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Home My WebLink About14-7002 Supreme Court.:of Pennsylvania Cour n C 0 M n�,PIeas l, �, For Prothonotary Use Only: `� Vi�*Gt)Ye,f Sheet to j I CU�EANf County Docket No; The information collected on this form is used solely far court administration purposes..This form does not supplement or replace Mefiling and service ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: Complaint ❑Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction ❑Declaration of Taking C Lead Plaintiff's Name: PENNYMAC LOAN SERVICES, Lead Defendant's Name: SUSAN Y.SPOTTS T LLC I Are money damages requested? ❑Yes FX1 No Dollar Amount Requested: ❑within arbitration limits Q (Check one) N outside arbitration limits N Is this a Class Action Suit? ❑Yes No Is this an MDJ Appeal? ❑Yes 0 No A Name of Plaintiff/Appellant's Attorney: Kenya Bates.Esq.,Id.No.203664 Phelan Hallinan LLP O Check here if you have no attorney(are a Self-Represented [Pro Se) Litigant) Nature of the Place an"X"to the left of the ONE case category that most accurately describes your Case: 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 ❑Nuisance ❑Dept.of Transportation ❑Premises Liability ❑Statutory Appeal:Other ❑Product Liability(does not S include mass tort) ❑Employment Dispute: ❑Slander/Libel/Defamation Discrimination E ❑Other: ❑Employment Dispute:Other ❑Zoning Board C ❑Other: T I MASS TORT ❑Other: O ❑Asbestos N ❑Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Ejectment ❑Common Law/Statutory Arbitration $ ❑Other: ❑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: ❑Medical ❑Other: ❑Other Professional: Pd.R.C.P.205.5 Updated 01/0112011 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 947164 t _1 t _ 3 l } f (fav E; 1'z{ Cd 10: 40 e t L_WA NIA IW PHELAN HALLINAN,LLP Kenya Bates,Esq.,Id.No.203664 1617 JFK Boulevard,Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia,PA 19103 kenya.bates@phelanhallinan.com 215-563=7000 PENNYMAC LOAN SERVICES,LLC 6101 CONDOR DRIVE, SUITE 200 COURT OF COMMON PLEAS MOORPARK, CA 93021 CIVIL DIVISION Plaintiff V. TERM SUSAN Y. SPOTTS NO. 19 DEERFIELD ST BEAVER SPRINGS,PA 17812 CUMBERLAND COUNTY Defendant CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE CkWA File#: 947164 n1, ( 1�� z 1. Plaintiff is PENNYMAC LOAN SERVICES, LLC 6101 CONDOR DRIVE, SUITE 200 MOORPARK, CA 93021 2. The name(s) and last known address(es)of the Defendant(s) are: SUSAN Y. SPOTTS 19 DEERFIELD ST BEAVER SPRINGS,PA 17812 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/30/2013 SUSAN Y. SPOTTS and DAVID A. SPOTTS made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as Nominee for LIBERTY UNITED LIABILITY COMPANY,which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 201304496. By Assignment of Mortgage recorded 09/16/2014 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201420884.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/01/2014 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File#: 947164 by written notice sent to Mortgagor;the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 10/13/2014: Principal Balance $114,575.94 Interest $3,349.53 12/01/2013 through 10/13/2014 Late Charges $25.75 Property Inspections $219.50 Property Preservation $255.00 Escrow Deficit $466.60 TOTAL $118,892.32 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however,Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding,this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974,Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File#: 947164 9. DAVID A. SPOTTS was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of DAVID A. SPOTTS's death on or about 10/27/2013, his ownership interest was automatically vested in the surviving tenant by the entirety. 10. Plaintiff hereby releases DAVID A. SPOTTS, from liability for the debt secured by the mortgage. WHEREFORE,Plaintiff demands an in rem judgment against the Defendant(s) in the sum of$118,892.32,together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: 7 , X,4; Kenya Bates,Esq., Id.No.203664 Attorney for Plaintiff File#: 947164 VERIFICATION Teresa Luna hereby states that he/she is Default SpecialiSt III of PENNYMAC LOAN SERVICES,LLC, Plaintiff in this matter,that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. PENNY OICES, C 1 � DATE: ` 1 Name: Teresa Luna Title: Default Specialist M PENNYMAC LOAN SERVICES, LLC 947164 Name: SPOTTS File#: 947164 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON, SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING DESIGNATED AS LOT NO. B-2, IN A SUBDIVISION