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HomeMy WebLinkAbout14-1603 S Supreme Court of Pennsylvania Court of Common Pleas ForProthonotarp t'seOntp: Civil Cover Sheet Docket No: a'ivd Cumberland County I4 -1603 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadiW or other papers as required bylaw or rules of court. S Commencement of Action: E x Complaint ❑ Writ of Summons o Petition C ❑ Transfer from Another Jurisdiction o Declaration of Takin Lead Plaintiff's Name: NATIONWIDE ADVANTAGE Lead Defendant's Name: WILLIAM C. WASHINGTON, SR. T MORTGAGE COMPANY AND BECKY S. WASHINGTON I O N Are money damages requested? : ❑ Yes X No Dollar Amount Requested: within arbitration limits A Check one outside arbitration limits Is this a Class Action Suit? Do Yes ❑X No Is this an MDJA eal? o Yes ❑X No Name of Plaintiff/Appellant's Attorney: Martha Von Rosenstiel, Esq. o Check here if you are a Self-Represented (Pro Se ) Litigant Nature of the Case Place an "X" to the left of the ONE case category that tuost accurately describes your PRLIVARY 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 (donor tneludeJudgmenty CIVIL APPEALS ❑ Iutenntional ❑ Buyer Plaintiff Adininistrative Agencies Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment 0 Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation Premises Liability _. Statutory Appeal: Other S ❑ Product Liability (does not inch&e mass ford) ❑ Ennployunent Dispute: E ❑ Slander /Libel; Defamation Discrimination C El Otha- Employment Dispute: Other ❑Zoning Board ❑ other: T I ❑ Other: O INIASS TORT Asbestos N ❑ Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOL S Toxic Waste ❑ Ejectment ❑ Connnon Latin /Statutory Arbitration B Other: El min Eent. Dontain'Coudenuuttion ❑ Declaratory Judgment ❑ Ground Rent Mandamus Landlordrfenant.Dispute 8 Non- Domestic Relations ❑x Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ mort¢age Foreclosure: Conunnercial ❑ Quo Warranto El Dantal ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Otlren- El Medical ❑ Other: Other Professional: - µ Updated 1/1/:'011 1 {ac k °;�.0 art=. tA1`�' MARTHA E. VON ROSENSTIEL, P.C. s 30702CFC -MS Martha E. Von Rosenstiel, Esquire / No. 52634' Ami 1 Heather Riloff, Esquire / No. 309906 C U IME'JERLF C0UNTY 649 South Avenue, Suite 7 i -T S Y>_VA 1' I A Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391 -2009 - Plaintiff V. NO. 1 - W a i vitTem WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 3 Prickley Pear Drive Carlisle, PA 17013 Defendants CIVIL ACTION — MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le ban demandado a usted en la torte. Si usted quiere defenderse de set forth in the following pages, you must take action within twenty estas demandas expuestas en las paginas siguientes, usted tiene (20) days after this complaint and notice are served, by entering a veinte (20) dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la corte en forma escrita sus You are warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende, la corte toma ra medidas y further notice for any money claimed in the complaint or for any other puede continuar la demanda en contra suya sin previo aviso o claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas, la corte puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER -AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW. THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A WITH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO, LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 fly`/ 717- 249 -3166 03.`75 P p 800 - 990 -9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE 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. MARTHA E. VON ROSENSTIEL, P.C. 30702CFC -MS Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391 -2009 Plaintiff V. NO. 1 WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 3 Prickley Pear Drive Carlisle, PA 17013 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Nationwide Advantage Mortgage Company, a corporation organized and existing under state law, with offices for the conduct of business at 1100 Locust St., Dept. 2009, Des Moines, IA 50391 -2009. 2. Defendants, William C. Washington, Sr. and Becky S. Washington are the mortgagors and real owners of premises Lot 9 Prickly Pear Drive, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Mortgage Electronic Registration Systems as a nominee for American Home Bank, NA on October 28, 2004, which mortgage was recorded on November 1, 2004 in the Office of the Recorder of Deeds of Cumberland County in Mortgage 1886, page 1314, secured on premises Lot 9 Prickly Pear Drive, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The loan was then modified by American Home Bank, N.A., on October 17, 2005 and it was recorded on December 9, 2005 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 723, Page 887. 5. The mortgage was then assigned to Nationwide Advantage Mortgage Company by written assignment dated March 16, 2009 and recorded on April 23, 2009 in the Office of the Recorder of Deeds of Cumberland County in Mortgage 200912826. 6. The loan was then modified by Nationwide Advantage Mortgage Company, on October 9, 2010 and it was recorded on October 21, 2010 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No 201030251. 6. Plaintiff alleges.each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from March 2012 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 267,017.29 Interest from 4/1/2012 to 2/12/2014 at $14.63 per diem $ 9,980.86 Accrued late charges $ 209.80 Accrued Escrow deficit $ 12,982.28 Attorney's Fee $ 1,300.00 NSF Fee $ 20.00 Property Inspection Fee $ 304.00 Sheriffs Fee $ 1,500.00 Foreclosure Attorney $ 1,540.01 Paid Foreclosure Fees and Costs $ $1,448.31 Deferred Amounts $ $25,500.00 Total $ 321,802.55 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $ 321,802.55, plus per diem interest at $14.63 from February 13, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff ti VERIFICATION Karla K Neel hereby states that he /she is the Associate Vice President of Nationwide Advantage Mortgage Company, plaintiff herein; that he /she is duly authorized to make this Verification on behalf of Nationwide Advantage Mortgage Company and verifies that the statements made in the foregoing Complaint in Nationwide Advantage Mortgage Company v. William C. Washington, Sr. and Becky S. Washington relating to the property located at Lot 9 Prickly Pear Drive, Carlisle, PA 17013 are true and correct to the best of his /her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. f r 1 I W1 Vatio n T iyt:A s ciate Vice P r es i d ent wide Advantage Mortgage Company Dated: March 6, 2014 N EXHIBIT I r LEGAL DESCRIPTION ALL THAT CERTAIN unimproved tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, being more fully bounded and described according to a Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57, as follows: BEGINNING at a point along the northern side of a 50.00 foot right -of -way known as Prickly Pear Drive at the dividing line between Lots Nos. 8 and 9 of the hereinafter mentioned subdivision plan, thence continuing along said dividing line, North 46 degrees 45 minutes 43 seconds West, a distance of 133.71 feet to a point along the dividing line between Lots Nos. 9 and R2 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 04 degrees 31 minutes 27 seconds East, a distance of 52.73 feet to a point along the dividing line between Lots Nos. 9 and 11 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 61 degrees 08 minutes 11 seconds East, a distance of 110.42 feet to a point along the dividing line between Lots Nos. 9 and 10 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, South 28 degrees 51 minutes 49 seconds East, a distance of 174.00 feet to a point along the northern side of said Prickly Pear Drive; thence continuing along the northern side of said Prickly Pear Drive, South 61 degrees 08 minutes 11 seconds West, a distance of 56.81 feet to a point; thence continuing along same by a curve to the left, having a radius of 200.00 feet, an arc length of 47.78 feet, with a chord bearing of South 54 degrees 20 minutes 06 seconds West and a chord distance of 47.37 feet to a point along the northern side of said Prickly Pear Drive, the point and place of beginning. CONTAINING 0.51 acres and being Lot No. 9 of the Final Subdivision Plan for Phase I of Hillcrest Farms West Subdivision of the Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57. UNDER AND SUBJECT to the Declaration of Covenants, Reservations and Restrictions as recorded in Misc. Book 693, Page 333. ALSO UNDER AND SUBJECT to any restrictions, easements and right -of -ways as recorded in Plan Book 86, Page 57. EXHIBIT II .. .. .. .. .. ................. .... ...... .............. Natiomwfid.e 1, Advantage Mortgage V /I /& Se:11t Via Certified Nfa& 0 Of2y 0 1,2 7196 1006 989-S 930 BECKY S WASHINGTON 1�fffl 9 PRI(XLY PEAR DRIVE' , r � � � CARLISLF, I'A 1 Loan NumtbcT: llropertyAdth CARLISLE", VA 1701.3 'r Q FO R, tF, C 0 1 Dear BECKY S WASH NIGTO-IN: Mort- C , oll -p iriv (11 "NANk'") Oxmvci 0"! ter wk". kP- Tbe NIORTGAG& held by N;1(iOf1WiL IT ,a, or on yolly property toelated at i,(yr 9 PRJCKLY PEAR DRIVE £':111 -ISLE., PA 17013 IS IN SHRIOU'S DEFAULT because ym have ",(-,L the monthly pa�mcnt (s) aild ( t()T' Olt' qjollijis ol'03101/201.2 t 04W)/2012 il-s f S Next payinent Due D. 43!41.1; 412 Dtic: $3�186,00 SA 1. 