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Home My WebLink About14-5742 For Prothonotary Use Only: Supremo, Co=curt.-of' Po-,n sylva,ni,a . Y t Colo f 10is Plea " i t. _` vmb .tan County Docket No. The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other papers as required by lov or rules of court. Commencement of Action: S<, 0 Complaint ❑ Writ of Summons ❑ Petition ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name:Matrix Financial Services Corporation Lead Defendant's Name:Amy E.Strom T I Are there money damages requested? ❑ Yes ®No Dollar Amount Requested: ❑within arbitration limits (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney:McCabe,Weisberg&Conway,P.C. __— ❑ Check here if you have no attorney(a ScI&Represented (.Pro Se] Litigant) 7777 Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment ❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections h ❑Nuisance ❑ Department of Transportation ❑Premises Liability(does not include �,. 11 Statutory Appeal:Other $ mass tort) E ❑ Slander/Libel/Defamation ❑Employment Dispute: 11 Other: Discrimination Other Dispute:Employment❑Em C to p y p ❑Zoning Board ❑ T; ;•,�_. ;.�°� Other a ❑ Other MASS TORT ❑Asbestos ❑Tobacco 3 t ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Other. ❑Ejectment ❑Common Law/Statutory Arbitration ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations •. * ®Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑Mortgage Foreclosure:Commercial ❑Quo Warranto ❑Dental ❑Partition ❑Replevin { ❑Legal ❑Quiet Title ❑Other: b ❑Medical ❑Other: r, ❑Other Professional: 4 Updated 1/1/2011 McCABE,WEISBERG & 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 ANDREW L. MARKOWITZ,ESQUIRE-ID#28009 HEIDI R. SPIVAK,ESQUIRE-ID# 74770 MARISA J. COHEN,ESQUIRE- ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 - —* ANN E. SWARTZ,ESQUIRE-ID# 201926 c� r-� JOSEPH F. RIGA,ESQUIRE- ID# 57716 a �° cs:� l JOSEPH I. FOLEY,ESQUIRE-ID# 314675 c/f __ ^ CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE- ID# 315954 -- -- LENA KRAVETS,ESQUIRE-ID# 316421 Z5 s Y CAROL A. DiPRINZIO,ESQUIRE-ID#316094 123 South Broad Street, Suite 1400 �i C) - Philadelphia,Pennsylvania 19109 215 790-1010 / Matrix Financial Services Corporation Cumberland County 5151 Corporate Drive Court of Common Pleas - - Troy, MI 48098 Number / V. Amy E. Strom 1800 Hunter Drive Mechanicsburg,PA 17050 and Daniel M. Strom 1800 Hunter Drive Mechanicsburg,PA 17050 COMPLAINT IN MORTGAGE FORECLOSURE c� IIS. 7S axe 3 <<� qa File#14-101641 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex-puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisiones de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION --HIRE A LAWYER,THIS OFFICE MAY BE ACERCA DE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO - PUEDE INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS ATA REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990-9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 File#14-101641 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless,within thirty (30) days after your receipt of this notice,you dispute the validity of the debt, or any portion of the debt,we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed,we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt,we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: Matrix Financial Services Corporation v.Amy E. Strom and Daniel M. Strom Cumberland County File#14-101641 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Matrix Financial Services Corporation. 2. The Defendant is Amy E. Strom, who is a mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1800 Hunter Drive, Mechanicsburg,PA 17050. 3. The Defendant is Daniel M. Strom, who is a mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1800 Hunter Drive, Mechanicsburg, PA 17050. 4. On April 10, 2013,Amy E. Strom and Daniel M. Strom, mortgagors,made, executed and delivered a Mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc.,as nominee for Royal United Mortgage LLC which Mortgage is recorded in the Office of the Recorder - u of Cumberland County as Instrument Number 201313409 (the "Mortgage"), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C.P. 5. On April 10, 2013, Defendant, Amy E. Strom and Daniel M. Strom, also executed a promissory note secured by the aforementioned Mortgage. Plaintiff, directly or through an agent, is in possession of the note and is the holder of the note with the right to enforce it;the note is either made payable to plaintiff or has been duly endorsed. 