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HomeMy WebLinkAbout14-3673 For Prothonotary Use Only: rSc�pi eme court..pf' P''{ennsir1vani.a, aurt � Farm„ �le+a �. , "t Docket No. °.Ar timber and County ` ----�-� The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of leadin s or other papers as required by law or rules of court. Commencement of Action: ®Complaint ❑ Writ of Summons ❑ Petition S ❑Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiffs Name:LoanCare,A Division of FNF Servicing,Inc. Lead Defendant's Name: James J.Windemaker T I Are there money damages requested? ❑ Yes ®No Dollar Amount Requested: ❑within arbitration limits j O (check one) ❑outside arbitration limits i N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppe'al? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: McCabe,Weisberg and Conway,P.C. 11Check here if you have no attorney(a Self-Represented [Pro Sel Litigant) L Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS EF ❑Intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection:Credit Card ❑Board of Assessment E ❑Motor vehicle ❑Debt Collection: Other ❑Board of Elections I ❑Nuisance ❑Department of Transportation ❑Premises Liability(does not include S mass(ort) ❑ Statutory Appeal: Other l E C3Slander/Libel/Defamation 1:1 Employment Dispute: ❑Other: Discrimination ❑Employment Dispute: Other ❑Zoning Board jT ❑Other I i ( O ❑Other s MASS TORT j N ❑Asbestos ❑Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS B ❑Toxic Waste ❑Other: ®Ejectment ❑Common Law/Statutory Arbitration ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑Landlord/Tenant Disput ❑Non-Domestic Relations E ❑ Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY Mortgage❑ Mort a e Foreclosure:Commercial ❑Quo Warranto ❑Dental ❑ Partition ❑Replevin ❑Legal ❑Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: Updated 1/1/2011 McCABE, WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J.McCABE, ESQUIRE-ID# 16496 MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY, ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 . CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 JOSEPH I.FOLEY,ESQUIRE-ID#314675 " r JENNIFER WUNDER,ESQUIRE-ID#315954 ` 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 - �c (215) 790-1010 zo 4 ` LoanCare, A Division of FNF Servicing, Inc. CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: '373 1� James J. Windemaker and Occupants COMPLAINT IN EJECTMENT NOTICE AVISO You have been sued in court. If you wish to defend against the Le han demandado a usted en la corte. Si usted quiere defenderse claims set forth in the following pages,you must take action de estas demandas ex-puestas en las paginas siguientes,usted within twenty (20) days after this complaint and notice are tiene veinte(20)dias de plazo al partir de la fecha de la demanda served, by entering a written appearance personally or by y la notificacion. Hace falta asentar una comparencia escrita o attorney and filing in writing with the court your defenses or en persona o con un abogado y entregar a la corte en forma objections to the claims set forth against you. You are warned escrita sus defensas o sus objeciones a las demandas en contra de that if you fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la corte judgment may be entered against you by the court without further tomara medidas y puede continuar la demanda en contra suya sin notice for any money claimed in the complaint or for any other previo aviso o notificacion. Ademas, la corte puede decidir a claim or relief requested by the plaintiff. You may lose money favor del demandante y requiere que usted cumpla con todas las or property or other rights important to you. provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LLEVE ESTA DEMANDA A UN ABOGADO LAWYER AT ONCE. IF YOU DO NOT HAVE A INMEDIATAMENTE. SI NO TIENE ABOGADO O LAWYER OR CANNOT AFFORD ONE,GO TO SI NO TIENE EL DINERO SUFICIENTE DE PAGAR OR TELEPHONE THE OFFICE SET FORTH TAL SERVICO, VAYA EN PERSONA O LLAME BELOW TO FIND OUT WHERE YOU CAN GET POR TELEFONO A LA OFICINA CUYA HELP. DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association Cumberland County Bar Association 32 South Bedford Street 32 South Bedford Street Carlisle,Pennsylvania 17013 Carlisle,Pennsylvania 17013 (800)990-9108 (800)990-9108 a ' � t McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 JOSEPH 1. FOLEY,ESQUIRE-ID#314675 JENNIFER WUNDER,ESQUIRE-ID#315954 123 South Broad Street,.Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. CUMBERLAND COUNTY 3637 Sentara Way, Suite 303 COURT OF COMMON PLEAS Virginia Beach, Virginia 23452 vs. Number: James J. Windemaker and Occupants 410 Herman Avenue Lemoyne, Pennsylvania 17043 COMPLAINT IN EJECTMENT 1. Plaintiff is the owner of the premises known as 410 Herman Avenue, Lemoyne, Pennsylvania 17043, by virtue of a Sheriffs Deed executed and delivered to Plaintiff on the 13th day of May, 2013 and recorded in Cumberland County on the 12th day of June, 2014 as Instrument Number 201412351. The legal description of which is set forth in the Sheriffs Deed which is attached hereto as Exhibit "A." 2. Plaintiff acquired title by reason of a Sheriffs Sale conducted by the Sheriff of Cumberland County on April 9, 2014, by reason of Writ of Execution issued out of Cumberland County Court of Common Pleas,Number 2013-3677 at the suit of LoanCare, A Division of FNF Servicing, Inc vs James J. Windemaker. 3. Defendants James J. Windemaker and Occupants are in possession of the foregoing described premises without title, color of title, or benefit of a lease from Plaintiff. . i 4. Defendants are wrongfully and unlawfully in possession of the premises. 5. Defendants have no rights of possession to said premises. 6. By reason of the aforesaid Sheriff's sale, Plaintiff holds paramount title to the premises but Defendants continue to unlawfully and willfully retain possession and keep Plaintiff out of possession thereof and refuse to vacate and deliver up the said premises to Plaintiff. 7. No landlord tenant relationship exists between Plaintiff and Defendants, either written or oral, express or implied,and no such relationship was created as a result of the mortgage foreclosure. 8. Because there is no landlord tenant relationship -this is an action in ejectment, not eviction- there is no requirement to give Defendants a notice to quit or vacate the premises. Further,the commencement of an action in foreclosure culminating in a sheriffs sale, followed by the filing of a complaint in ejectment should have put Defendants on notice that Plaintiff intends to recover full interest, title, and possession of the premises. 9. Notwithstanding the aforesaid,.Defendants have willfully remained in possession of Plaintiff's property and refuse, and still refuse to vacate the premises and continue to occupy the same. WHEREFORE, Plaintiff demands a judgment be entered in its favor for possession of the property. McCABE,WEISBERG& CONWAY,P.C. BY: lam/ [ ] Terrence J.McCabe,Esquire [ ]Marc S. Weisb g,Esquire [ ] Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Christine L.Graham,Esquire [ ] Joseph I.Foley,Esquire [ ]Jennifer Wunder,Esquire VERIFICATION I,the undersigned,hereby verify that I am the attorney for the Plaintiff in this action, and that I am familiar with the matters set forth in the within action,that I am authorized to make this verification, and that the forgoing facts are true and correct to the best of my knowledge, information and belief,and further state that false statements herein are made subject to the penalties of 18 PA.C.S. § 4904 relating to unsworn falsifications to authorities. McCAB ISB//ERG& NWAY,P.C. BY: U/t [ ]Terrence J.McCabe,Esquire [ arc 9.Weisberg,Esquire [ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ] Christine L.Graham,Esquire [ ]Joseph I.Foley,Esquire [ ]Jennifer Wunder,Esquire LoanCare,A Division of FNF Servicing,Inc.v.James J.Windemaker and Occupants 0037A2 Tax Parcel No 12-22-0$22-139 Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of$ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to LoanCare,A Division of FNF Servicing, Inc. 2012-3677 Civil Term LoanCare,A Division of FNF Servicing,Inc. Vs James J.Windemaker ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Lemoyne in the County of Cumberland and Commonwealth of Pennsylvania,more particularly bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated August 29, 1977, as follows,to wit: BEGINNING at a point on the Southern side of Herman Avenue, said point being 75 feet West of the Southwest corner of the intersection of Herman Avenue and Cranberry Street; Thence along the Western line of Lot No. 54 Block"C"on the hereinafter mentioned Plan of Lots, South 29 degrees East 150 feet to a point in the Northern side of Plum Alley; Thence along the Northern side of Plum Alley, South 61 degrees West 17.50 feet to a point in the center line of Lot No. 53, Block"C"on the hereinafter mentioned Plan of Lots; Thence along the center line of Lot No. 53, Block"C" aforesaid, thru the center of the partition wall dividing properties known as 410 and 412 Herman Avenue and beyond North 29 degrees West 150 feet to a point in the Southern side of Herman Avenue; Thence along the Southern side of Herman Avenue,North 61 degrees East 17.50 feet to a point, the Place of BEGINNING. BEING the Eastern one-half of Lot No. 53, Block"C", on a Plan of Lots Known as Plan No. 1, Riverton, Recorded in Deed Book J, Volume, page 40. HAVING THEREON ERECTED a 2 '/2 story frame dwelling known and numbered aS 410 Herman Avenue, Lemoyne, Pennsylvania. UNDER AND SUBJECT,NEVERTHELESS,to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. 