96 Late C"llar""es. S20-00 Other Charges: Uncollected NSF Fees: S0'00 Offier Fees: WOO (',orporate Advance Bahmce: SOO) Attorney I'Qcs: inspection Fees: Unapplied Balance: ($0,00 - ro"rAl, YOU MUST 1 CURE DEFAULT S3,207.96 F '. The total -Olno""L 110 %v re tl) 4,me (h d ir, ellault, or in k) tIjer 6yt)r( 1 C��.JkIL� n lt 1111 � your aymerag, as of c i a te oftl1i.s letter, is S3,207.9 euxe this defimlt within THIRTY (30) DAYS of tt C elate o later, by p ying. us tile ol'$3,207.9 Olis any nctcli tional monthly payluentsand Iatt: i , v j ) i c j j rrsjy due during this peri(KI 91 92_'9'J 9 1 i 'i aniolult due inim" i t nit the t,oj;3I StgnKSMA ge Company Advantage rvlorqgage Company N Advat P,0, Bux740850 I I()() T .00tI gt St., Dept. 2009 C,W C)" 45274-0850 Deb I,, IA 50391-2009 i (it) not cure the dCfault within THIRTY (30) DAYS, ate i nt,d to exerc (gir rjg�.it to accelerate &I at A - ver is Owed Lan the original arnol"It borro-k;ved will tie couskkred (!lie gage pay Thi� rnearls A, 0ate lnorte',, . . y ents. 311 the original av-Irtg�lge in rrwiltlily iustlilln If [lill imi Wid Yolt rnay lose the chance to pay t. 11 1 t7" 1 11�. .111111t i nkt ITI;i( within VHlR.1:Y (30) DAYS, wu ILIM it )ti,110A ts) ill- 1 'ed �our ;ii Of t. , n o f (it' If (lie ,,, , w to taut lose y our ;ijtor our mort ase to ou'. attovncys, but you property wrial be Sold by the Sheriff 1:0 pay offthe Mo, ( I c bt. if we refer your ': -till have to Pay the reaswrtable 't All 7,411 (. the ( j e �, i ttlt b-forc they bogin Ien gs agains you, YU W McOcecclij to S5= it' legal proco-eding" -are startcd you. you wi �1 Ile UP -ne-Vs fiecs Vvill be a4.1&d to Uol n I ty ijr - er S attorney s f Qcs �,- they are ov 50 Ally to , p the reason.ablL vou cue the det1th withn Te birty day wl,iat.,Lnier you owe. ll,, which clay also hwhoe ow 1 y ;i(torney's 1'ecs. Imm Non w ol m)t be raydred to pa. We na a - Ile y(lu perg) ,. j I l Ily Cur talc. talc. un-paid principal balance tuld i11 Other sun's k'll " Lldcr Ole 11 1 in the thirty day IWX i0d Mlci i`oreclosure pr hal ve begiltlt Y vita "have -'lot cured the d("filult )Arifll t o ne ],our before (Ile Sheril'i" have the right t<) care s 'I c"I axgt� i the derault and p w sa at any thne up lie unpaid jjjl)jI payments PIM - 11 Y late ,,k, y may do so b paying the total 111 of t as o'l-ney" loos 1.1nd cost �l Courlectell, :viii Ole sale ';uld perl'om., . thorew-ilable att requirelnelits undel the 'Tiorqylg7e)_ held would bc 3PProxil 4 "x t h e earliest - a k�. it i C -Qti.giated that ; k (latc that �iicb a ShedWs s me coWd be eli to y bef re t - I A rl yk e of Me date of the Sheriff salt vMl be s oil o he S rnonths frorn the date Of At " Q Ole 4Il7K)tkt3t net to c u r e the ( - lefault vNill increase the longar you wait. You Inay find out at any h ti exactly what the reqiked payrtielit will be by calling; us at (800) 356-3442, I'l- payincrit muSt. be it] -lolley a rder and.inade payable to i's It the Lid( cashier's ciler Ir L-, iqated above, you s . I � I ' l l ted check Or n X Id your to 1-en aul 11i It ' rul li z -e that a SI sa %N ill end yo ur ownership of be inortgLlged property I'M u after tile Slcrir�,,s sale, ;j I. u h could he sw:ru�d to evict y o you continue to Ii"C in the Property 0 , protect your interest in the propery HAVE RIGHT _I ON 211- You have adlitioll'al rights to help _tfl_ OR TO BORL�0\\* THE PROPERTY ro OBTA.IN :M0 N p _y TO PAY OFF Tlff-, 1 % t T(;AGE , DE 131N,C, INSTURFrION T(.) PAY OFF IIS 1.0,13T (YO IIANI�- t` 13.t .L%1.()N1 pROM AN(yFHER LE�N JT V(.) T1.1i., T1VjOtZ L) , I , (i t N(.'. j j:... TO A THE Rjour 11) SEIJ OR 'TRANSFER THE PROPERTY 0 IVILL ASSUME THIS MORTGAGE DEB, pROVIDED WAT AW BUYER OR TFUkNSFHREE WI R FEES AN13 cons -kRf_ PAID THE OUTSTANRNNG PAWEN'TS, CHARGI..'.S AND 10 OTHER REqUIREMENTS LNDER THE N'10K 10R J OR. AJ."If I SALF,� AND THAT 11 1:1 PIZ ), ("ONTMA' IjS .I,() RICA " ARE SATISFWI Y — - 1 - URD PARTIr' NQGHT EXIST. YOU HAVE THERIGHT 1: HAVE THIS DEFAIALT C(JR1J) 13Y ANY T1 ACJING ON BERAL.•. t gaj ()Sitioll as if no d had ge �krijj be r io be same P If you cure the d(�fault� the mor our tIef �! dar to this right to cure v, ault inure tb;ui three tir'WS ill UtTlY cal n yea r. ACCOUN CX NXMC OVIM c"stur a IF YOU ARE, UNABLE :I "(.) BRING Y01JR F , C scrv are provid I reso lve delinquencies and avoid FORECLOS(JRE'. , & a I programs desig;Iled to help Ifyot1wouldl without cost to our Cus y t)n j -,xiy be eligible f5ol -Mit (8 66) 3504884� v tO ntact the boss Mitigation DepiOn to learn imne dbmt We PTOP yo , .Ry M - 530 PNI E"astc-n "'"'tandard Tij WF AK,' VE (N ,& tbr(.)u, Fri(Vly SAO AIN ,kSSIVING VOI'L r tmw 706 9W6 9"S 9 n 9 NP 2 0 3, jen CSCRA and , dents 1 iLttentigm Service'lleMbers 11)(1 del for y0j], incill(ling fc kinder mo co state laws provide if"POM"t protections 'ervice, C)j flare b within the lust nine 0) a ths, A.W. if you are ClIrrelltly ill the 1 Y M k Instrument now Ill (Ief please notify NM C i.tTunediately. W I joined after sig"irig the Note aad SW Ilos ifive p roo . f as lo V(mr 11 �Lqlus. contacting the NANIC a;., to Your ml ary service, ymi {-last provid you do not provide N information, it will be assumed that YOU are 1101 entitler to - "' tl ' Aul. N , L "lle— thure are goverlljyle�jlt approved hoaie(A "nership K yj)tjr b and as;sista r counse ling agencie's, please C.afl. to help honxvivlleni avoid losing their holl. 'To list o f a pp (I You ITUIN also Contact the �69-428*7 Or I'llis mutter Is vcl 1.113 ptikrtjjjt. V [ease ive it o ur i-mmed i ate a (ter) tlon. ' Sincerely, w j ( j Co� c Adv� — 1.100 L ocus t S treet, Mp t, 2 (:09 IA 5 (soo) 356- FEDERAL LAW REQUrRES tJS J ADVISE Yok. fl-tAf NIA.110NWIDE A.,DVANrA(.X rVIOR'FGAGf; A DF13f. ANY ( Ja.N A DEBT COLLECTOR �NN' 'Yo[!R. (_)j.JL,K;A'H0N - FA11 US PURPOSE. TO riff" I _ fNFORNCATION' 013 NED MA PE U I'OR S I'AYANN A BANKIZ-1- PICY PROCEI 41 ftt' All I)ISCHARGED OR IS SL' JEC 11 -)IMM� f-.*.sw2r A I AND Ff' DO 1Y V-ffs NO ['1CF.", JS f )NiALPURP0SFS0JN �NS y( OBLIGA'T1( N� PAYNIEN I' OR AN A-1 TO CoL[,FC'I' AN 7 . - ti AT*I'ORNF�,Y, I PROVIDCW WIM ME AIJORNI.A's NjMlvil A L Y0 ARE, RjyRE VW A SS A -40NF NUMM PA \C T& a tt x '006 Nationwide Advantage Martgage sent, Via ("ertif led Mail ov22IN2 7196 IM6 905 9928 603. W I UJAM W A' MENGTON SK � jtT � 3 PRXXLY PEAR M I CARLISIJF� PA 170B-8546 Y-V) lxia-ri Nitniber: 40000 yj DRIVIE� property AMesc LOT 9 pRWK.I Y) j CARUSLnPA IMU - �F N10g[GAC j"I If 1F (0 uRn CIL A x y S WILLIAM C WASHIN(i'mN R: 'n-,e ;AORMAGH beld by Mathnwide,Mmug, Nj, ngagc Company pain aVNANK7Yha6WAm or mu s) on your pj- tocatodut: LOT 9 PRWKLY PEAR DRIME CARLBLI PA 1WH3 Is IN SsRKMS WMAL'IF you 'Nave a- ,lk.11 ptlyll and other (.)f'04/0 throti gh OS� V2012 as RAWS: Ne .t Paynx-ilt DIc 111te: 0500012 • Total Monthly Payments Due: symoo Late MOO Other (7hx1'1, UIncollected *NS.F Fees', W011) Mer Wes: C Balance: Wo Atto F rticy ­cc S: k OO Inspection I' e3: $Moo Unapplictl Balance: C 5A i3 Q i y0 Nt .jjjST pAy CjJRE DEYAULT: S3q4W92 t,(,)t;jj amourt.now required to cure U dc ()I• in 0111cT Nvol .(Is, gcl. caught ILP in, your paymunts, , g do Wuw, h 'x;3,249.9:2 You may ewe this ciefittilt within THIRTY (30) DAYS of the (IIAO Of t Icttc'-, by Inlying -us the abo anlounit of 3;1249.91 phisaily additional monthly paymmits and late charge(s) Which clay !"all due duriclg p! krm 746 9W6 9W9 W 641 a3 Measc renalt the total amount mIL ijamediatdy to: 5mmord No! �-11,soa 1�e (:ompany Pvlorttlaf Natiorwide Advuntai�'e Nationwide Ad gle Coml?i�-"Y 11()() J,ocn,�t St,, inept. 2009 P.O. 11ox 740850 [)es 14ohies, IA 50391 COW& OH 45274-0850 If you do not Me the defla.i.ilt within THIRTY 00 DAYS, we j to exercise Our right to lic(Ae"ile dre jne ThiS 117MMS 111MI WhatevC ed on t h e Ofiginal 31TIC11.111t bomow - will be considered Ate I . . .1r il; OvIr I 1ge payinenti. U& If hill Jose the c-hance W P�:iY () rf tile original iTiortgage in ril0l"HY ion iii and YO t i.s not imld-� within -1111IR l'Y (W) DAYS., we alSO intend to payin(NA o)f (lie a.mount of der"Alt, o d property. If the is l'ore your inortl �Ittorneys to ��tart a law !o ft)reclose your rnoruga g property will he .sold by the SuCliffto ly ( ,ff the W If we rele-r your C to our attoyileyij b�ut you P; - You. you will still have to pay th rea.�onahlbe bcgin lqtlal proccedirigs agaills , to MmIt be vt attorlwy's Iles, actually Kum? up to S50-W 1 lowevc-ir, if' legal proccedings arc s&U ag ou y Y ` u ' "' added to il they fire over Any attort Y's feet will he hme W py dw rMWAt "' ;""' k ' - i costi- I 1"YoU 01 N,h nmy a imjWe our . rV the det,Mlt %ViLhifl the thirty t"trY p."