6. On April 16,2014,the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., as nominee for Royal United Mortgage LLC, its successors and assigns to Flagstar Bank, FSB, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201410941,such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa.R. C.P. - 7. On August 12,2014,the Mortgage was assigned by Flagstar Bank,FSB to Matrix Financial Services Corporation,Plaintiff herein,by Assignment of Mortgage,recorded in the Office of the Recorder of Cumberland County as Instrument Number 201418933,such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa.R. C. P. File#14-101641 Page 4 8. The premises subject to said Mortgage is described in the legal description attached as Exhibit"A" and is known as 1800 Hunter Drive,Mechanicsburg,Pennsylvania 17050. 9. The Mortgage is in default because monthly payments of principal and interest upon said Mortgage due December 1, 2013 and each month thereafter are due and unpaid, and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 10. The following amounts are due on the Mortgage: Principal Balance / $ 105,484.05 Interest throup-August 10, 2014 $ 2,962.14 (Plus $10.48 per diem thereafter) Late Charges $ 169.96 Attorney's Fee $ 2,350.00 Property Inspections $ 30.00 ` . GRAND TOTAL $ 110,996.15 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale.If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 11. Plaintiff complied with all notice requirements as prescribed by 41 P.S. §101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $110,996.15, together with interest at the rate of$10.48 per diem and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. McCABE,WEISBERG& CO/NW/A,AY,P.C. BY: .� ./lam✓ r [ ] Terrence J.McCabe,Esquire [ Marc S.Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire [ ] Carol A.DiPrinzio,Esquire Attorneys for Plaintiff File# 14-101641 Page 5 VERIFICATION Plaintiff is the holders of the note for the subject loan;however,Plaintiff lacks sufficient knowledge or information to make this Verification because Flagstar Bank,FSB ("Flagstar"), as Plaintiffs Attorney in Fact and servicer for the subject loan,maintains or has access to the business records supporting the statements in the foregoing Complaint.I have reviewed those business records, and hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. MATRIX FINANCIAL SERVICES CORPORATION By: Flagstar Bank, F B; its Attorney in Fact P ANDREA BILEK .F0 RECLOSURE,k1NA Y51 Name: Matrix Financial Services Corporation v.Amy E. Strom and Daniel M. Strom Loan Number ending with: 6881 This is a communication from a debt collector. File 4 14.101641 This letter may be an attempt to collect a debt and any information obtained will be used for that pure EXHIBIT "A" Exhibit A {*LEGAL DESC*} ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO A SURVEY PREPARED BY D.P. RAFFENSPERGER, ASSOC., ENGINEERS AND SURVEYORS, DATED FEBRUARY 11, 1980 AND MARCH 27, 1980 AS FOLLOWS, TO WIT: BEGINNING AT A CONCRETE MONUMENT IN LINE OF LANDS NOW OR FORMERLY OF CAROL M. FLOYD; THENCE BY SAID LAND AND BY LAND NOW OR FORMERLY OF PAUL S. SMITH, SOUTH 23 DEGREES 15 MINUTES 00 SECONDS EAST, 529.36 FEET TO A CONCRETE MONUMENT; THENCE IN THE SAME DIRECTION A DISTANCE OF 53.65 FEET CROSSING THE NORTHERN SEGMENT OF LAMBS GAP ROAD (L.R. 21051) TO A POINT IN THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE ALONG THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD, SOUTH 61 DEGREES 44 MINUTES 49 SECONDS WEST, 128.34 FEET TO A POINT IN THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE THROUGH THE INTERSECTION OF LAMBS GAP ROAD AND HUNTERS ROAD, A/K/A HUNTERS DRIVE AND LONG THE CENTERLINE OF HUNTERS ROAD, A/K/A HUNTERS DRIVE, NORTH 52 DEGREES 00 MINUTES 00 SECONDS WEST, 322.73 FEET TO A POINT IN THE CENTERLINE OF HUNTERS ROAD, A/K/A HUNTERS DRIVE; THENCE BY A CURVE TO THE LEFT WITH A RADIUS OF 235.00 FEET ALONG THAT CENTERLINE OF HUNTERS ROAD, A/K/A HUNTER DRIVE; THENCE BY LAND OF J. J. CIGNETTO, NORTH 