410 Herman Avenue, Lemoyne, Pennsylvania 17043. BEING the same premises which DANIEL C. BROWN by deed dated May 31, 2007 and recorded June 7,2007 in the office of the Recorder in and for Cumberland County in Deed Book 280, Page 1802, granted and conveyed to James J. Windemaker and Linda K. Windemaker, Husband and Wife. AND the said Linda K. Windemaker departed this life on December 24, 2012;thus vesting sole title to James Windemaker, by operation of law. TAX PARCEL NUMBER: 12-22-0822-139 The same having been sold by me to the said grantee on the 9th day of April Anno Domini Two Thousand and Fourteen (2014)after due advertisement according to law,under and by Virtue of a Writ of Execution issued on the 8th of August Anno Domini 2013 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term,Two Thousand and Twelve (2012) Number 3677 at the suit of LoanCare,A Division of FNF Servicing,Inc.—vs-James J. Windemaker In Witness Whereof, I have hereunto affixed my signature this 13`h day of May Anno Domini Two Thousand and Fourteen(2014) r R. Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania,personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid,and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 13th day of May Anno Domini Two Thousand and Fourteen(2014) •� tiar G, .c rte. Pr thonotary, l• :t-; <� ::';. h4"10 IV,CumbedMW C"ft C"*,FA My Commission EYpoes the F �.�;,.f °"�';�:,�.?` ';•`' I hereby certify that the residence And Post Office address of the Within Grantee is 3637 Sentara Way Suite 303 Virginia Beach, VA 23452 Richard W. Stewart Solicitor REV-183 EX(04-10) RECORDER'S USE ONLY pennsylvania REALTY TRANSFER TAX state Tax Paio ' DEPARTMEMADFREVENUE STATEMENT OF VALUE Book Number VN Bureau of Individual Taxes Page Numbe, PO Box 280603 See reverse for instructions. Harrisburg,PA 17128-0603 Date Recorded w Complete each section and file in duplicate with Recorder of Deeds when(1)the full value/consideration is not set forth in the deed,(2)the deed is without consideration or by gift,or(3)a tax exemption Ls claimed.A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement.If more space is needed,attach additional sheets. A.CORRESPONDENT-Att inquires may be directed to the following person: Name Telephone Number McCabe, Weisberg and Conway, P.C. 215-790-1010 Mailing Address City State Zip Code 123 S. Broad Street, Suite 1400 Philadelphia PA 19109 B.TRANSFER DATA C. Date of Acceptance of Document Grantor(s)/Lessor(s) Grantee(s)/Lessee(s) LoanCare,a Oiv4s on of FNF Servicing,Inc. Sheriff of Cumberland Mailing Address Mailing Address 1 Courthouse Square,Third Floor __ 3637 Sentara Way, Suite 303 City State Zip Code City State Zip Code Carlisle PA 17013 Virginia Beach VA 23452 D. REAL ESTATE LOCATION Street Address City,Township,Borough 410 Herman Avenue Lemoyne Borough County School District Tax Parcel Number Cumberland West Shore School District 12220822139 E.VALUATION DATA-WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? iJ Y ❑ N 1.Actual Cash Consideration 2.Other consideration 3.Total Consideration $1.00 +0.00 =$1.00 4.County Assessed Value S.Common Level Ratio Factor 6.Fair Market Value $118,500.00 x 0.97 =$114,945.00 F. EXEMPTION DATA 1a.Amount of Exemption Claimed tb.Percentage of Grantor's Interest in Real Estate 1c.Percentage of Grantor's Interest Conveyed 100 100% 100% Check Appropriate Box Below for Exemption Claimed. ❑ Will or intestate succession, _ (Name of Decedent) (I:s,aie File Number) ❑ Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) ❑ Transfer from a trust. Date of transfer into the trust If trust was amended attach a copy of original amended trust. ❑ Transfer between principal and agent/straw party. (Attach complete copy of agencylstraw party agreement.) ❑ Transfers to the commonwealth,the U.S. and instrumentalities by gift, dedication, condemnation or in lieu of con- demnation. (If condemnation or in lieu of condemnation, attach a copy of resolution.) Transfer from mortgage to a holder of a mortgage in default. (Attach copy of mortgage and note/assignment.) ❑ Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ❑ Statutory corporate consolidation, merger, or division. (Attach copy of article.) ❑ Other(Please explain exemption claimed.) Property was sold at Sheriff sale on April 9,2014 to LoanCare,a Division of FNF Servicing,Inc.as holder of a mortgage in default,and,thus,tax exempt. Under penalties of law,I declare that I have examined this statement, including accompanying information,and to the best of my knowledge and belief, it is true,correct and