OF THE VILLAS, IN PLAN BOOK 52,PAGE 124,DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHWESTERN CORNER OF THE PROPERTY AT THE CORNER OF LOT NO. B-3; THENCE ALONG LOT NO. B-3, SOUTH 75 DEGREES 47 MINUTES 50 SECONDS EAST, 82.73 FEET TO THE COMMON PARKING LOT; THENCE ALONG SAID COMMON PARKING LOT, SOUTH 14 DEGREES 12 MINUTES 10 SECONDS WEST 26 FEET TO THE CORNER OF LOT NO. B-1; THENCE ALONG LOT NO. B-1,NORTH 75 DEGREES 47 MINUTES 50 SECONDS WEST, 82.75 FEET TO A POINT ALONG COMMON AREAS; THENCE ALONG THE COMMON AREAS,NORTH 14 DEGREES 12 MINUTES 10 SECONDS EAST; 26 FEET TO THE CORNER OF LOT NO. B-3, THE POINT OF BEGINNING. BEING DESIGNATED AS UNIT B-2 ON A SUBDIVISION PLAN RECORDED IN CUMBERLAND COUNTY PLAN BOOK 52,PAGE 124. File#: 947164 . . .L OF LAND WHICH BY DEED DATED 12/0412009 BEING THE SAME LOT OR PARCE D CORDS OF CUMBERLAND ' AND RECORDED 12/14/2009 AMONG THE LAN TITLE FROM DAVID A• COUNTY IN INSTRUMENT NUMBER 200941423 CONVEYING DAV A. SPOTTS JOINED BY SPOUSE SUSAN Y. SPOTTS,THE SPOTTS UNTO DA WITHIN NAMED GRANTORS, PROPERTY ADDRESS: 10 ABBEY COURT,CARLISLE,PA 17015-4384 PARCEL#40-24-0759-001.-UB2---1 File#: 947164 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAndersonFlED U'FF fC. Sheriff 7 1 ^ iC i HCNu .rir Jody S Smith w� z; � � 9 PM . Chief Deputy 24 Richard W Stewart CUMBERLAND COUNTY Solicitor QP:F iCE of THE SHERIFF PENNSYLVANIA b Ciuuub Pennymac Loan Services, LLC vs. Susan Y Spotts Case Number 2014-7002 SHERIFF'S RETURN OF SERVICE 12/03/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Susan Y Spotts, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Snyder, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 12/08/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Susan Y Spotts, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 10 Abbey Court, South Middleton Township, Carlisle, PA 17007. Residence is vacant. 12/12/2014 01:20 PM - The requested Complaint in Mortgage Foreclosure served by the Sheriff of Snyder County upon Susan Y Spotts, personally, at The Synder County Sheriffs Office at 12 South Main Street, Middleburg, PA 17842. Joseph S. Reigle, Jr., Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.78 SO ANSWERS, December 16, 2014 RONNY R ANDERSON, SHERIFF c) CountySuite Sheriff, Teleosoft. Inc. SAVED DISK # 2014-7002 MISC. DKT. BOOK # 43 PAGE # 99 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNYMAC LOAN SERVICES, LLC VS SUSAN Y. SPOTTS NO: 2014-7002 NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE AND NOW, December 12, 2014, 1, Joseph S. Reigle, Jr., according to law deposes and says that the above described Notice Susan Y. Spotts, named defendant, on December 12, 2014, at 1:20 Middleburg, Snyder County, Pennsylvania, by personally handing described Notice and Complaint in Mortgage Foreclosure and that SO ANSWERS JOSEPH S. REIGLE, JR., SHERIFF SNYDER COUNTY, PA. 11,441 • Jes' 0: PH S. REIGLE, JR., SHERIFF Sheriff of Snyder County, Pennsylvania, being duly sworn and Complaint in Mortgage Foreclosure was served upon P.M., at the Snyder County Sheriffs Office, 12 S. Main St to Susan Y. Spotts a true and correct copy of the above 1 made known to Susan Y. Spotts the contents of the same. COMMONWEALTH OF PENNSYLVANIA COUNTY OF SNYDER - SS: SWORN TND SUB CRIBE BEFORE ME TH ODAY OF %'e , 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CATHERINE A REID Notary Public MIDDLEBURG BORO., SNYDER COUNTY My Commission Expires Jul 29, 2017 DEPUTATION BY: SHERIFF OF CUMBERLAND COUNTY, PA. SNYDER COUNTY SHERIFF'S FEES: Docketing, Service, Etc. Mileage Postage Notary Deposit: $ 200.00 Receipt if 16433 Refund: $ 165.00 Check # 10354 $18.00 10.00 2.00 5.00 TOTAL: $ 35.00 PAID TO COUNTY CHECK # REIMBURSED TO PETTY CASH CHECK # Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 PENNYMAC LOAN SERVICES, LLC Court Number: Expiration Date: Type of Action: Mortgage Foreclosure Complaint Defendant/s: SUSAN Y. SPOTTS Serve Upon: SUSAN Y. SPOTTS Address for Service: 19 DEERFIELD ST BEAVER SPRINGS, PA 17812 Alternate Ad. _ s for Service: 10Alit' r __ OURT CA;.'' SLE, ISA 17015-4384 T pe of Service: Deputize ❑ Certified Mail ❑ Posting (copy of court order required) ❑ Personal ❑ Adult in Charge 0 Special Service Instructions: **If service is to be made by deputized service to another county please specify which county SNYDER . Filing Attorney's Information: Name: Phelan Hallinan, LLP /attorneyName/ Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Telephone: 215-563-7000 x 1482 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 PENNYMAC LOAN SERVICES, LLC Court