? ym"611 M)t be required to pay attorney's fi, We may ale() site you pasmamy Ar the unpaid prhicipal balmux and all Olersiktns due 1111der (he i md E(:)i��closure proce"Xia-g have beg you S60 yot h ave not cured the tie VAN" ( Ile thirty day Per'(-x' , a t any time up to om! hour bcfore the Sheriffs have the d ault and prevent (lie s4 - other 0jfar =. _,i t cure (lie def" - S Plus ably late m k sa l e , y mmy do so by POW he total axtiount (.W the unpaid monthly payincrit, ,,, ,, , QU , Me a u mm ys R%"md M conuectcol )'Ath file rand perto)r'jl ;Iny uncler the lncirtg�;qge). e that such a Sherill's SMe cOUld l held would be appro-iii Vi) It is estimated that the earliest (,at le. iminjils frorn the date or this notice. A notice of the date o f the Shed& sale xvill be smit to you be the e Sak tit' c()tjr1-,C the 11M)unt nmoled W ettr 1,1 olefault will i ncrea - wait. Y ,,c the longer you a . ou may find out at 1 MY Qn muma to at (800) 356-3442. This pay111ML must be 0 caih, ti[TIC exac tj- it t rcquired P�XYITI t will he by c . g y whL l ti) 11% ,. ti m ki r ms mated above. You sho check, certified check or stoney r_ij and made payab realize that a Sheriffs Sale will c]14LI y ownership of the 111ort,-kged proper an d y(:)tu 1 -i gilt to remain in it. If a t h e sj- sale, a I could be Mou, ted M cWt YOM y ou ccontinue to livt� in ( he Pr interest in th p YOU HAVE THE RIGHT TO SELL You have additional rights to help proWct 1 AY 01 114-1 MORTGAGE , t )! .- - 1 - 0 BORRO PROPIERTY TO OBTAIN -%T(:)NFY TO I 43T, M Y HAVIP, N ��4 TO PAY OFF THIS MONi�,Y FROM ANOTHER IA- DINCi INS'l ITU 140' A R.W.TI TO SELL OR, TRANSFER IME PROPERTY' SUBJEC17 TO BU,yj,R ()R,M,1vNSFEREE W•jO WILL A SSUME 111E Pv1.ORTGA(jB DEM'r.', PR0VID1.`.-',D:*rH.AT AIJ- THF, OU1 PAYME';'�FS, (...jj_AjZGj. AND AT - Y - IS FEE ,S AN D p j� , o R�j'O iC)R AT TI IE, S AL 1A F ND T1 1M.''I'll E, ou IE R R F;,QUIR.jjN N1'S UNDER THE NMO RTG ;A,61' ARE SAMMEDY CONTACT US 10 DUTERMNE UNDEI� 1tJEIAi ClIkCUNISTANCE'S TH71S RIGID smourEXISM Y -O j j jtj-1E3 R HAVE",T11IS DEFAMT CURED BY ANY 'I'l-11RD PARTY AC ON y(:)j BEHALF. If you cure the derault, the mor umve will. be restored to the sarrle pos as if n o default had occurred, However, yollaxe not chilled to this right to cure YOUr (Ict'atilt.1-nore than three (in.les ja my calendar ye-ir, [p y()U UN A131-F TO INUNG YOUIR ACCOUNT CURRI,NT, NANIC offers con.'sulner assist ri ce s ; avoid, FORECLOSU Fhese services are providol pro designed to help resolve delinfiltiencie the-roption. It'yom X wouldlikc , you ITLIY be e plan or o ,,Rh,,, c ost t oitjr jigible f or a 1 W0,K � 1 . c at (866) 350-884, , Mtact ti 1.()s� _) T1 r to learn i t se pro, , N--i itigation f i(ge about tile, grarns, you auri C 0 I'l, - n Standard Time, WE`, ARE VERY INTERESTED !N ,, •j1)11day t j- ; ,� o -, - 8:00 AN4 - 5:3 sto A 4 jj (;j 17 ASS19TING YOU VA ACT6 NP 2 51 iembers and dependents: Tht: Servic.i.mlombei (1vil Relief Act ( "SC -Mid Servicep t v I' , )ro iti roreciw;urt, under j7lost . Certain state laws p important prot".tions 0 , 1 ib C If Vol[ are CUITC1110Y in the military se -vice, or have been within the last n i l le (9) nioiwhi, AN1 i0irred after sigiiing the Note and S jr) now in default, please notify N ANIC imracoliatcly. WhOm - contacting the NAIVIC as to your military semce. You must Provide Positive proof as to y" mir f -Alita.-ry " 1 If You do not provide this iitfornmition, it will be P.,SgIini '0tec I ndef (13 11� ed 1h3t you are riot entitled to P above -mentioned Aut, For your benefit W'd assistance, there Uc (..1.0verl.umult approved h onjeo � vners j j ip ( , , C) U jj s t; jijjg j1u iicies dk,5ipncd - 3 avoid losing d obtain a list of apPrW c 14IScIlcie', p lea to help hormoNvix-1, icir hornes. To i lay aiso contau'l Che 1. 1K yvl I - I - Visit �hd'.ggy"o llsgL; I hihct�hgj- c tin, You J1 ,800, 569-4 ol jolneomiership Presav3tiotl FolMotatiods I lopc hotline at (88's "(.'his ruaucr is very isnporuaill. Pteasegive, it your inlavdiate atientioll. S n. f rely. DQpt, 2009 DciNloincs, I.A. 5 03$91-2 009 (8 '156-3442 - 1 - 0 ADVISE Y01-3 T IAT TACIE �MORTCJACE' R I W WE AD VX FEDERAL LAW REQUII -ES US 1.�VT 'I"IffS IS , '.N !.TTFrvtpj, r() A J)EFIT� ANY CO�NWANY IS A DEBT (�()1,LEC TOR AND Tf rN FORMA. I`ION- OBTAMED NIAY Br T. 4[ D-IE E-KFE YOUR o ,D y"OR THAT PURPOSE, TO' HAS BEEN DISCH�kRGED OR TS SUBJECT TOTHE NtTrGMIATIC STAY IN A BANKRI-4 FR0Cr -'S - I'( " - rF 'NI AND sF..S ( �M.A' AND D01.1 f 'U - A DI , rjqIS'N(YrICE IS FOR (NFORNTATIOINAL Pl-."RPO .), OR AN xFTENI PJ TO COLLECT ANA [NDFA 17 E.DNLESS AS Nl()IJR PIERSONAL, ()BIAGA ('10N. IT y()I3 kj RF',I [, N'rED iY AN eVfTC)R-NIN,- PLEAS). PWGVIDI US V Tilt" AlTDRN J N s N AN! F ADDIZE'SS Ij NIJMBFR. M. ACT6 IL96 itri. 1 2 9 13 9,312A FORM 1 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391 -2009 Plaintiff °�- VS. NO. I4 - 14c n 3 0,41, 1 Tam WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 3 Prickley Pear Drive Carlisle, PA 17013 -- Defendants NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE c� DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. t 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 Mid Penn Legal Services at (717)243 -4400 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 the 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 AN TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: March 11, 2014 ZJ Date ignature of Counsel for Plaintiff G,, FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket H _ 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: APPLICATI CUSTOMERIPRIMARY Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: _ Cell: Other: Email: # of people in household: How long? C Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? INFORMATI FINANCIAL 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 and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ if yes, provide names, location of court, case number & attorney: Asset Amount Owed: Value: Home: $ $ Other Real Estate: $ ____ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. _ Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 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 Support /Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [:] No ❑ if yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? 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: _ AUrHORIZArION 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 Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed FORM 3 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391 -2009 Plaintiff vs. NO. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 3 Prickley Pear Drive Carlisle, PA 17013 Defendants REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated _ 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that 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 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391 -2009 Plaintiff vs. NO. 12 WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 3 Prickley Pear Drive Carlisle, PA 17013 Defendants 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 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference 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 forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; 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. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY tor � "°w�°n� `* _^ ' OFF xsmTHE, HEW,: 204oR -_ 10 rU `�~— v,�c`�'^(��W\� p����Y '' .., �vr' Nationwide AdvantagoWortgageCompany va. WiUiamCharles Washington, Sr (et a|.) Case Number SHERIFF'S RIFF' S RETURrrN OF SERVICE �� 03/25/2014 08:07 PM - Dep sworn accord to law, served the requested quoah»d Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: William Charles Washington, Sr at Prickly Pear Drive, Lot Q. North Middleton Township, Carlisle, PA 17013.n/Wa3 Prickly Pear Drive, Carlisle, PA 17013. *Correct actually Uy part nf the physical address, but was part of the development plans. 03/25/2014 08:07 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be William Washington, husband, who accepted as "Adult Person in Charge" for Becky S. Washington at Prickly Pear Drive, Lot 9, North Middleton Township, Carlisle, PA17O13n/k/o3 Prickly Pear Drive, Carlisle, R417O13. *Correct address for this residence is 3 Prickly Pear Drive, (Lot 9) Carlisle, PA 17013. Lot 9 is not actually part cf the physical address, but was part of the development plans. SHERIFF COST: $5O.78 SO ANSWERS, ^ March 26, 2014 RDNNYR ANDERSON, SHERIFF • FORM 3 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF. COMPANY CUMBERLAND COUNTY, 1100 Locust St.,Dept. 2009 PENNSYLVANIA Des Moines,IA 50391-2009 r' Plaintiff 4} • vs. NO. ,20 1 — O/4 O3 WILLIAM C.WASHINGTON, SR.AND BECKY cp' - S.WASHINGTON —<›* --A _ 3 Prickley Pear Drive --1 -cc:3 asp. C.)-7'1 Carlisle,PA 17013 ice'-, Defendants ,. • REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated `�-�r. a� 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904k relating to unsworn falsification to authorities. �G�•-t i - /6 `f Signature of Oefen a Counsel/Appointed Date Legal Representative 4;1Z_ 6--/ //4 Signature of Defendant Date • s • Da, s 7ri Signature of Defendant 0 to NATIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1603 CIVIL WILLIAM C. WASHINGTON, SR. : and BECKY S. WASHINGTON, . Defendants: CASE MANAGEMENT ORDER AND NOW, this `0L1:41 day of May, 2014, the parties having agreed to 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 � //, AIN ,/ , at o2 00 `,p m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 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 forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; 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. /Martha Von Rosenstiel, Esquire 649 South Avenue, Unit 7 Secane, PA 19018 For the Plaintiff /Susan J. Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rlm BY THE COURT, C.? CD MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff #30702 MBCPG NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff vs. WILLIAM. C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendants : Case No: 14 -1603 -Civil PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECLOSURE To the Prothonotary: Kindly reinstate the Complaint in Mortgage Foreclosure in the above matter. MARTHA E. VON ROSENSTIEL, P. BY: DATED: June 3, 2014 Mart a E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Cow ot s11,75pd aid' o/1i& � )4/. cs( \_Service. for Professionals Incl 1,13&R; 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: (215) 985-0169 Nationwide Advantage Mortgage Company -vs- William C. Washington., et al COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: NAP5 National Association of Philadelphia Association Professional Process Servers of Professional Process Servers COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 14-1603 Civil Term AFFIDAVIT OF SERVICE B&R Control # Reference Number CS112333 -1 SERVICE INFORMATION On 14 day of April, 2014 we received the Mortgage Foreclosure Complaint for service upon William C. Washington at 12034 Chase Crossing Circle, Apt. 202 Rockville, MD 20852 ***Special Instructions *** nServed Date In the Time manner described below. Personally served. Adult family member. Relationship is Accepted By: Cr% Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age Other Height Weight Race Sex Not Served Date ,�L z.0 Time Not Served Informa on j Moved Unknown 2-fpn No Answer The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Servertattertir Law Firm Phone (610)328-2887 Fo Martha E. Von Rosenstiel, Esquire Martha E. Von Rosenstiel, P.C. 649 South Avenue Suite 7 Secane, PA 19018 Vacant Other ore me this dopy ServeBy D ".�� •.Filed Date 3/20 14 ORIGINAL 104DB 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: (215) 985-0169 Nationwide Advantage Mortgage Company -VS- William C. Washington., et al COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: NA P5 1,11411i National Association of Professional Process Servers Philadelphia Association of Professional Process Servers COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 14-1603 Civil Term AFFIDAVIT OF SERVICE B&R Control # Reference Number CS112333 - 2 SERVICE INFORMATION On 14 day of April, 2014 we received the Mortgage Foreclosure Complaint for service upon Becky S. Washington at 12034 Chase Crossing Circle, Apt. 202 Rockville, MD 20852 ***Special Instructions *** n Served Date Time In the manner described below. Personally served. Adult family member. Relationship is Accepted By: Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age Other Height Weight Race 'Sex Not Served Date 2-/ / Time 4, .721101 Not Served Information Il Moved Unknown Il The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Server/Slieriff—_� er No Answer Vacant Other Law Firm Phone (610)328-2887 Fo Martha E. Von Rosenstiel, Esquire Martha E. Von Rosenstiel, P.C. 649 South Avenue Suite 7 Secane, PA 19018 ••n •r.",' ServeB D. 5 Filed Date 3/20 2 ORIGINAL 104DB SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff "727 F Jody S Smith _ Chief Deputy ! ! Richard W Stewart f,, ,, Solicitor t P���, Nationwide Advantage Mortgage Company Case Number vs. William Charles Washington, Sr(et al.) 2014-1603 SHERIFF'S RETURN OF SERVICE 06/2312014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Becky S. Washington, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found"at 111 Race Street, South Middleton, Boiling Springs, PA 17007. Per the current tenants they recently moved into this address and have received some of the defendnats mail. Per the Boiling Springs Postmaster the defendant is not known at the address provided. SHERIFF COST: $39.78 SO ANSWERS, /12 June 23, 2014 RON R ANDERSON, SHERIFF NATIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1603 CIVIL WILLIAM C. WASHINGTON, SR. : and BECKY S. WASHINGTON, . Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / `'r s day of July, 2014, following conciliation conference, it appearing that there are documents outstanding for the plaintiff's review, by agreement of the parties, the plaintiff will identify the required documents which will be submitted by the defendants fourteen (14) days following their identification. Continued conciliation conference is set for Friday, September 19, 2014, at 2:45 p.m. in Chambers of the undersigned. BY THE COURT, 44 Kevin Hess, P.J. Martha Von Rosenstiel, Esquire 649 South Avenue, Unit 7 Secane, PA 19018 For the Plaintiff ✓usan J. Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rim 7/ Lin MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COMPANY Plaintiff VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendants 30702- CPG -MB (correct) COURT OF COMMON PLEAS Cumberland COUNTY : No: 14 -1603 -Civil PRAECIPE TO CORRECT c) TO THE PROTHONOTARY: Kindly mark the record to reflect that property address should be listed as Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013. It was incorrectly listed as Lot 9 Prickly Pear Drive, Carlisle, PA 17013 due to clerical error. Dated: August 4, 2014 MARTHA E. VON ROSENST ; L, P.C. BY: ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COMPANY PLAINTIFF VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS r-, f HE PRO rs ©1.NONoTA j ;#30702CMS-MB 2014 A US I1IIU CUMBERLAND Ul�BENL �, � PENNS YLVANIAUNry COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 14 -1603 -Civil MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Complaint and all subsequent notices upon Becky S. Washington by regular mail and certified mail at the last known address, Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 and by posting of the premises located at Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 (hereinafter "Subject Premises") and in support thereof avers the following: 1. The Plaintiff filed its Complaint in Mortgage Foreclosure against William C. Washington, Sr. and Becky S. Washington on or about March 20, 2014, for the Defendants' failure to make monthly mortgage payments from March 1, 2012 for the property located at Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 (hereinafter "Subject Premises"). 2 Plaintiff has been unable to complete service of its Complaint in Mortgage Foreclosure upon Becky S. Washington at the Subject Premises. Service was accepted at the Subject Premises by co-defendant, William C. Washington, Jr., however the co-defendants have a pending divorce and may not accept service for one another. The Sheriffs Return of Service is attached hereto made part hereof and marked as Exhibit A. 3. Plaintiff has been unable to complete service of its Complaint in Mortgage Foreclosure upon Becky S. Washington at two additional addresses provided by the Reasonable Investigation. The Sheriffs Return of Service and Process Server's Affidavit of Service is attached hereto made part hereof and marked as Exhibit B. 4. Pursuant to Pennsylvania Rules of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. 5. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefore is attached hereto, made part hereof, and marked as Exhibit C. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure and all subsequent notices by certified and regular mail at the last known address, Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 aby posting of the Subject Premises. MART. E. VON ROSENS EL, P.C. Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: August 6, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS #30702CMS-MB BRIEF IN SUPPORT OF ITS MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Complaint and all subsequent notices upon Becky S. Washington by regular mail and certified mail at the last known address, Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 and by posting of the premises located at Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 (hereinafter "Subject Premises") and in support thereof avers the following: I FACTS The Plaintiff filed its Complaint in Mortgage Foreclosure against William C. Washington, Sr. and Becky S. Washington on or about March 20, 2014, for the Defendants' failure to make monthly mortgage payments due March 1, 2012 for the property located at Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 (hereinafter "Subject Premises"). II ARGUMENT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: 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. The Court in Romeo v. Looks, 369 Pa. Super 608 (1982) stated that: Before resort to substituted service may be had, however, a plaintiff must have demonstrated a good faith effort to locate the Defendant through more direct means. Pa.R.C.P. 430 provides guidance as follows: An illustration of good faith effort to locate the Defendant includes (1) 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 of the Defendant and (3) examination of local telephone directories, voter registration records, local tax records, and motor vehicle records. See also Kittanning Coal Co., Inc. v. International Mining Co.,Inc. 551 F. Supp. 834 (1982), Romeo v. Looks, 369 Pa. Super 608 (1987). As set forth in the Sheriffs Return of Service and Process Server's Affidavit of Service, marked Exhibit A and B, the Sheriff and Process Server have been unable to serve the Complaint after several attempts. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit C. The Plaintiff submits that it has made a good faith effort to locate and serve the Defendant and has been unable to do so. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure and all subsequent notices by certified and regular mail at the last known address, Lot 9 ' ckly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 and by posting of the Subj; ct Premises. MARTHA E. VON ROSENSTIE , P.C. BY. Mr a E. Von Rosenstiel, squire Heather Riloff, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS #30702CMS-MB CERTIFICATE OF SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion for Special Service, Brief in support thereof, attached exhibits, and proposed Order in the above matter was made upon the following by regular first class mail, postage prepaid, deposited with the United States Postal Service on August 6, 2014: William C. Washington, Sr. and Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to dsworn falsification to authorities. MARTHA E. VON ROSENSTIE P.C. Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: August 6, 2014 #30702CMS-MB MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, verifies that she is the attorney for the Plaintiff in the foregoing action; that she familiar with the facts in this matter; and that the statements made in the foregoing Motion for Special Service are true and correct to the best of her information and belief. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: August 6, 2014 MARTHA E. VON ROSENST L, P.C. Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Qu�ItY et clutd„„,,, Richard W Stewart '• Solicitor orPi vY)4546kIFF Nationwide Advantage Mortgage Company Case Number vs. William Charles Washington, Sr (et at.) 2014-1603 SHERIFF'S RETURN OF SERVICE 03/25/2014 08:07 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wil: William Charles Washington, Sr at Prickly Pear Drive, Lot 9, North Middleton Township, Carlisle, PA 17013.n/k/a 3 Prickly Pear Drive, Carlisle, PA 17013, *Correct address for this residence is 3 Prickly Pear Drive, (Lot 9) Carlisle, PA 17013, Lot 9 is not actually part of the physical address, but was part of the development plans. RYAN BURGErT, 6 PUT 03/25/2014 08:07 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be William Washington, husband, who accepted as "Adult Person in Charge" for Becky S. Washington at Prickly Pear Drive, Lot 9, North Middleton Township, Carlisle, PA 17013 nik/a 3 Prickly Pear Drive, Carlisle, PA 17013. *Correct address for this residence is 3 Prickly Pear Drive, (Lot 9) Carlisle, PA 17013. Lot 9 is not actually part of the physical address, but was part of the development plans, SHERIFF COST: $50.78 March 26, 2014 fir,) t;vunlySullo Gtwrll, Taenson• I�u. RYAN BURGETT, SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 4grnGrrrly4 r :ECF, ., `;''E ° S 00-7/‘ Nationwide Advantage Mortgage Company Case Number vs, William Charles Washington. Sr (et at) Case SHERIFF'S RETURN OF SERVICE 06/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law,. states he made diligent search and inquiry for the within named Defendant to wit: Becky S. Washington, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 111 Race Street, South Middleton, Boiling Springs, PA 17007. Per the current tenants they recently moved into this address and have received some of the defendnats mail. Per the Boiling Springs Postmaster the defendant is not known at the address provided. SHERIFF COST: $39.76 June 23, 2014 CountySmte Scam€ rvec , € €s. SO ANSWERS, RON— R ANDERSON, SHERIFF EXHIBIT Services for Profess' nab hwy." 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 548.7400 FAX: (215) 985-0159 Nationwide Advantage Mortgage Company -VS- William C. Washington., et al • CASE NUMBER 14-1603 Civil Term AFFIDAVIT OF SERVICE Nerlone1AssacLlfortof Pht+adeWeeAuodauor, Professional Prams Servers al Professional Process Sene?tc COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: ***Special Instructions "'• 88R Control # Reference Number SERVICE INFORMATION CS112333 - 2 On 14 day of April, 2014 we received the Mortgage Foreclosure Complaint for service upon Becky S. Washington at 12034 Chase Crossing Circle, Apt. 202 Rockville, MD 20852 Served Date Time In the manner described below. Accepted By: Personally served. Adult family member. Relationship is Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age Other Not Served Date( /tt Time 6:21 Not Served Inform } , Moved Height Weight Race Unknown i No Answer Vacant E) Other w The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Servere—� ;.- Law Firm Phone (610)328-2887 Fo Martha E. Von Rosenstiel, Esquire Martha E. Von Rosenstiel, P.C. 649 South Avenue Suite 7 Secane, PA 19018 Sex ORIGINAL ServeB File Date 3/20 10408 AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 30702 Attorney Firm: MVR Subject: William C. Washington Sr, & Becky S. Washington Property Address: Possible Mailing Address: Lot 9 Prickly Pear Drive, Carlisle, PA 17013 (William C. Washington Sr.) 3 Prickley Pear Drive, Carlisle, PA 17013 (Becky S. Washington) 111 Race Street, Boiling Springs, PA 17007 I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct William C. Washington Sr. - 197-40-xxxx Becky S. Washington - 186-54-xxxx B. EMPLOYMENT SEARCH William C. Washington Sr. & Becky S. Washington - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that William C. Washington Sr. reside(s) at: 3 Prickly Pear Drive, Carlisle, PA 17013 & Becky S. Washington reside(s) at: 111 Race Street, Boiling Springs, PA 17007. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for William C. Washington Sr. & Becky S. Washington. B. On 07-02-14 our office made a telephone call to a possible phone number of the subject(s) (717) 241-2616 and received the following information: not in service. III. INQUIRY OF RELATIVES AND NEIGHBORS On 07-02-14 our office made a phone call in an attempt to contact Janette L. Washington, potential relative of William C. Washington Sr. & Becky S. Washington at (717) 249-1583, 929 North West Street; Carlisle, PA 17013: not in service. On 07-02-14 our office made a phone call in an attempt to contact Kristen J. Schuler, potential relative of William C. Washington Sr. & Becky S. Washington at (717) 249- 6011, 45 South East Street, Carlisle, PA 17013: not in service. On 07-02-14 our office made several phone calls in an attempt to contact Terdeli W. Washington, potential relative of William C. Washington Sr. & Becky S. Washington. at (717) 218-3833, 45 South East Street, Carlisle, PA 17013: answering machine. FtiXHIBIT u,�. On 07-02-14 our office made several phone calls in an attempt to contact Diana M. Hare (717) 609-1215,1 Prickly Pear Drive, Carlisle, PA 17013: answering machine. On 07-02-14 our office made a phone call in an attempt to contact Matthew G. Strickland (717) 249-8856,11 Prickly Pear Drive, Carlisle, P.A 17013: not in service.. On 07-02-14 our office made several phone calls in an attempt to contact David S. Miller (717) 258-5349,107 Race Street, Boiling Springs, PA 17007: answering machine. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 07-02-14 we reviewed the National Address database and found the following information: William C. Washington Sr. - 3 Prickly Pear Drive, Carlisle, PA 17013 & Becky S. Washington -111 Race Street, Boiling Springs, PA 17007. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: (William C. Washington Sr.) 3 Prickley Pear Drive, Carlisle, PA 17013 & (Becky S. Washington) 111 Race Street, Boiling Springs, PA 17007. V. OTHER INQUIRIES A. DEATH RECORDS As of 07-02-14 Vital Records and all public databases have no death record on file for William C. Washington Sr. & Becky S. Washington. VI. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH William C. Washington Sr. -11-1949 Becky S. Washington - 06-1962 B. A.K.A. Becky S. Kuhn Washington * Our accessible databases have been checked and cross-referenced for the above named individual(s). * Please be advised our database information indicates the subject resides at the current address. I 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. Scc. 4904 relating to unsworn falsification to authorities. 