complete. Signature of Correspondent or a onsible Party Date FAILURE TO COM LETE THIS FORM ROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE EED. TAMMY SHEARER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE '' CARLISLE, PA 17013 = 717-240-6370 - y Instrument Number-201412351 Recorded On 6/12/2014 At 9:37:49 AM *Total Pages-5 *Instrument Type-DEED-SHERIFF'S Invoice Number-162652 User ID-KW *Grantor-WINDEMAKER,JAMES J *Grantee-LOANCARE *Customer-SHERIFF *FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT LEMOYNE BOROUGH $0.00 TOTAL PAID $69.00 I Certify this to be recorded in Cumberland County PA 0 RECORDER OF DEEDS riso *-Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0037A2 II l II I I II IIIII I I I III I f III SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - - Sheriff Jody S Smith Chief Deputy _`''t ': a�- G '�' C Vie. Richard W Stewart ' Solicitor I i��S f LV P',ELt4'H &P', A LoanCare A Division of FNF Servicing, Inc. Case Number vs. 2014-3673 James J. Windemaker SHERIFF'S RETURN OF SERVICE 06/20/2014 05:07 PM-Deputy Shawn Harrison, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves-to be J Windemaker for Debra Windemaker, occupant,who accepted as"Adult Person in Char 'f upa t at 410 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043. SH N HA N, DEPUTY 06/20/2014 05:07 PM- Deputy Shawn Harrison, being duly sworn according to law, served the q ested Complaint in Ejectment by"personally" handing a true copy to a person representin ems ves o be the Defendant, to wit: James J. Windemaker at 410 Herman Avenue, Lemo a gh, moyne, PA 17043. SH HAR N, DEPUTY SHERIFF COST: $46.08 SO ANSWERS, June 23, 2014 RbNtrY R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 JOSEPH I. FOLEY, ESQUIRE - ID #314675 JENNIFER L. WUNDER, ESQUIRE - ID #315954 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil PRAECIPE . 2 _ c %c TO THE PROTHONOTARY: Kindly enter judgment for possession against the Defendants James J. Windemaker and Occupants in the above -captioned matter for failure to answer Complaint in twenty days as required by Pennsylvania Rules of Civil Procedure. Premises: 410 Herman Avenue, Lemoyne, Pennsylvania 17043 McCABE, WEI BY: RG & CONWAY, P.C. [ ] Terrence J. Mcabe, Esquire [ ] Edward D. Conway, Esquire [ ] Christine L. Graham, Esquire [ ] Jennifer L. Wunder, Esquire [ Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Joseph I. Foley, Esquire avtid siG.opzietg4 CJtAtaai?c 3oq asa OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Prothonotary James J. Windemaker 410 Herman Avenue Lemoyne, Pennsylvania 17043 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. rem- tr Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg & Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Prothonotary Occupants 410 Herman Avenue Lemoyne, Pennsylvania 17043 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the abo; Prothonotary proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg & Conway, P.C. at (215) 790-1010. `713f/0N McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 JOSEPH I. FOLEY, ESQUIRE - ID #314675 JENNIFER L. WUNDER, ESQUIRE - ID #315954 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, James J. Windemaker , is over eighteen (18) years of age, and reside at 410 Herman Avenue, Lemoyne, Pennsylvania 17043. SWORN AND SUBSCRIBED BEFORE ME THIS ( DAY COMMONWEALTH OF PENNSYLVANN NOTARIAL SEAL K nterly Lynn McCloskey, Notary Public City of Philadelphia, Phila. County My Commission Expires September 7, 2016. McCABE, SBERG & CONWAY, P.C. BY: , [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Christine L. Graham, Esquire [ ] Jennifer L. Wunder, Esquire [ arc S. Wa3sberg, Esquire [ ] Margaret Gairo, Esquire [ ] Joseph I. Foley, Esquire Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: WINDEMAKER First Name: JAMES Middle Name: Active Duty Status As Of: Jul -28-2014 Results as of : Jut -28-2014 07:55:56 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date StatusService Component NA , NA - . _ No ' i. NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA . NA ,. 'No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: GBU1O9EEE06A040 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 JOSEPH I. FOLEY, ESQUIRE - ID #314675 JENNIFER L. WUNDER, ESQUIRE - ID #315954 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil CERTIFICATION The undersigned attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail letters notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letters in accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit HAI! SWORN AND SUBSCRIBED BEFORE ME THIS 7`) DAY OF , 2014. 11 NOTAR Y P IBLI J COMMON LTH OF PEN NOTARIAL SEAL IC3rabedy Lynn. McCloskey, Notary public City of Philadelphia, Phila. County 2018 Commissionues =� , McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ]ahI"r6 S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Christine L. Graham, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary July 15, 2014 James J. Windemaker 410 Herman Avenue Lemoyne, Pennsylvania 17043 LoanCare, A Division of FNF Servicing, Inc, v. James J. Windemaker and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EER 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERT Y OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYF,R. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTEIAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION 1MPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PCRSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE, TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECUA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR S ENTENC IA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DER_ECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDI ATAMENT E. SI USTED NO TIENE A UN ABOGADO, VA A 0 TE,LEFONF,A LA OFICINA EXPUSO ABAJO, ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. Si USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS SERVICE:3S LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG & CONWAY, P.C. BY; [ ] Terrence J. McCabe, Esquire [lMarc berg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ 1 Christine L. Graham, Esquire [ ] Joseph I. Foley, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary July 15, 2014 Occupants 410 Herman Avenue Lemoyne, Pennsylvania 17043 LoanCare, A Division of FNF Servicing, Inc, v, James J. Windemaker and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BE:CAUSE, YOU HAVE FAILED TO ENTER A 'WRTITEN 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOURPROPERTY OR OTHER IMPORTANT RIGHTS. You SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOT1F1CACION 1M.PORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDI A POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENS AS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. At, NO TOMAR LA ACCION DEBIDA DENTRO 'DE DMZ (I 0) DIAS DELA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPAREC.ER USTED EN CORTE U O1R PREUBA ALGUNA, DICTAR SENTENCIA EN -SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECH OS IMPORT ANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. Si USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA °FIONA LO PUEDE PR.OPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR.PARA EMPLEAR. UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCI AS QUEPUEDEN OFRECER LOS SERVICIOS LEGALES A 'PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WE SBERG & CONWAY, P.C. BY: [ ] Terrence J. Mc abe, Esquire [ ] Edward D. Conway, Esquire [ ] Christine L. Graham, Esquire [ ] Marc . Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Joseph 1. Foley, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 JOSEPH I. FOLEY, ESQUIRE - ID #314675 JENNIFER L. WUNDER, ESQUIRE - ID #315954 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windemaker and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil AFFIDAVIT OF LAST -KNOWN ADDRESS OF DEFENDANTs I, the undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that to the best of my information, knowledge and belief, the last -known address of the Defendants are as follows: James J. Windemaker and Occupants 410 Herman Avenue, Lemoyne, Pennsylvania 17043 SWORN AND SUBSCRIBED BEFORE ME TH.IS 21 DAY OF , 2014 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. IvfcCabe, Esquire [ ] Mhrc S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Christine L. Graham, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire NOTAR P f: LIC COMMON AL IN OF .PENNSYLVAMA NOTARIAL SEAL. Kimbertyr Lynn McCloskey, Notary Public City of Philadelphia, Phila. County Commission Expires Se ember 7, 2016 VERIFICATION The undersigned, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISFRG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Christine L. Graham, Esquire [ ] Jennifer L. Wunder, Esquire Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Joseph I. Foley, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 JOSEPH 1. FOLEY, ESQUIRE - ID #314675 JENNIFER L. WUNDER, ESQUIRE - ID #315954 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 LoanCare, A Division of FNF Servicing, Inc. v. James J. Windernaker and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-3673 Civil P C FOR T OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the above -captioned matter. 