale, on Wednesday. September 3, 2014 at 10:00 A.M., at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $140,693.64 plus interest to the sale date obtained by Worthington Federal Bank F/K/A Franklin Security Bank 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 Worthington Federal Bank F/K/A Franklin Security Bank, 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 Craig Oppenheimer, Esquire at (215) 886- 8790. F:\Clients\BSI Financial\Convery-263F FNMA\Writ package 4-3-14.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 SHERIFFS 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 FAClients\BSI Financial\Convery-263F FNMA\Writ package 4-3-14.wpd LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right -of -way line of Nottingham Drive at the northeastern corner of Lot No. 14 -A as shown on the hereinafter mentioned plan of lots; thence along Nottingham Drive by a curve having a radius of 175.00 feet an arc length of 33.67 feet to a point; thence South 08 degrees 01 minute 37 seconds East 19.47 feet to a point at the dividing line between Lot Nos. 14 -A and 14 -B; thence South 81 degrees 58 minutes 23 seconds West 110.00 feet to a point at the dividing line between Lot Nos. 14 -A and 23; thence along said line North 08 degrees 01 minute 37 seconds West 50.00 feet to a point; thence North 80 degrees 24 minutes 01 second East 106.81 feet to a point the place of beginning. CONTAINING 5,630.10 square feet. BEING Lot No. 14 -A, Major Final Subdivision Plan for Southfield Crossing (Phase Two), prepared by Hartman and Associates, Inc., Engineers and Surveyors, and recorded on September 24, 1993, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania; in Plan Book 66, Pages 131 -A, B, C, D, E and F. UNDER AND SUBJECT to restrictions appearing in Misc. Book 481, Page 1063, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, and as shown on the aforementioned plan. TOGETHER with all and singular the buildings, improvements, ways, woods , waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances to the same belonging or in anywise appertaining; and the reversion and reversions, remainder and remainders, rents, issues and profits thereof, and of every part and parcel thereof; AND ALSO all the estate, right, title, interest, use, possession, property, claim and demand, whatsoever of the Grantor both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with the appurtenances. TO HAVE AND TO HOLD all and singular the premises herein described together with the hereditaments and appurtenances unto the Grantees and to the Grantees' proper use and benefit forever. Known as 19 Nottingham Drive, Mechanicsburg, PA 17050 Parcel No. 38- 19- 1621 -209 Being the same premises which Fine Line Homes, Inc. granted and conveyed unto Keith M. Convery and Carol A. Convery by Deed dated June 5, 1998 and recorded June 9, 1998 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book 178, Page 995. Carol A. Convery departed this life on or about April 13, 2012, thereby vesting title in Keith M. Convery, her husband, by right of survivorship. F : \Clients\BS1 Financial \Convery-263F FNMA \Writ package 4- 3- 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 WORTHINGTON FEDERAL BANK f /k/a FRANKLIN SECURITY BANK Vs. NO 14 -550 Civil Term CIVIL ACTION — LAW KEITH M. CONVERY 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) SEE LEGAL DESCRIPTION (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: $140,693.64 L.L.: $.50 Interest from 4/15/13 to 9/3/14 @ $1.1.56 per diem -- $1,641.52 Atty's Comm: Atty Paid: $188.05 Plaintiff Paid: Date: 4/25/14 s. (Seal) Due Prothy: $2.25 Other Costs: 614.ceLI David D. Bu- 11, Prothonotary Deputy REQUESTING PARTY: Name: CRAIG OPPENHEIMER, ESQUIRE 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. 313264 Richard M. Squire & Associates, LLC Attorneys for Plaintiff 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 Telephone: 215-886-8790 Fax: 215-886-8791 Worthington Federal Bank F/K/A Franklin Security Bank, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 PLAINTIFF, DEFENDANT. -< COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW TERM DOCKET NO: 14-550 NOTICE OF POSTPONEMENT OF SHERIFF'S SALE TO: PROTHONOTARY OF CUMBERLAND COUNTY 1 Courthouse Square, Suite 100 Carlisle PA 17013-3387 The real property located at 19 Nottingham Dr, Mechanicsburg, PA 17050 previously scheduled to be sold at Sheriffs Sale on September 3, 2014 at 10:00 A.M. Cumberland County Courthouse, 1 Courthouse Square , Carlisle, PA 17013 HAS BEEN POSTPONED TO December 3, 2014 at 10:00 A.M. By: Date: August 29, 2014 Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris Scott, Esquire Attorneys for Plaintiff, Worthington Federal Bank F/K/A Franklin Security Bank 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 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Z C? Worthington Federal Bank F/K/A Franklin COURT OF COMMON PLEAS Security Bank, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050, DOCKET NO: 14-550 DEFENDANT. CERTIFICATION OF SERVICE I, Morris Scott, Esquire being counsel for Plaintiff, Worthington Federal Bank F/K/A Franklin Security Bank, 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 individual, by first-class mail, postage pre- paid: SHERIFF OF CUMBERLAND COUNTY 1 Courthouse Square Carlisle PA 17013-3387 Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 By: Date: August 29, 2014 Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris Scott, Esquire Attorneys for Plaintiff, Worthington Federal Bank F/K/A Franklin Security Bank -2- v \ Riobard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff tiutiru • FEDERAL NATIONAL MORTGAGE ASSOCIATION PLAINTIFF, V. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE Plaintiff, by its undersigned attorney, Morris Scott, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale was sent to every recorded lienor/lien creditor and every other interested party known as of the date of the filing of the Praecipe for Writ of Execution on the date(s) appearing on the Certificate(s) of Mailing, attached hereto as Exhibit "1." 2. Proof of service of the Notice of Sheriffs Sale is attached hereto as Exhibit "2." Service effectuated by Sheriff. VService effectuated by Private Process Server. Service effectuated per Court Order. Certificate of Service attached containing: Court Order; Posting Affidavit; and Mailing receipts. All:Notices were served within the time limits set forth by Pa. R.C.P. 3129. Richard M. Squire Associat Dated: 11 114 By: Richard M. Squire, Esq. (PA I.D.# 04267) Robert W. Cusick, Esq. (PA I.D. # 80193) Morris Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.corn rcusick@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Exhibi NAME AND ADDRESS OF SENDER PE OF MAIL HECK PPR Richard M. Squire & Associates 0 Registered Mall Registered Mall: Affix stamp here if Issued as certificate of mailing 115 West Avenue, Suite 104 LI insured or for additional copies of this bill. Jenkintown, PA 19046 0 COD ID With Postal Insurance 0 Certified Mail El Without Postal Insurance O Express Mail „,.--- us posTAGEs. FIR 06 1. 2. BSI -263F FNMA - Convery, Keith M. Proof of of Mailing LH Notice Regular Mall Tax Claim Bureau One Courthouse Square, Room 106 Carlisle, PA 17013-3339 Domestic Relations 062Suuuunig46 - • '•:' e V. '•-•31*(iNI'I''.* 13 North Hanover Street, P.O. Box 320 Carlisle Carlisle, PA 17013-3014 3. Pa Department of Revenue - - Bureau of Compliance P.O. Box 281230 /1);AS 11 I Harrisburg, PA 17128-1230 ' i • 4. Department of Public Welfare ;1_1 . Att: Legal Departmentw\..kat v ,t - . ' ro Health & Welfare Building s -,..9. P.O. Box 2675 Harrisburg, PA 17105-2675 -- 6 -. 0 V'.\ \s':•.'.- ' 5. Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Building, Room 432 Harrisburg, PA 17105-2675 6. Tenant/Occupant 19 Nottingham Dr Mechanicsburg, PA 17050 . 7. Worthington Federal Bank F/K/A Franklin Security Bank c/o BSI Financial Services, Inc. . 314 S. Franklin Street Titusville, PA 16354 8. Franklin Security Bank, FSB 2809 S. Lynnhaven Road - Ste 200 Virginia Beach, VA 23452 9. GMAC Mortgage Corp. DBA DiTech.com . 3200 Park Center Drive - Ste. 150 Costa Mesa, CA 92626 10, Southfield Crossing 28 Warwick Rd. Mechsanicsburg, PA 17055 The full declaration of value Is required on all domestic and international register maximum Indemnify payable for nonnegotiable documents under Express Mall reconstrucllon Insurance Is $50,000 per piece subject to a limit of $50,000 per o maximum indemnity payable on Express Mall merchandise insurance Is $500. Indemnity payable Is $25,000 for Registered Mail, $500 for COD end $500 for Ir handing charges apply only to Third- and Fourth-Gass parcels. Special deliver special handling service. URED, C.O.D., CERTIFIED, AND EXPRESS MAIL 3 NAME AND ADDRESS OF SENDER Richard M. Squire & Associates 115 West Avenue, Suite 104 Jenkintown, PA 19046 INDICATE TYPE OF MAI O Registered Mail 0 Insured O COD ❑ Certified Mail ❑ Ex.ress Mail CHECK APPROPIATE BLOCK FOR POSTMARK Registered Mail: AND DATE_OF RECEIPT Affix stamp here if issue_ 0 With Postal Insurance or for additional copies 1y o„ps 0 Without Postal Insurance $1.20 0 - US POSTAGE 062S0 068 3006 ' 19046 BSI -263F FNMA - Convery, Keith M. Proof of Mailing NOS Lienholders Regular Mail Silver spring Township Authority 5 Willow mill Park Road Suite 3 Mechanicsburg, PA 17050 Total Number of Pieces Received at Pos ce C'A 1 POSTMASTER, PER (Name of receiving employee) PS FORM 3�� g The full declaration of value is required on all domestic and international register maximum indemnity payable for nonnegotiable documents under Express reconstruction insurance is $50,000 per piece subject to a limit of $50,000 per o maximum indemnityp � Mail indemnity payables $25,000 for Registered on Express Mail Mail $500 forCOD rand eis f or handling charges apply only to Third- and Fourth -Class parcels. Special deliver FOR R special handling service. $500for Ir REGISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS MAIL Exhibit "2" Commonwealth of Pennsylvania. In the Court of Common Pleas of Cumberland County CASE NO.: 14-550 AFFIDAVIT OF SERVICE Worthington Federal Bank f/k/a Franklin Security Bank vs. Keith M. Convery Commonwealth of Pennsylvania County of Dauphin as. I, Timothy Hoot, a competent adult, being duly sworn according to law, depose and say that at 1:47 PM on 09/20/2014, I served Keith M. Convery at 74 Runyon Road, Hummelstown, PA 17036 in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Marie Convery, Mother. O Adult in charge of Defendant(s) residence who refused to give name and/or relationship. O Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. O an officer of said Defendant's company. O Other: a true and correct copy of Notice of Sheriff's Sale of Real Property issued in the above captioned matter. Description: Sex: Female — Age: 85 — Skin: White — Hair: Gray — Height: 5' 02" — „eight: 110 •to and subscr4bed efore me on ay of S'ep.riet...e-f--- , 20 Y PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Brittany Edci us, Notary Public Lower Paxton Township, Dauphin County My commission expires April 11, 2018 Law Firm: Richard M. Squire and Associates, LLC Address: One Jenkintown Station, 115 West Avenue, Suite 104, Jenkintown, PA, 19046 Telephone: (215) 886-8790 X Timothy Hoot Shinkowsky Investigations PO Box 126538 Harrisburg, PA 17112 (800) 276-0202 Atty File#: - Our File# 34314 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Worthington Mortgage vs. Keith Convert' Case Number 2014-550 SHERIFF'S RETURN OF SERVICE 06/20/2014 08:50 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 Nottingham Drive, Mechanicsburg, PA 17050, Cumberland County. 08/01/2014 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: Keith Convery, 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 19 Nottingham Drive, Mechanicsburg, PA 17055, property appears to be vacated, Total Utility Shut -Off Notice for effective date of 6/19/14 posted on door, defendant's mail is still delivered there. cab. SHERIFF COST: $1,167.54 SO ANSWERS, August 01, 2014 RNY R ANDERSON, SHERIFF ToluDsoft, Int. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff C THEfQ ffp ED -OFFICE 20/4 NOV 2/ 1:¢`x/9:49 CUI113ERLAD COUNTY FEDERAL NATIONAL MORTGAGE ASSOCIATION PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE Plaintiff, by its undersigned attorney, Morris Scott, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale was sent to every recorded lienor/lien creditor and every other interested party known as of the date of the filing of the Praecipe for Writ of Execution on the date(s) appearingon the Certificate(s) of Mailing, attached hereto as Exhibit "1." 2. Proof of service of the Notice of Sheriff's Sale is attached hereto as Exhibit "2." Service effectuated by Sheriff. , Service effectuated by Private Process Server. Service effectuated per Court Order. Certificate of Service attached containing: Court Order; Posting Affidavit; and Mailing receipts. . All Notices were served within the time limits set forth by Pa. R.C.P. 3129. Dated: ( I Richard M. Squi e & Associates, LLC By: /).V 11//0 Richard . quire, Esq. 'A . I .# 04267) Robert W. Cusick, Esq. (PA I.D. # 80193) 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 rcusick@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Exhibit "1" NAME AND ADDRESS OF SENDER CHECK APPROPIA7F RI Cl( Pt1112 PrISTMAPII AND nArr OF a=r=tcrr Richard M. Squire & Associates El Registered Mail . _ .. ,.. — r • •• •• • • Registered Mall: 'i • • /414 0 IA 11 •-•• maw' •-• • ism Iv • a la...W. IN I Affixstamp here if Issued as certificate of mailing 115 West Avenue, Suite 104 0 Insured ddltional copies of this bill. Jenkintown, PA 19046 0 COD 0 With Postal Insurance 0 Certified Mail 0 Without PostaInsurance .20 pOSTAGst 1.(162buk"....15046 2. BSI -263F FNMA - Convery, Keith M. Proof of Mailing LH Notice Regular Mali Tax Claim Bureau One Courthouse Square, Room 106 Carlisle, PA 17013-3339 Domestic Relations 1 ; • ....1 ••• -' 4,4 "•!..0:-. -•. 13 North Hanover Street, P.O. Box 320 Carlisle . Carlisle, PA 17013-3014 3. Pa Department of Revenue Bureau of Compliance P.O. Box 281230 . -. c•Isn Hantsburg, PA 17126-1230 .,- 4. Department of Public Welfare Att Legal Department 44-0, t i v4i . 0, -, Health & Welfare Building 0 P.O. Box 2675' Harris' burg, PA 17105-2675- 6 •L V4 5. Department of Public Welfare Bureau of Child Support Enforcemern Health & Welfare Building, Room 432 Harrisburg, PA 17105-2675 6. Tenant/Occupant 19 Nottingham Dr Mechanicsburg, PA 17050 • 7. Worthington Federal Bank F/K/A Franklin Security Bank c/o BSI Financial Services, inc. . 314 S. Franklin Street Titusville, PA 16354 Franklin Security Bank, FSB 2809 S. Lynnhaven Road - Ste 200 Virginia Beach, VA 23452 9. GMAC Mortgage Corp. DBA DiTech.com 3200 Park Center Drive - Sta. 150 Costa Mesa, CA 92626 10. Southfield Crossing 28 Warwick Rd. MechsanIcsburg, PA 17055 NAME AND ADDRESS OF SENDER INDICATE TYPE POSTMARK AND DATE OF RECEIPT Richard M. Squire & Associates 115 West Avenue, Suite 104 BSI -263F FNMA- Convery, Keith M, Proof of Mailing NOS Lienholders Regular Mail -----\ 0 Registered Mail 0 Insured Registered Mail: Affix stamp here if iss��= or for additional copies \ rf j :'"..-' . �,,— POSTMASTER, PER (Name of receiving employee) Jenkintown, PA 19046 PS FORM 3877 , i ` JIM*" 6.- CAD DCf_ic-rcor I IMC11DCll f� A rt f.CDT1CICi1 A \IIl cv ODCCG ■ A A11 0 COD 0 With Postal Insurance �� •�� • ❑ Certified Mail ❑Without Postal Insurance US POSTAGE FIRST-CLASS ❑ Express Mail 062S0006863006 g 19046 OEM 1. BSI -263F FNMA- Convery, Keith M, Proof of Mailing NOS Lienholders Regular Mail -----\ Silver spring Township Authority 5 Willow mill Park Road Suite 3 Mechanicsburg, PA 17050 _-t-.l:'` \ rf j Total Number of Pieces 1 Received at PO ..2 7 ,. - ��, ��~� ` 1.-• ice. a� -- POSTMASTER, PER (Name of receiving employee) The full declaration of value is required on all domestic and interna Tonal registe maximum Indemnity payable for nonnegotiable documents under Express Mail c reconstruction insurance Is $50,000 per piece subject to a Smit of $50,000 per a maximum Indemnity payable on Express Mali merchandise Insurance IS $500. . indemnity payable is $25.000 for Registered Mail, $500 for COD and $500 for Ir handling charges apply only to Third- and Fourth -Class parcels. Special deliver special handling service. PS FORM 3877 , i ` JIM*" 6.- CAD DCf_ic-rcor I IMC11DCll f� A rt f.CDT1CICi1 A \IIl cv ODCCG ■ A A11 ••\vv•\v V, V.V. , �l\••i 1VV, Exhibit "2" Commonwealth of Pennsylvania In the Court of Common Pleas of Cumberland County CASE NO.: 14-550 AFFIDAVIT OF SERVICE Worthington Federal Bank flkla Franklin Security Bank vs. Keith M. Convery Conmonweaith of Pennsylvania County of Dauphin as. I, Timothy Hoot, a competent adult, being duly sworn according to law, depose and say that at 1:47 PM on 09/2012014, I served Keith M. Convery at 74 Runyon Road, Hmnmelstown, PA 17036 in the manner described below: O Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Marie Convery, Mother. ❑ Adult in charge of Defendant(s) residence who refused to give name and/or relationship, ® Manager/Clerk of place of lodging in which Defendant(s) reside(s). O Agent or person in charge of Defendant's office or usual place of business. ❑ an officer of said Defendant's company. EJ Other: a true and correct copy of Notice of Sheriff's Sale of Real Property issued in the above captioned matter. Description: Sex: Female — Age: 85 — Skin: White — Hair: Gray — Height: 5' 02" — Weight: 110 Swor to and sit cr bed efore me on t day of Nle i-vt beer — , 20L NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL, SEAL Brittany Edcius, Notary Public Lower Paxton Township, Dauphin County My commission expires April 1, 2018 Law lirm: Richard M. Squire and Associates, LLC Address: One Jenkintown Station, 115 West Avenue, Suite 104, Jenkintown, PA, 19046 Telephone: (215) 886-8790 x Timothy Hoot 5hinkowsky Investigations PO Box 126538 Harrisburg, PA 17112 (800) 276-0202 Atty File#: Our File# 34314 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anders() Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor on►tcsoN rmt ruttl6RIFF Worthington Mortgage vs. Keith Convery Case Number 2014-550 SHERIFF'S RETURN OF SERVICE 06/20/2014 08:50 PM Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting. a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 Nottingham Drive, Mechanicsburg, PA 17050, Cumberland County. 08/01/2014 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: Keith Convery, 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 19 Nottingham Drive, Mechanicsburg, PA 17055, property appears to be vacated, Total Utility Shut=Off Notice for effective date of 6/19/14 posted on door, defendant's mall Is still delivered there. cab. SHERIFF COST: $1,187.54 SO ANSWERS, August 01, 2014 RONR ANDERSON, SHERIFF 1q 4ourily8ta Shortff. ToioosoR Inc. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE ENTRY OF APPEARANCE Kindly enter the appearance of Morris Scott, Esquire on behalf of the Plaintiff, Worthington Federal Bank F/K/A Franklin Security Bank, in the above -captioned matter. Dated: November 26, 2014 RICHARD M. S S RE & AS CVES, LLC BY: Aal Air 4Vi • c and M. quire, Esquire Morris Scott, Esquire Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE EMERGENCY MOTION TO POSTPONE SHERIFF'S SALE 1. Plaintiff is Worthington Federal Bank F/K/A Franklin Security Bank, the mortgagee on premises 19 Nottingham Dr, Mechanicsburg, PA 17050, owned by Defendant. 2. Plaintiff's action in mortgage foreclosure resulted in a default judgment entered by the Prothonotary. 3. Plaintiff filed its Writ of Execution and received a sheriff sale date of September 3, 2014. 4. The September 3, 2014 sale date was postponed to December 3, 2014, in order for Plaintiff to obtain service of the Notice of Sale upon Defendant, which service was successfully effected. 5. Plaintiff requests that the December 3, 2014 sale be postponed so that it can file the Required Certificate of Filing with regard to the postponement of the sale, within 15 days of the sale date. 6. Plaintiff is unable to sua sponte have the sale date postponed, as the next available sale date is beyond the 130 day time period within which Plaintiff as of right may postpone a sale. 7. There is no prejudice to Defendant if this Court grants Plaintiff's Motion, as it would extend the time of opportunity for Defendant to seek to resolve this matter prior to the sale. 8. There would no benefit to either party if the Court were to deny Plaintiff's Motion, and Plaintiff was forced to relist the property for another Sheriff's Sale, the result of which would be additional fees and costs, which would be passed on to the Defendants. 9. Plaintiff avers, pursuant to Cumberland County Rule 208.3(a)(2), that there has been no previous Order signed in this matter. WHEREFORE, Plaintiff, by its attorneys, moves this Honorable Court to postpone the December 3, 2014 Sheriff's Sale to the March 4, 2015 Sheriff's Sale. Date: November 26, 2014 Respectfully submitted, Richard M. Squire & Associates, LLC BY: Morris A. Scott #83587 Attorney for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. Keith M. Convery DOCKET NO. 14-550 19 Nottingham Dr Mechanicsburg, PA 17050 CIVIL ACTION DEFENDANT MORTGAGE FORECLOSURE VERIFICATION Morris A. Scott, Esquire, hereby states that he is one of the attorneys for the Plaintiff, a corporation, unless designated otherwise; that he is authorized to make this Verification; that the statements made in the foregoing Motion to Postpone Sale are true and correct to the best of his knowledge, information and belief The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: RICHARD M. S 4 U RE & ASSOCIi ES LLC ( By: 41 fit Rich. . q ire, Esq. P .D.# 04267) -7 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 mscott@squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, MORRIS A. SCOTT, ESQUIRE, attorney for the within Plaintiff, hereby certify that a true and correct copy of Plaintiffs Motion to Postpone Sheriff's Sale, Memorandum of Law, Proposed Order, and Notice of Presentation, was mailed to the Defendants at: Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 By overnight mail postage prepaid mail on November 26, 2014. Respectfully submitted, Richard M. Squire & Associates, LLC Date: November 26, 2014 BY: Morris A. Scott #83587 Attorney for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S EMERGENCY MOTION TO POSTPONE SHERIFF'S SALE Matter Before the Court: The matter before the Court is Plaintiff's Emergency Motion To Postpone Sheriff Sale. Statement of Question Involved: Where Plaintiff seeks to postpone the Sheriff Sale in order to file a Certificate of Filing, and where the postponement would cause no prejudice to Defendant, should Plaintiff's Motion to Postpone Sheriff Sale be granted? Suggested Answer: Yes. Facts: Plaintiff is Worthington Federal Bank F/K/A Franklin Security Bank, the mortgagee on premises 19 Nottingham Dr, Mechanicsburg, PA 17050, owned by Defendant. Plaintiff's action in mortgage foreclosure resulted in a default judgment entered by the Prothonotary. Plaintiff filed its Writ of Execution and received a sheriff sale date of September 3, 2014. The September 3, 2014 sale date was postponed to December 3, 2014, in order for Plaintiff to obtain service of the Notice of Sale upon Defendant, which service was successfully effected. Argument: Pa.R.C.P. 3129.3(b)(2) provides that: (b)(2)(i) When the sale is stayed, continued, postponed or adjourned as provided by subdivision (b)(1), the plaintiff shall file (A) a notice of the date of continued sheriff s sale with the prothonotary at least fifteen days before the continued sale date, and (B) a certificate of filing with the sheriff confirming the filing of the notice of the date of continued sheriff's sale with the prothonotary. The sheriff shall continue the sale to the next available sale date if the notice of the date of continued sheriff's sale has not been timely filed. This continuance imposes a new obligation on the plaintiff to meet the requirements described in (b)(2)(i)(A) and (B). (ii) Non-compliance with this subdivision is not a basis for setting aside the sheriff's sale unless raised prior to the delivery of the sheriff's deed. The sale shall be set aside only upon a showing of prejudice. Plaintiff requests that the December 3, 2014 sale be postponed so that it can file the Required Certificate of Filing with regard to the postponement of the sale, within 15 days of the sale date. Plaintiff is unable sua sponte to have the sale date postponed, as the next available sale date is beyond the 130 day time period within which Plaintiff as of right may postpone a sale. There is no prejudice to Defendant if this Court grants Plaintiff's Motion, as it would extend the time of opportunity for Defendant to seek to resolve this matter prior to the sale. There would no benefit to either party if the Court were to deny Plaintiff's Motion, and Plaintiff was forced to relist the property for another Sheriff s Sale, the result of which would be additional fees and costs, which would be passed on to the Defendants. Relief: WHEREFORE, Plaintiff, by its attorneys, moves this Honorable Court to postpone the December 3, 2014 Sheriff's Sale to the March 4, 2015 Sheriff's Sale. Respectfully submitted, RICHARD M. SQ IRE & ASS 3 CIA ES, LLC Date: n)zH/lµ By: ich. i r. quire, Esq. (PA I. .# 04267) V Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquireAsquirel aw.com mscott(&,squirelaw. com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF PRESENTATION To: Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 Please take notice that the following Motion: lPlaintiff's Motion Emergency Motion to Postpone Sheriff Sale o Defendant's Motion will be presented to the Court on Monday, December 1, 2014, at 10 AM, in at the Court of Common Pleas of Cumberland County, at the office of Court Administration. A copy of the Motion is attached. Date: November 26, 2014 Respectfully submitted, Richard M. Squire & Associates, L C BY: "41_1 Morns A. Scott #83587 Attorney for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. Attorneys for Plaintiff 61, ?1 v /jt, CUr I"Er`i , ) comry pEivsv,4111q IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR SUBSTITUTION OF PARTIES UNDER Pa. R.C.P. 2352(a) TO THE PROTHONOTARY: Kindly substitute FEDERAL NATIONAL MORTGAGE ASSOCIATION, as Plaintiff, in the above -captioned matter for all purposes in connection with the above - captioned matter. The basis for this substitution is the praecipe to mark judgment to the use of FEDERAL NATIONAL MORTGAGE ASSOCIATION, filed contemporaneously herewith. The address of Federal National Mortgage Association is: P.O. Box 650043 Dallas, TX 75265. Dated: November 1 7 , 2014 RICHARD M. SQUIRE & ASSOCIATES, LLC BY: orris A. Scott, Esquire Attorney for Plaintiff ani, qsz1 ('ILS Co -V 3a-1a� �.'#- 311 DSO Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. 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 Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANT. CERTIFICATE OF SERVICE I, 11 Q r r;,s A S. f';Esquire, hereby certify that, on this date, I served or caused to be served a true and correct copy of the foregoing PRAECIPE FOR SUBSTITUTION OF PARTIES UNDER Pa. R.C.P. 2352(a) and PRAECIPE FOR ENTRY OF APPEARANCE upon the following person via regular mail, postage prepaid: Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 Dated: November 17, 2014 RICHARD M. SQUIRE & ASSOCIATES, LLC BY: Morris A. Scott, Esquire Attorney for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire 1D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT. 2C 14 DEC - I hhl I I 0 I CUi'' iJLCL!-i I:0 COUNTY PENNSYLVANIA. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE TO MARK JUDGMENT TO THE USE OF FEDERAL NATIONAL MORTGAGE ASSOCIATION TO THE PROTHONOTARY: Kindly mark the judgment in this matter obtained by First Bank of Richmond, to the use of Federal National Mortgage Association. Richard M. Squi e By: Date: November 17, 2014 & Associ , tes, LL a orris .S co , squire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank • PLAINTIFF, v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, MOtri'S A . ,soie - Esquire, hereby certify that, on this date, I served or caused to be served a true and correct copy of the foregoing Plaintiff's PRAECIPE TO MARK JUDGMENT TO THE USE OF FEDERAL NATIONAL MORTGAGE ASSOCIATION upon the following persons via regular mail, postage paid: Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 Date: November , 2014 Richard By: Morris A. Scott, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215)886-8790 Attorneys for Plaintiff Worthington Federal Bank F/K/A Franklin Security Bank PLAINTIFF v. Keith M. Convery 19 Nottingham Dr Mechanicsburg, PA 17050 DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 14-550 CIVIL ACTION MORTGAGE FORECLOSURE ORDER r -J rrl r Y GJ AND NOW, this G9') day oax:/1'10 , 2014, upon consideration of Plaintiffs Motion to Postpone Sheriffs Sale it is hereby ORDERED AND DECREED that the Sheriff's Sale of the above property is postponed to the March 4, 2015 Sale without the need for further advertising or notice. Cop 1122ILL 14+4 /eat a 9c - Kms` ��flcy &Pit! I J. Distribution List: Rule 208.3(a)(6) Richard M. Squire & Associates, LLC 115 West Avenue, Suite 104 Jenkintown, PA 19046 Morris A. Scott, Esquire Keith M. Convery, Pro Se 19 Nottingham Dr Mechanicsburg, PA 17050