1 -4"J The above information is obtained from available public records and we are only liable for the cost of the affidavit. NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS ORDER GRANTING MOTION FOR SPECIAL SERVICE AND NOW, this /.3` day of /4„ f,v,✓ , 2014, upon consideration of Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Becky S. Washington by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail, no signature required, and regular, first class mail at the last known address, Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 and by posting the premises of Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013. r.3 r 1-- L7 C) CDJ C`7 < �- Ce) cD cr _, LLS wzr c UJ C-4 U MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff #30702 MBCPG NATIONWIDE ADVANTAGE MORTGAGE: COMPANY Plaintiff vs. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON OF THE PRO i NONC3 Ti lr,t 2014 AUG 22 NI CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY : Case No: 14 -1603 -Civil Defendants PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECLOSURE To the Prothonotary: Kindly reinstate the Complaint in Mortgage Foreclosure in the above matter. MARTHA E. VON ROSENSTIEL, BY: DATED: August 19, 2014 Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Um* I.1S pa 14,, e,L0y,177 I Fif 2ibmg a c 9 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff CUMBE„LAI@ COU," t,.. 30702 -MB CSV : COURT OF COMMON PLEAS NATIONWIDE ADVANTAGE MORTGAGE: CUMBERLAND COUNTY COMPANY Plaintiff vs. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant : CASE NO: 14 -1603 -Civil CERTIFICATION OF SERVICE Heather Riloff, Esquire, hereby certifies that she is the attorney for the plaintiff herein and that service of the Civil Action in Mortgage Foreclosure Complaint in the above matter was made upon Becky S. Washington, by certified mail and by regular mail, pursuant to Court Order on August 26, 2014. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: DATED: August 27, 2014 Martha E. Von Ros Heather Riloff, Esq Attorneys for Plainti Lfl r - m nJ ET' fLI ru rR N U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT (Domestic Mali Only; No insurance Coverage Provided) For delivery information visit our website at www.usps.come Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees PS Form 3800, August 2006 See Reverse for Instructions U.S. POSTAL SERVICE CERTIFICATE OF MAILIN MAY DE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D PROVIDE FOR INSIDI ANCE—POSTMAST Received From: MARTHA VON R 649 SOUTH UNIT 7 SECANE, PA 19018 c piece of ordinary mail addressed lo: Affix fee here in stamps Or meter postage and Pos1 mark. Inquire of Lo Carldf, , PA nor5 Wct9.9ion 1'S Form 3817, Mar.1989 1P 01738253 AUG 26 2014 AILED FROM Z PCODE 19018 _ $.11EY BOWES 001.300 JOIN_ Cf4<9 e 32-Yrif NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANTS ORDER GRANTING MOTION FOR SPECIAL SERVICE AND NOW, this J,3day o , 2014, upon consideration of Plaintiff's Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Becky S. Washington by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail, no signature required, and regular, first class mail at the last known address, Lot 9 Prickly Pear Drive a/kJa 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 and by posting the premises of Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013. OD BY THE COURT: Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 0CW T fvF;01•HOWJ 1 2'1/4114 SEP -9 t't1 26 ruMBERLANLVPO COUNT '11 PEINSYNIA 01 II 47,(01 OFF T:E OF E. •;R[FP Nationwide Advantage Mortgage Company vs. William Charles Washington, Sr (et al.) Case Number 2014-1603 SHERIFF'S RETURN OF SERVICE 08/29/2014 03:23 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Becky S. Washington, pursuant to Order of Court by "Posting" the premises located at 3 Prickly Pear Drive, North Middleton Township, Carlisle, PA 17013 with a true and correct copy according to law. SHERIFF COST: $40.78 SO ANSWERS, September 02, 2014 RONO R ANDERSON, SHERIFF fc) SountyS.ffito Sheriff, TelF;osoft, Inc. NATIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION : NO. 14-1603 CIVIL WILLIAM C. WASHINGTON, SR. : and BECKY S. WASHINGTON, : Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 17th day of September, 2014, on agreement of the parties, the conciliation is continued. The new date for the continued conciliation conference is set for Friday, October 17th, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Nathan C. Wolf, Esquire 10 W. High Street Carlisle, PA 17013 For the Plaintiff / rtha Von Rosenstiel, Esquire 649 South Avenue, Unit 7 Secane, PA 19018 For the Plaintiff Asan J. Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rlm 1 ES' PZ.4 l 1£rC 9 MAY Kevi A. Hess, P. NATIONWIDE ADVANTAGE IN THE COURT OF COMMON PLEAS OF MORTGAGE COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION NO. 14-1603 CIVIL WILLIAM C. WASHINGTON, SR. and BECKY S. WASHINGTON, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this �sday of October, 2014, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is lifted. BY THE COURT, b Com __ Kev' A. Hess, P.J. zP1 `") cn Nathan Wolf, Esquire r�-2 �- 10 West High Street �p- =C x �; Carlisle, PA 17013 For the Plaintiff_, Susan J. Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rlm I co p'X 5 �t: #30702CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff V. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON : NO. 14 -1603 -Civil Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: William C. Washington, Sr. and Becky S. Washington for want of an. answer. (X) Assess Damages as Follows Debt Interest from 02/13/2014 to 11/7/2014 At $$14.63 per diem $ 321,802.55 $ 3,921.13 Total $ 325,723.68 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 This (l day of Nov MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenotiel, Es;uire Heather Riloff, Esquirle Jeniece D. Davis, Esqui Attorneys for Plaintiff , 2014 judgment is eriferexd •in favor of the Plaintiff and against Defendant(s), William C. Washington, Sr. and Becky S. Washing •n by default for want of an answer and damages assessed at the sum of $325,723.68 as ificatio Prothofiota 1.e an Bounty per...� ostAA swt.sogt4i_ ‘. iakkso3is #30702CFJ-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff vs. : No: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. : WASHINGTON Defendant(S) NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, P.C. by the undersigned hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: November 07, 2014 Martha E. Von Rosenstiel, Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff v. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendants #30702CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14 -1603 -Civil TO: William C. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 10/27/14 Martha E. Von Heather Riloff, Jeniece D. Davis, ' quire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY • Plaintiff V. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendants #30702CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14 -1603 -Civil TO: Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 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, 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 SERV -ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 10/27/14 Martha E. Von Heather Riloff, Jeniece D. Davi Attorneys for Plai osenstiel, Esquire squir Es. e MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire/ No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff v. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant TO: William C. Washington 3 Prickly Pear Drive Carlisle, PA 17013 #30702CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14 -1603 -Civil 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, GO TO OR TELEPHONE THE OFFICE SET FORTH THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 10/27/14 Martha E. Von Heather Riloff, Jeniece D. Davis, sq Attorneys for Plaintiff ose sq el, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary William C. Washington, Sr. Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA17013 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANT(S) : NO: 14 -1603 -CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $325,723.68 on November 07, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary William C. Washington, Sr. 3 Prickley Pear Drive Carlisle, PA 17013 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANT(S) : NO: 14 -1603 -CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $325,723.68 on November 07, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA17013 David D. Buell, Prothonotary NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON DEFENDANT(S) : NO: 14 -1603 -CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $325,723.68 on November 07, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. Commonwealth of Pennsylvania COUNTY OF CUMBERLAND NATIONWIDE ADVANTAGE MORTGAGE COMPANY V. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON 30702CWE-DN COURT OF COMMON PLEAS DOCKET NO. 14 -1603 -Civil ATTORNEY LD. #52634 ATTORNEY I.D. #309906 ATTORNEY I.D. # 208967 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 11/8/2014 to 3/4/2015 At 6 % TOTAL* *Plus costs to be endorsed C> $ 325,723.68 -4 $ 6,264.18 $ 33,1987.86 MARTHA E. VON ROSENSTIEL, P.C. BY: J ha E. Von • osen Heather Riloff, Esquir Jeniece D. Davis, Esquire Attorneys for Plaintiff PREM: Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013 ,\ tVE/5b D4 -31`k s& U Eb.