410 Herman Avenue, Lemoyne, Pennsylvania 17043 402 SO PC/ atke 1-1(10 8, McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Christine L. Graham, Esquire [ ] Jennifer L . Wunder, Esquire (.7 -o- r1 [`'Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Joseph I. Foley, Esquire at., co cit#,77,v.3- /2# c cn) —It (7' - /07,-357 e Tax Parcel No 12-22-0822-139 Know all Men by these Presents That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to LoanCare, A Division of FNF Servicing, Inc. 2012-3677 Civil Term LoanCare, A Division of FNF Servicing, Inc. Vs James J. Windemaker ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Lemoyne in the County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the Southern side of Herman Avenue, said point being 75 feet West of the Southwest corner of the intersection of Herman Avenue and Cranberry Street; Thence along the Western line of Lot No. 54 Block "C" on the hereinafter mentioned Plan of Lots, South 29 degrees East 150 feet to a point in the Northern side of Plum Alley; Thence along the Northern side of Plum Alley, South 61 degrees West 17.50 feet to a point in the center line of Lot No, 53, Block "C" on the hereinafter mentioned Plan of Lots; Thence along the center line of Lot No, 53, Block "C" aforesaid, thru the center of the partition wall dividing properties known as 410 and 412 Herman Avenue and beyond North 29 degrees West 150 feet to a point in the Southern side of Herman Avenue; Thence along the Southern side of Herman Avenue, North 61 degrees East 17.50 feet to a point, the Place of BEGINNING. BEING the Eastern one-half of Lot No. 53, Block "C", on a Plan of Lots Known as Plan No, 1, Riverton, Recorded in Deed Book J, Volume, page 40. HAVING THEREON ERECTED a 2 %z story frame dwelling known and numbered as 410 Herman Avenue, Lemoyne, Pennsylvania. UNDER AND SUBJECT, NEVERTHELESS, to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. 410 Herman Avenue, Lemoyne, Pennsylvania 17043. BEING the same premises which DANIEL C. BROWN by deed dated May 31, 2007 and recorded June 7, 2007 in the office of the Recorder in and for Cumberland County in Deed Book 280, Page 1802, granted and conveyed to James J. Windemaker and Linda K. Windemaker, Husband and Wife. AND the said Linda K. Windemaker departed this life on December 24, 2012; thus vesting sole title to James Windemakcr, by operation of law. TAX PARCEL NUMBER: 12-22-0822-139 Exhibit fl lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOANCARE, A DIVISION OF FNF SERVICING, INC. VS. No. 14-3673 Civil Term JAMES J. WINDEMAKER AND OCCUPANTS Costs Attorney's $ 194.83 Plaintiff's $ Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) LOANCARE, A DIVISION OF FNF SERVICING, INC. being: (Premises as follows): 410 HERMAN AVENUE, LEMOYNE, PA 17043 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. uell, Prothonotary, Common Pleas Court of Cumberland County, PA Date 7/31/14 (Seal) 2 of 2 No 14-3673 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOANCARE, A DIVISION OF FNF SERVICING, INC. VS. JAMES J. WINDEMAKER AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 194.83 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Marc S. Weisberg, Esquire McCabe, Weisberg & Conway, P.C. 123 South Broad Street, Suite 1400 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of , . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY UFFiC.E," QF THEHEF<IFF f'lLED }- oFF J f � .; i t:°E PROTHQNn AR'; 20/4 SEP -9 PH 3: 26 CUMBERLAND COUNTY PENNSYLVANIA LoanCare A Division of FNF Servicing, Inc. vs. James J. Windemaker Case Number 2014-3673 SHERIFF'S RETURN OF SERVICE 09/08/2014 06:26 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: James J. Windemaker at 410 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. 09/09/2014 06:26 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Occupant, to wit: Debra Windemaker, also wife of defendant, at 410 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. SHERIFF COST: $58.33 SO ANSWERS, September 09, 2014 RONNY R ANDERSON, SHERIFF (c) CourtySuito Sheriff, Te;eosnft. Inc Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor n SHERIFF'S OFFICE OF CUMBERLAND COUNTY..�,j mcD r-� b cD 2 LoanCare A Division of FNF Servicing, Inc. vs. James J. Windemaker Case Number 2014-3673 SHERIFF'S RETURN OF SERVICE 09/08/2014 06:26 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: James J. Windemaker at 410 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. 09/08/2014 06:26 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Occupant, to wit: Debra Windemaker, also wife of defendant, at 410 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County, and informed Defendant of contents of same. 10/29/2014 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 410 Herman Avenue, Lemoyne, PA 17043. SHERIFF COST: $109.03 SO ANSWERS, October 29, 2014 RONiNR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teieosoft, Inc.