25 DEGREES 48 MINUTES 34 SECONDS .EAST, CROSSING A CONCRETE MONUMENT AT 25.00 FEET 412.50 FEET TO A CONCRETE MONUMENT, THE PLACE OF BEGINNING. CONTAINING 2.563 ACRES. BEING THE SAME PROPERTY CONVEYED TO DANIEL M. STROM, INDIVIDUALLY BY DEED FROM DANIEL M. STROM AND TATYANA V. STROM RECORDED 08/02/2010 IN INSTRUMENT 201021008, IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA. FORM l Matrix Financial Services Corporation IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA vs. )q i S � a Amy E. Strom and.Daniel M. Strom ivil Ua s~" rl Defendants ,a � > u' >r rw �w rcZ� NOTICE OF RESIDENTIAL MORTGAGE FORECLO= URE ;- DIVERSION PROGRAM v You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference.First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint.If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.THIS PROGRAM IS FREE. Respectfully submitted: Q9 I M1 Date [Signat,]!ire of Counsel for Plaintiff] 14-101641 Page 7 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRI 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 on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: `Cell: Other: Email: #of people on household: How long? INFORMATIONFINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes❑No 0 If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ "" $ _. Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles boats motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 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°a 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 Da /Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes❑No❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: --- - Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes❑No❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes❑No❑ If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): _ Phone: Servicing Company(Name): Contact: Phone: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: ✓ Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation(hardship letter) Listing agreement(if property is currently on the market) 3 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY QFiICE OF ]"FlESHERIFF e;rE PRO!HCHOl R 2014 OCT 24 PM 3:35 CUMBERLAND COUNTY PENNSYLVANIA Matrix Financial Services Corporation vs. Amy E Strom (et al.) Case Number 2014-5742 SHERIFF'S RETURN OF SERVICE 10/01/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Amy E Strom, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/10/2014 10:10 AM - Deputy Tim Black, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Daniel M Strom at 1800 Hunters Drive, Hampden Township, Mechanicsburg, PA 17050. TIM LACK, DEPUTY 10/10/2014 10:10 AM - Deputy Tim Black, 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 Daniel Storm, Husband, who accepted as "Adult Person in Charge" for Amy E Strom at 1800 Hunters Drive, Hampden Township, Mechanicsburg, PA 17050. TI BLACK, DEPUTY 10/10/2014 11:00 AM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Lancaster County, the within named Defendant Amy E Strom, not found. Mark S. Reese, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $74.30 October 21, 2014 (c) CountySuite Sheriff, Teieosoft, Inc. SO ANSWERS, RONW R ANDERSON, SHERIFF SHERIFF'S OFFICE OF LANCASTER COUNTY Mark S. Reese Brad Harris Sheriff • Solicitor Charles Hamilton James Montanez Chief Deputy Lieutenant MATRIX FINANCIAL SERVICES CORPORATION VS. AMY E STROM Case Number 2014-5742 SHERIFF'S RETURN OF SERVICE 10/10/2014 11:00 AM - DEPUTY CHARISSA LEPPLER, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: AMY E STROM AT 416 ESHLEMAN DRIVE, LITITZ, PA 17543. THE DEFENDANT WAS FOUND TO HAVE MOVED. BAD ADDRESS. SPOKE WITH DEFS GRANDPARENT, THEY STATES DEF LIVED WITH THEM TEMP. AND THAT DEF LIVES IN MECHANICSBURG PA. THEY STATED THAT THEY DONT HAVE AN ADDRESS THEY HAVET SEEN OR SPOKEN TO HER IN A WHILE. SHERIFF COST: $50.46 October 14, 2014 L COSTS 44,046.. CHARISSA L LER, DEPUTY SO ANSWERS, ol.