-17 _) • (4„ 5O e " itjs/9 fiJ e 4 1i 4,111 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff VS. : NO: 14 -1603 -CIVIL WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant(s) #30702 -DN LEGAL DESCRIPTION ALL THAT CERTAIN unimproved tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, being more fully bounded and described according to a Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57, as follows: BEGINNING at a point along the northern side of a 50.00 foot right-of-way known as Prickly Pear Drive at the dividing line between Lots Nos. 8 and 9 of the hereinafter mentioned subdivision plan, thence continuing along said dividing line, North 46 degrees 45 minutes 43 seconds West, a distance of 133.71 feet to a point along the dividing line between Lots Nos. 9 and R2 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 04 degrees 31 minutes 27 seconds East, a distance of 52.73 feet to a point along the dividing line between Lots Nos. 9 and 11 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 61 degrees 08 minutes 11 seconds East, a distance of 110.42 feet to a point along the dividing line between Lots Nos. 9 and 10 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, South 28 degrees 51 minutes 49 seconds East, a distance of 174.00 feet to a point along the northern side of said Prickly Pear Drive; thence continuing along the northern side of said Prickly Pear Drive, South 61 degrees 08 minutes 11 seconds West, a distance of 56.81 feet to a point; thence continuing along same by a curve to the left, having a radius of 200.00 feet, an arc length of 47.78 feet, with a chord bearing of South 54 degrees 20 minutes 06 seconds West and a chord distance of 47.37 feet to a point along the northern side of said Prickly Pear Drive, the point and place of beginning. CONTAINING 0.51 acres and being Lot No. 9 of the Final Subdivision. Plan for Phase I of Hillcrest Farms West Subdivision of the Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57. UNDER AND SUBJECT to the Declaration of Covenants, Reservations and Restrictions as recorded in Misc. Book 693, Page 333. ALSO UNDER AND SUBJECT to any restrictions, easements and right-of-ways as recorded in Plan Book 86, Page 57. IMPROVEMENTS: Residential dwelling Tax Parcel # 29-06-0021-187 TITLE TO SAID PREMISES IS VESTED IN William C. Washington, Sr. and Becky S. Washington, h/w, by Deed from Don E. Backenstow, married man, by Michael A. Scherer, his agent, dated 10/28/2004, recorded 11/01/2004 in Book 266, Page 15. #30702CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff VS. : NO: 14 -1603 -CIVIL WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 C; C.; Martha E. Von Rosenstiel, P.C. by the undersigned attorney for the 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 real property located at Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9, Carlisle, PA 17013: 1. Name and address of owners(s) or reputed owner(s) William C. Washington Lot 9 Prickly Pear Drive Al a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: William C. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: 4 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes 'PO Box 280603 Harrisburg, PA 17128-0603 Cumberland County Adult Probation 4 East Liberty Avenue • Carlisle, PA 17013 Occupant Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject. to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY: Dated: November 06, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosens el, Esquire Heather Riloff, Esquir Jeniece D. Davis, Esqu re Attorneys for Plaintiff #30702-CWE-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff vs. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant(s) t r r- T:;L r rOTHONOTAR'," 2O! 12 3: 06 CUr FE?ERLAM) COu;1TY PE fl SYLVAi!iA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14 -1603 -Civil CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA — Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency Expiration of the 30 days since Service of the Notice (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. BY: MARTHA E. VON ROSENSTIEL, P.C. r Martha E. Von Rosenstiil, ES Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff uire Or 30702CAM-DN --/Ct MARTHA E. VON ROSENSTIEL, P.C. 204 /06, Martha E. Von Rosenstiel Esquire / No. 52634 Heather Riloff, Esquire /No. 309906 18/F/17 3: 07 P4''41,7 Jeniece D. Davis, Esquire / No. 208967 41A1--0 •0 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE COURT OF COMMON PLEAS MORTGAGE COMPANY : CUMBERLAND COUNTY Plaintiff vs. : No: 14 -1603 -Civil WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on Date of Sale: March 04, 2015 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 14 -1603 - Civil in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against William C. Washington, Sr. and Becky S. Washington, Defendant(s). Judgment was entered on November 07, 2014 in the amount of $325,723.68. The property was seized and taken in execution as the property of William C. Washington, Sr. and Becky S. Washington. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN unimproved tract of land situate in North Middleton Township, Cumberland County, Pennsylvania, being more fully bounded and described according to a Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57, as follows: BEGINNING at a point along the northern side of a 50.00 foot riglit-of-way known as Prickly Pear Drive at the dividing line between Lots Nos. 8 and 9 of the hereinafter mentioned subdivision plan, thence continuing along said dividing line, North 46 degrees 45 minutes 43 seconds West, a distance of 133.71 feet to a point along the dividing line between Lots Nos. 9 and R2 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 04 degrees 31 minutes 27 seconds East, a distance of 52.73 feet to a point along the dividing line between Lots Nos. 9 and 11 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, North 61 degrees 08 minutes 11 seconds East, a distance of 110.42, feet to a point along the dividing line between Lots Nos. 9 and 10 of the hereinafter mentioned subdivision plan; thence continuing along said dividing line, South 28 degrees 51 minutes 49 seconds East, a distance of 174.00 feet to a point along the northern side of said Prickly Pear Drive; thence continuing along the northern side of said Prickly Pear Drive, South 61 degrees 08 minutes 11 seconds West, a distance of 56.81 feet to a point; thence continuing along same by a curve to the left, having a radius of 200.00 feet, an arc length of 47.78 feet, with a chord bearing of South 54 degrees 20 minutes 06 seconds West and a chord distance of 47.37 feet to a point along the northern side of said Prickly Pear Drive, the point and place of beginning. CONTAINING 0.51 acres and being Lot No. 9 of the Final Subdivision Plan for Phase I of Hillcrest Farms West Subdivision of the Final Subdivision Plan for Phase I of Hillcrest Farms West, prepared by R.J. Fisher & Associates, Inc., being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 86, Page 57. UNDER AND SUBJECT to the Declaration of Covenants, Reservations and Restrictions as recorded in Misc. Book 693, Page 333. ALSO UNDER AND SUBJECT to any restrictions, easements and right-of-ways as recorded in Plan Book 86, Page 57. Tax ID #29-06-0021-187 IMPROVEMENTS: Residential Dwelling . A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 14 -1603 -Civil. You should check with the Sheriff's Office by calling (717) 240- 6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 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 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Vs. NO 14-1603 Civil Term CIVIL ACTION — LAW WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $325,723.68 L.L.: 5.50 Interest FROM 11/8/2014 TO 3/4/2015 AT 6% - $6,264.18 Atty's Comm: Due Prothy: $2.25 Atty Paid: 5303.59 Other Costs: Plaintiff Paid: Date: 11/12/14 Davi D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: HEATHER RILOFF, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 309906 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COMPANY Plaintiff VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendant(s) #30702CAM - DN C3"��.Y r ~rft l C' ((1 14 OEC I 111' 117 c ,,fs ,D C �4,TY ot, � VA ii/ COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 14 -1603 -CIVIL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned for the Plaintiff in the above action, hereby verifies that on 0 , true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY MARTHA E. VON ROSENSTIEL, P.C. (1J artha E. Von Rosnsti Heather Riloff, Esq Jeniece D. Davis, Esq re Attorneys for Plaintiff :3I For Accountable Mall Name and MARTHA E. VON ROSENSTIEL, P.C. Address Attorney At Law of 649 South Avenue, Unit 7 Sender Secane, PA. 19018 30702BP Indicate type of mail 0 Registered 0 Return Receipt for Merchandise 0 Insured 0 COD 0 Intl Recorded Del. 0 Certified 0 Express Mail UnecK appropriate blocK for Registered Mail: 0 With Postal Insurance• 0 Without Postal Insurance, I-\mx certified additional stamp of nese II issueu ds mailing or for copies of th jiS�p8I POsi. fie' `• i�.' °te `ref - ' �}y{� - ' ! PITNEYHIES .