Number: Expiration Date: Type of Action: Mortgage Foreclosure Complaint Defendant/s: SUSAN Y. SPOTTS Serve Upon: SUSAN Y. SPOTTS Address for Service: 10 ABBEY COURT CARLISLE, PA 17015-4384 Alternate Address for Service: 19 DEEFD ST BEAV SPRINGS, PA 17812 Type of Service: ❑ Personal ❑ Adult in Charge ❑ Deputize ❑ Certified Mail ❑ Posting (copy of court order required) Special Service Instructions: **If service is to be made by deputized service to another county please specify which county . Filing Attorney's Information: Name: Phelan Hallinan, LLP /attorneyName/ Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Telephone: 215-563-7000 x 1482 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and fling in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 947164 PHELAN HALLINAN, LLP Kenya Bates, Esq., Id. No.203664 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 kenya.bates@phelanhallinan.com 215-563-7000 PENNYMAC LOAN SERVICES, LLC 6101 CONDOR DRIVE, SUITE 200 MOORPARK, CA 93021 Plaintiff V. SUSAN Y. SPOTTS 19 DEERFIELD ST BEAVER SPRINGS, PA 17812 File #: 947164 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 1 ---/b0 CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand 'd the al of said Cot< at Carlisle, Pa. day of _ 20 Prothonotary Yoe hoar! ccrtW thatvithhl to be a Ulla :f CZi N't; of the o l &rnc+t 3iicd c; recon 1. Plaintiff is PENNYMAC LOAN SERVICES, LLC 6101 CONDOR DRIVE, SUITE 200 MOORPARK, CA 93021 2. The name(s) and last known address(es) of the Defendant(s) are: SUSAN Y. SPOTTS 19 DEERFIELD ST BEAVER SPRINGS, PA 17812 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/30/2013 SUSAN Y. SPOTTS and DAVID A. SPOTTS made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as Nominee for LIBERTY UNITED LIABILITY COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 201304496. By Assignment of Mortgage recorded 09/16/2014 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201420884.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/01/2014 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File #: 947164 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 10/13/2014: Principal Balance $114,575.94 Interest $3,349.53 12/01/2013 through 10/13/2014 Late Charges $25.75 Property Inspections $219.50 Property Preservation $255.00 Escrow Deficit $466.60 TOTAL $118,892.32 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the .Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 947164 9. DAVID A. SPOTTS was a co -record owner of the mortgaged premises as a tenant by the entirety. By virtue of DAVID A. SPOTTS's death on or about 10/27/2013, his ownership interest was automatically vested in the surviving tenant by the entirety. 10. Plaintiff hereby releases DAVID A. SPOTTS, from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $118,892.32, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. By: File #: 947164 PHELAN HALLINAN, LLP Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff VERIFICATION Teresa Luna , hereby states that he/she is Default Specialist III of PENNYMAC LOAN SERVICES, LLC, Plaintiff in this matter, that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 947164 Name: SPOTTS File #: 947164 Name: Title: Teresa Luna Default Specialist III PENNYMAC LOAN SERVICES, LLC LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON, SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING DESIGNATED AS LOT NO. B-2, IN A SUBDIVISION OF THE VILLAS, IN PLAN BOOK 52, PAGE 124, DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHWESTERN CORNER OF THE PROPERTY AT THE CORNER OF LOT NO. B-3; THENCE ALONG LOT NO. B-3, SOUTH 75 DEGREES 47 MINUTES 50 SECONDS EAST, 82.73 FEET TO THE COMMON PARKING LOT; THENCE ALONG SAID COMMON PARKING LOT, SOUTH 14 DEGREES 12 MINUTES 10 SECONDS WEST 26 FEET TO THE CORNER OF LOT NO. B-1; THENCE ALONG LOT NO. B-1, NORTH 75 DEGREES 47 MINUTES 50 SECONDS WEST, 82.75 FEET TO A POINT ALONG COMMON AREAS; THENCE ALONG THE COMMON AREAS, NORTH 14 DEGREES 12 MINUTES 10 SECONDS EAST; 26 FEET TO THE CORNER OF LOT NO. B-3, THE POINT OF BEGINNING. BEING DESIGNATED AS UNIT B-2 ON A SUBDIVISION PLAN RECORDED IN CUMBERLAND COUNTY PLAN BOOK 52, PAGE 124. File 4: 947164 BEING THE SAME LOT OR PARCEL OF LAND WHICH BY DEED DATED 12/04/2009 AND RECORDED 12/14/2009 AMONG THE LAND RECORDS OF CUMBERLAND COUNTY IN INSTRUMENT NUMBER 200941423 CONVEYING TITLE FROM DAVID A. SPOTTS UNTO DAVID A. SPOTTS JOINED BY SPOUSE SUSAN Y. SPOTTS, THE WITHIN NAMED GRANTORS. PROPERTY ADDRESS: 10 ABBEY COURT, CARLISLE, PA 17015-4384 PARCEL #40-24-0759-001.-UB2---1 File #: 947164