- MARK S. S. REESE, SHERIFF DATE CATEGORY MEMO CHK # DEBIT CREDIT 10/06/2014 Advance Fee 10/06/2014 Receiving, Docketing & Return 10/06/2014 Service 10/06/2014 Affidavit 10/06/2014 Deputy Time 10/06/2014 Copies 10/10/2014 Service Mileage 10/14/2014 Not Found Return 10/14/2014 Refund Advance Fee 225610 $0.00 $150.00 $9.00 $0.00 $9.00 $0.00 $2.50 $0.00 $10.00 $0.00 $6.00 $0.00 $8.96 $0.00 $5.00 $0.00 $99.54 $0.00 BALANCE: $150.00 $150.00 $0.00 iitiff Attorney IIACCABE, WEISBERGCCONWAY, P.C., 123 SOUTH BROAD STREET, SUITE 1400, PHILADELPHIA, PA 19 (c) CountySuite Sheriff, TeleosoL Inc 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-5742 Civil ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants, Amy E. Strom and Daniel M. Strom, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount Due Interest from 08/11/14 to 11/17/14 Total Date: //-17- 14 $ 110,996.15 $ 1,037.52 $ 112,033.67 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] . .ret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ eidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff au\ Ea1to .Sb7ea c - wiri\ c 3133(. AND NOW, this )S day of { V. , 2014, Judgment is entered in favor of Plaintiff, Matrix Financial Services Corporation, and against Defendants, Amy E. Strom and Daniel M. Strom, in rem only and not in CA1 personam, and damages are assessed in the amount of $112,033.67, pintere .nd co BY THE PROT McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-5742 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Amy E. Strom and Daniel M. Strom, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendants, Amy E. Strom and Daniel M. Strom, are over eighteen (18) years of age, and reside as follows: Amy E. Strom, 1800 Hunter Drive Mechanicsburg, PA 17050 SWORN AND SUBSCRIBED Daniel M. Strom, 1800 Hunter Drive Mechanicsburg, PA 17050 Date: /1-1774 BEFORE ME THIS f 7 DAY McCABE, WEISBERG & CONWAY, P.C. BY: OF NJVtL�,f�e,R , 2014 NOT U13LIC g$ hllA!*Th OP PENNSYLVANIA NOTARIAL SEAL Kimberly Lynn McCloskey, Notary Public City of Philadelphia, Phila. County Commission Expires September 7, 2016 [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff [ arc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ✓J Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph 1. Foley, Esq. [ ] Lena Kravets, Esq. 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-5742 Civil AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last -known mailing addresses of the Defendants are: Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 SWORN AND SUBSCRIBED BEFORE ME THIS 11 DAY OF P(I VIGwl:11,(2 , 2014 1/14,v, COMM NIN!!FA! TIT OF PENNSYLVANIA NOTARIAL SEAL Kimberly Lynn McCloskey, Notary Public City of Philadelphia, Phila. County Commission Expires September 7, 2016 SS. Daniel M. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Date: 7 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff arc S. Weisberg, Esq. argaret Gairo, Esq. Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-5742 Civil CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS 'OF d . ' , 2014 17 DAY (M ONW 1.TH OF PENNSYLVANIANOTAF;IAL SEAL Kimberly Lynn McCloskey, Notary Public City of Philadelphia, Phila. County Commission Expires Se i tember 7, 2016: Date: f/ 7. /.1 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff [ 4arc . Weisberg, Esq. [ Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Matrix Financial Services Corporation v. Amy E. Strom and Daniel M. Strom Cumberland County; Number: 14-5742 Civil ] rc S. Weisberg, Esq. aret Gairo, Esq. eidi R. Spivak, Esq. [•/] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph 1. Foley, Esq. [ ] Lena Kravets, Esq. [] [ OFFICE OF THE PROTHONOTARY .COURT OF COMMON PLEAS Cumberland: County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary To: Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 October 31, 2014 Matrix Financial Services Corporation vs. Amy E. Strom and Daniel M. Strom Cumberland County Court of Common Pleas Number: 14-5742 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 (10) 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 sn NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 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 FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DERE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACI6N 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 QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE/, IWEISBE " CONWAY, P.C. BY: (�(- [ ] Terrence J. McCabe, ulre [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire 4717 Celine P. DerKrikorian, Esquire ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff —Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire �hif A 14-101641 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 31, 2014 To: Daniel M. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Matrix Financial Services Corporation vs. Amy E. Strom and Daniel M. Strom Cumberland County Court of Common Pleas Number: 14-5742 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 (10) 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 sn NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 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 FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. 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 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 QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGIJN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG D CONWAY, P.C. eit/ [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [oseph F. Riga, Esquire [ eline P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff BY: [ ] Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire 14-101641 . Department of Defense Manpower Data Center StatusReport t Pursuant to Sery cemembers Civil Relief Act Last Name: STROM First Name: AMY Middle Name: Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17-2014 06:50:49 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 Status Service Component NA NA No � 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/PC09SLDR.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: CFTAO7DAF031630 . Department of Defense Manpower Data Center ,Status Report Pursuant to Servicemei hers Civil Relief Act. Last Name: STROM First Name: DANIEL Middle Name: Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17-2014 06:50:51 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - - No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No 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 teport 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/PC09SLDR.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: 4FUAC74AE031670 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-5742 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonot voeil4 If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. �y OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Daniel M. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-5742 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 14-5742 Civil Civil Term Matrix Financial Services Corporation v. AMOUNT DUE: $112,033.67 Amy E. Strom and Daniel M. Strom INTEREST: from 11/18/14 $1,970.94 at $18.42 ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, following described property of the defendant(s) 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050 (More fully described as attached) erest and costs upon the PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 0-�^ McCABE, W ISBERG & CONWAY, P.C. Terrence J. McCabe, Esq. ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. 1.6)[ ] Carol A. DiPrinzio, Esq. 1 q� Attorneys for Pia' tiff wese —74.34 C (15.15,," 1�. ] Marc S. Weisberg, Esq. ] Margaret Gairo, Esq. Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ] Joseph L Foley, Esq. ] Lena Kravets, Esq. Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Q5 Telephone: (215) 790 1010 % a • a. • Supreme Court ID No. 1049 c0 Q}k-SuLcr c1( 31(//aa iSsked LEGAL DESCRIPTION ALL THAT CERTAIN PIECE OR PARCEL OF LAND STRIATE 1N EAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO A SURVEY PREPARED BY D.P. RAFPENSPERGIR, ASSOC, ENGINEERS AND SURVEYORS, DATED FEBRUARY 11,1980 AND MARCB27,1980 AS POl LOWS, TO Wit BBGB+INING AT A CONCRETE MONUMENT IN LINE OF LANDS NOW OR FOIMRLY OF CAROL IC FLOYD; THDICE BY SAID LAND AND BY LAND NOW OR FORMERLY OF PAUL S. SMITH, SOUTH 23 DEGREES 15 /MUTES 00 SECONDS EAST, 529,36 FELT TO A CONCRETE MONUMENT, THENCE IN THE SAME DIRECTION A DISTANCE OF 53.65 FEET CROSSING THE NORTHERN SEGMENT OF LAMBS GAP ROAD (LR. 21051) TOA POINT LN THE . r OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE ALONG THE CBNTEUINE OF THE SOUTHERN SEGMENT OF SAID ROAD, SOUTH 61 D 44 MINUTES 49 SECONDS WEST, 128.34 FEET TO A POINT IN THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE THROUGH THE INTERSECTION OF LAMBS GAP ROAD AND HUNTERS ROAD, ATMA HUNTERS DRIVE AND LONG THE CENTERLINE OF HUNTERS ROAD, Ali/AHUNTERS DRIVE, NORTH 52 DEGREES 0014NUTES 00 SECONDS WEST, 322.73 FIST TO A POINT IN THE CENTRE OF HUNTERS ROAD, MCA HUNTERS DRIVE; THENCE BY A CURVE TO THE LEFT WITH A RADIUS OF 235.00 FEET ALONG THAT CENTER= OF HUMS ROAD, AtM/A HUNTER DRIVE; THENCE LAND 6F1. J. CIGNETTO, Nom{ 25 DEGREES 48 MSS 34SECONPS EAST, CROSSING A CONCRETE MONUMENT AT 25.00 FEET 412,50 FEET TO A CONCRETE MONUMENT, THE RACE OF BEGINNING. CONTAINING 2.563 ACRES. BEING THE SAME PROPERTY CONVEYED TO DANIEL M. STROM, D4DIVWUALLX BY DEED FROM DANIEL M. STROM AND TATYANA V. STRUM RECORDED 0810212010 IN INSTRUMENT 201021008, IN ME OFFIM OF THE RECORDER OF ' . M OF ERLAND COUNTY, FEN1 SYLVAN A. TOGETHER w h he Vet and COM= MC of all buildings, lmproveinellte, ways, Scats, alleys, driveways, passages, wen, watt.courses, rights, llbenies, pdvilegea, hereditaments and appurtenances, all tunes hereafter, forever. BEING the same premises which Daniel M. Strom, Individual by deed dated April 10, 2013 and recorded April 25, 2013 in Instrument Number Instrument Number 201313409, granted and conveyed unto Amy E. Strom and Daniel M. Strom, husband and wife Premises: 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050. TAX MAP PARCEL NUMBER: 10-14-0844-028 McCABE, WEISBERG & 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Matrix Financial Services Corporation Plaintiff v. Amy E. Strom and Daniel M. Strom Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-5742 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. I. Name and address of Owners or Reputed Owners Name Address Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Daniel M. Strom 2. Name and address of Defendants in the judgment: Name 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Address Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Daniel M. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address "MERS" Mortgage Electronic P.O. Box 2026 Registration Systems, Inc. Flint, Michigan 48501-2026 Royal United Mortgage LLC 7999 Knue Road Suite 300 Indianapolis, Indiana 46250 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Address 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Depai tment 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name NONE Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. is -1-1(4 DATE McC� ISBERCONWAY, P.C. BY: Terrence J. McCabe, Esq. [ 1 Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Matrix Financial Services Corporation v. Amy E. Strom and Daniel M. Strom Cumberland County; Number: 14-5742 Civil ] Marc ST -Weisberg, Esq. ] Margaret Gairo, Esq. ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ] Joseph I. Foley, Esq. ] Lena Kravets, Esq. LEGAL DESCRIPTION ALL THAT CEIRTAR3 PIECE OR PARCEL OF LAND SITUATE IN.HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO A SURVEY PREPARED BY D.P RAFFENSPERGE R, ASSOC, ENGINEERS AND SURVEYORS, DATED FEBRUARY 1 ],1980 AND MARCH27,1980 AS FOLLOWS, TO WIT: FINNING AT A CONCRETE MONUMENT IN LINE OF LANDS NOW OR FORMERLY OF CAROL M. FLOYD; ma= BY SAID LAND AND BY LAND NOW OR FORMERLY OF PAUL S. SMITH, SOUTH 23 DEGREES 15 MINUTES 00 SECONDS EAST, 529.36 FEET TO A CONCRETE MONUMENT; THENCE IN THE SAME DIRECTION A DISTANCE OF 53.65 FEET CROSSLN3 THE NORTHERN SEGMENT OF LAMBS GAP ROAD (LR. 21051) TOA POINT IN THE CENT 11i 1NE OF THE SOUTHERN SEGMENT OF SAID ROAD; MINCE ALONG THE CENTERL_ThrE OF THE SOUTHERN SEGMENT OF SAID ROAD, SOUTH 61 DEGREES 44 MINUTES 49 swops WEST, 128.34 FEET TO A POINT IN THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE THROUt311 WE INTERSECTION OF LAMBS GAP ROAD AND HUNTERS ROAD, AfiCtA HUNTERS DRIVE AND LONG THE CENTERLINE OF HUNTERS ROAD, A/K/A HUNTERS DRIVE, NORTH 52DEGREES 00 MINUTES OO SECONDS WEST, 32233 FEET. TO A POINT IN THE CENTERLINE OF HUNTERS ROAD, AMA HUNTERS DRIVE; THENCE BY A CURVE TO THE LEFT WITH A RADIUS OF 235.00 FEET ALONG THAT CENTERIVE OF HUNTERS ROAD, AIKIA HUNTS DRIVE; THENCE BY LAND On 3. CIGNETTO, NORTH 25 DEGREES 4S MINUTES 34 SECONDS EAST, CROSSING A CONCRETE MONUMENT AT 25.00 BEET 4I2.50 FEET TO A CONCRETE MONUMENT, THE PLACE OF BEGINNING. CONTAINING 2.553 ACRES. BEING THE SAME PROPERTY CONVEYED TO DANIEL M. STROM, INDIVIDUALLY BY DEED .FROM DANIEL M. STROM AND TATYANA V. STROM RECORDED 0E102(2010 IN INSTRUMENT 20102100& IN THE OFFICE OF THE RECORDER OF DEEDS OP CUMBERLAND COUNTY, PENNNSYLVA 1, 'TOGETHER with the tree and common use of all .buildings, .impto eigsways, stmets,.alIleys, driveways,... passages, waters, vc C urses, tights, llb n1es, privileges, Iwceeiitaments and apputtenanoes, all times. hereafter, imam. BEING the same premises which Daniel M. Strom, Individual by deed dated April 10, 2013 and recorded April 25, 2013 in Instrument Number Instrument Number 201313409, granted and conveyed unto Amy E. Strom and Daniel M. Strom, husband and wife Premises: 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050. TAX MAP PARCEL NUMBER: 10-14-0844-028 McCABE, WEISBERG & 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Matrix Financial Services Corporation v. Amy E. Strom and Daniel M. Strom Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-5742 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Amy E. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Daniel M. Strom 1800 Hunter Drive Mechanicsburg, Pennsylvania 17050 Your house (real estate) at 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $112,033.67 obtained by Matrix Financial Services Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Matrix Financial Services Corporation the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To fmd out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN HAMPDEN TOWNSHIP, C .IMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO A SURVEY PREPARED BY DP. RAFFENSPERGER, ASSOC., ENGINEERS AND SURVEYORS, DATED FEBRUARY 11, I984 AND MARCH 27, 1980 AS FOLLOWS, TO WIT: BEGINNING AT A CONCRETE MONUMENT IN LINE OF LANDS NOW OR FORMERLY OF CAROLM. FLOYD. THENCE BY SAID LAND AND BY LAND NOW OR FORMERLY OF PAUL S. SMITH, SOUTH 23 DEGREES 15 MINUTES 00 SECONDS EAST, 529.36 FEET TO A CONCRETE MONUMENT; THENCE IN THE SAM DIRECTION A DISTANCE OF 53.65 FEET CROSSING THE NORTHERN SEGMENT OF LAMBS GAP ROAD (LR, 21051) TOA POINT IN THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE ALONG TINE CENTERLINE OP THE SOUTHERN SEGMENT OF SAID ROAD, SOUTH 61 DEGREES 44 MINUTES 49SECONDS WEST, 12834 FEET TO A POINT 1N THE CENTERLINE OF THE SOUTHERN SEGMENT OF SAID ROAD; THENCE THROUGH WE INTERSECTION OF LAMBS CTAP. ROAD AND HUN'T'ERS ROAD, A/K/A HUNTERS DRQ AND LANG THE CENTERLINE OF HUNTERS ROAD, AIWA HUNTERS DRIVE NORTHS2 DEGREES 00 YLIMITES 00 SECONDS WEST, 322.73 FEET TO A PONT INTHE C NIERLINB OF HUNTERS ROAD, ANK/A HUNTERS DRIVE; THENCE BY A CURVE TO THE LEFT WITH A RADIUS OF 235.00FEE'rALONG VAT CENTERLINE OPHUNTERS MAD; AIKC/A HUNTER ORM THENCE BY LAND On J. CIGNE TO, Norm 25 DEGREES 48 MINUTES 34 SECONDS EAST, CROSSING A CONCRETE MONUMENT AT 25.00 FEET 412.50 FEET TO A CONCRETE MONUMENT, THE PLACE OF BEGINNING. 'CONTAINING 2.563 ACRESS, BEING THE SAME PROPERTY CONVEYED TO DANIEL M. STROM, INDIVIDUALLY BY DEED FROM DANT, M, STROM AND TATYANA V. STROM RECORDED 08107!2010IN INSTRUMENT 201021008,, IN THE OFFICE OFTHE RECORDER OFDADS OP C"OM:BERLAND) COUNTY.PENNSYLVANIA, -T@QEITI R wit!) due tree pd eoFecon Map bOdings, Improwments, ways, sweets, .aileyF, driveways,. , passages, Watets,-ante asurscs, fights; liberties, privileges, hereditarnerts and appurtenances, 81I dames hereafter, forCver. BEING the same premises which Daniel M. Strom, Individual by deed dated April 10, 2013 and recorded April 25, 2013 in Instrument Number Instrument Number 201313409, granted and conveyed unto Amy E. Strom and Daniel M. Strom, husband and wife Premises: 1800 Hunter Drive, Mechanicsburg, Pennsylvania 17050. TAX MAP PARCEL NUMBER: 10-14-0844-028 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 MATRIX FINANCIAL SERVICES CORPORATION Vs. NO 14-5742 Civil Term CIVIL ACTION — LAW AMY E. STROM AND DANIEL M. STROM 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: $112,033.67 L.L.: $.50 Interest FROM 11/18/14 - $1,970.94 AT $18.42 Atty's Comm: Due Prothy: $2.25 Atty Paid: $235.05 Other Costs: Plaintiff Paid: Date: 12/3/14 (Seal) -DaatL David D. Bue 1, Prothonota Deputy REQUESTING PARTY: Name: TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG & CONWAY, P.C. 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496