•-021P $ 005.17° Lin e Article Number Name of Addresses, Street, and Post Office Address Posta a g Fee Handling Charge Act. Value (If Regis.) Insured Value Due Send er If COD 1'(w� DC01730253R VIAILED S. H. Fee gel fei0•p U-• R. R. Fee S. D. Fee _ - Remarks 1 1 of 2 Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA. 17013 .48 2 Cumberland Register of Wills County Courthouse Carlisle, PA. 17013 .48 3 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC. 20044 .48 4 PA Department of Revenue Inheritance Tax Division, P.O. Box 280601 Harrisburg, PA 17128 .48 5 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA. 17013 .48 6 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 .48 7 Department of Public Welfare P.O. Box 2675 Harrisburg, PA. 17105 .48 8 OccupantsfTenants Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 .48 ,.3NtlD3s� PA. Department of Revenue Bureau of Individual Taxes P.O. Box 2806030 PA. 17128_Cumberland 48 ,oa (9 4)TOT oHarrisburg, County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 .48 �,cn,10 y49 1506 a 11 William C. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 .48 Total Number of Pieces Listed by Sender 11 Total Number of Pieces Received at Postmaster er e f Rece' ' ployee Name and MARTHA E. VON ROSENSTIEL, P.C. Address Attorney At Law of 649 South Avenue, Unit 7 Sender Secane, PA. 19018 307020001738253 BP Indicate type of mail 0 Registered 0 Return Receipt for Merchandise 0 Insured 0 COD 0 Intl Recorded Del. 0 Certified 0 Express Mail Check appropriate block for Registered Mail: 0 With Postal Insurance 0 Without Postal Insurance Affix stamp .- a't. -t, _, r 3s;f": ti re- here if f.« :Aril. _' - o _� - s r .�te f , l' :`. issue o r `Mt✓`p-9�-.a z i�°401417 i of Receipt 02 1P MAILED ' LV4, - cts® _ � ', ' ._.tee "....mg*PITNEY BOWES Q ®®�.�5 DEC 08 2014 FROM ZIP CODE 1 901 8 Lin e Article Number Name of Addresses, Street, and Post Office Address Posta a 9 Fee Handling Charge Act. Value (If Regis.) Insured Value Due Send er If COD R. R. Fee S. D. Fee S. H. Fee Rest Del. Fee Remarks 1 2 of 2 Becky S. Washington Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 .48 2 Becky S. Washington 111 Race Street Boiling Springs, PA 17007 .48 3 Becky S. Washington 12034 Chase Crossing Circle, Apt. 202 Rockville, MD 20852 .48 4 William C. Washington 3 Prickly Pear Drive Carlisle, PA 17013 .48 5 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 •48 6 .48 7 .48 8 .48 Ntl as D3S ,off 9 .48 o "00-% O vi 10 .48 �J � o1s0 4 a4 Ja� 1 ' 11 .48 Total Number of Pieces Listed by Sender 65 Total Number of Pieces Received at Post Office Postmaster, ' - --72 of - Receiving Emplo, ee) / [LES: PostakServic&M' CERTIFIED MAIL° RECEIPT Domestic Mail Only -13 -n N N a - 2120 0003 S a N 9977 6639 m 0 t7 O 7014 2120 For delivery information; visit our website at•www.usps.com®. al i .v or" (i f Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees C AL US $3.30 22.70 20.001 $6.49 12/0' Sent To Ills dt: 1.—e- .Ir.U__[�Jr b! 1P orPOBoxNo. 2 et �L/ 194Gr bri a8 cty, ye116 9,4 t of PS Form 3800; July 2014' vPL w41; �._ !.. . See Reverse fol ine:ru five U.S. Postal S'ervicet"" CERTIFIED MAIL° RECEIPT Domestic Mail Only For delivery information, visit our website at www.usps.come. 4,1 Postage $ Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To l_„kt.: wa4. 1 n P !reef & A t. o orPOBoxNo. `4 0 7 � /� C jj `S/ C' • , S = te, ZIP+: PS Form 3800, July 2014 $3.30 22.70 $ iP) rR .D N N tr tr m 0 O C] O ff.l r9 ru rl a r- 3070dv • See Reverse for ins C Jc.'c.:rs 1-, 1 U.S. Postal Service"' CERTIFIED. MAIL° RECEIPT' Domestic Mail Only For delivery information, visit our website at www.usps.com®. Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ A 40. t9 'J nJI� 22.70 20.00 $6.49 Sent To k��G $.._.g1.a�.b.ln6. ht. Tarvil or PO Box No. o%`' PALO Cif, State, ZIP+4 .4 76e' !PS Form 386J, Jt ly 2014: _ See Reverse for Inst:U.:loi -Il N N Ir m 1= O C! O ru ra ti N N 0' .A N N rr m a O C7 a Iv r9 f1J ra a N U:S,Postal Service CERTIFIED, MAIL? RECEIPT" Domestic' Mail Onlyi I For delivery information, visit our website at www.usps:com®.' 'C AL USE Postage Certified Fee Return Receipt Fee (Endorsement Required} Restricted Delivery Fee (Endorsement Required) Total Postage & Fees MEI MEd 0 12/ Po .04 Ser:f Tp freet &Apt. 0., ,-;2"4" or PO Box No.1,,O T `1 r(G Z Iv n YbHi/talk/4 P+4 11-4t ii f3 PS Form 3800, July 2014 Orllir3R D-`4* PCS it c' S.,r Fiev rs7forin.tru Lens. U.S:. Postal ServiceTM CERTIFIED MAIL° RECEIPT' Domestic Mail Only For delivery information; visit our website at www.usps.COrn® 1'C A L U S E Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $0.44 $3.30 $2.70 $0.00 $6.49 A pt4r10,10, vil Eli -I See Retersefor Instructions PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT William C. Washington, Sr. and Becky S. Washington SERVE UPON: William C. Washington, Sr. Lot 9 Prickly Pear Drive a/k/a 3 Prickley Pear Drive, Lot 9 Carlisle, PA 17013 AFFIDAVIT OF SERVICE COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 14 -1603 -Civil TYPE OF ACTION (LX Notice of Sheriff's Sale SPECIAL INSTRUCTIONS: please serve defendant personally Sheriffs Sale Date:3/4/2015 or adult In charge of premises (" Becky S. Washington CANNOT accept svc for William" /� k/kS11046TQN SA' SERVED Served and made known to u)(1-[,1 iiNt l.. , Defeaden t, 40.00'clock, p . M., at 3 Ptticgcy P=AC 'OQ, 01114.4S1.4- described 1114.4St. -described below: • I r.- :J ,'. I"/ 30702 -DN 1O/5 /irt ` r;� A,7,, J...,! i 1 cif:,,_, t 3:20 fir fit( i. , • :. f l��i/4.. ...i.jly on the 'day of Fb4-C-611115EA. 20114 , at , Commonwealth of Pennsylvania, in the manner V. Defendant personally served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Agent or person In charge of Defendant's office Relationship is _ Adult in charge of . Defendant's residence who or usual place of business. Other refused to give name/relationship. _ Description: Age C-it7S Height LiHeight Weight I $0 Race 13 Sex M Other i • • Ronald Moll , a competent adult, being duly sworn according to law, depose and state thati- personally handed a true and correct copy of the Notice of Sheriffs Sale issued in the captioned case on • to JII1.1.iA-* IM*1-S141 N!!r0'1. the date and at the address indicated above. Sworn to and subscribed before me this �^ day of b Fr c 20_ Notary: NOT SERVE On the Moved Unknown By: ,20 at No Answer KIMBERLY CURTY NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES MARCH 07, 2018 o'clock M., Defendant NOT FOUND because:: Vacant Time of Attempt: Date of Attempt: Result: Sworn to and subscribed before me this day 200_. of Notary: \c4 By: ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610.328-2887 • AFFIDAVIT OF SERVICE PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT William C. Washington, Sr. and Becky S. Washington SERVE UPON: Becky S. Washington Lot 9 Prickly Pear Drive a/kfa 3 Prlckley Pear Drive, Lot 9 Carlisle, PA 17013 SPECIAL INSTRUCTIONS: please POST PER COURT ORDER Served and made known to Ucel S.Wi*Sf}INbTV .1 4,. .00'clock, P . H., at 1 PRttgLity PEAR DO. described below: COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 14-1603-CivII TYPE OF ACTION XX Notice of Sheriffs Sale J,,`Q^/ if,3o O2 -DN 2 p U Iii,•, CtiI;' Erik . PEi'.'„'S YLVA COUNTY Sheriffs Sale Date:31412015 SERVED Defendant, on the S' day of ))EC.k4hi3&42 , 2044 , at C4-ALAs ut , Commonwealth of Pennsylvania, in -the manner Defendant personally served. Manager/Clerk of place of lodging in which. Adult family member with whom Defendant resides. Defendant resides. Agent or person in charge of Defendant's office Relationship is Adult in charge of Defendant's residence who usual place of business. Other pvsT+G> refused to give name/relationship. Description: Age Height Weight �011ai�C1— to 3 PAI CKUPly PA -40. faR c472 -L -t sc.A, PA the date and at the address indicated above. Sworn to and subscribed before me this. -day of DF. c—, 20. Notary: NOT SERVE On the Moved Unknown By: Race Sex Other }POS?I;C a competent adult, being duly sworn according to law. depose and state that l personally headed a true and correct copy of the Notice of Sheriff's Sale Issued in the captioned case on , 20 at o'clock _. M., Defendant NOT No Answer Vacant KIMBERLY CURTY NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES MARCH 07, 2018 Time of Attempt: Dale of Attempt Result: Sworn to and subscribed before me this day of 200 . Notary: By; ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NATIONWIDE ADVANTAGE MORTGAGE: COMPANY Plaintiff VS. WILLIAM C. WASHINGTON, SR. AND BECKY S. WASHINGTON Defendants AND NOW, this 'day ofS : No: 12-5452 ORDER 013, upon consideration of Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Becky S. Washington by mailing a true and correct copy of the Notice of Sale and all subsequent notices by certified mail and regular, first class mail at the last known address of 3 Prickley Pear Drive, Carlisle, PA 17013 and by posting thepremises of Lot 9 Prickly Pear Drive, Carlisle, PA 17013. BY THE COURT: