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HomeMy WebLinkAbout05-5072 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 MORTGAGEELECTRONlC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. OS - S()7~C-u, (~~ CUMBERLAND COUNTY Plaintiff v. BRIAN S. SCHREINER HEATHER L. SCHREINER A/KJ A HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 File#: 123]86 c. File #: 123 J 86 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGA TION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 1. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 2. The name(s) and last known address(es) of the Defendant(s) are: BRIAN S. SCHREINER HEATHER L. SCHREINER NK/A HEATHER L. STIRLING 3507 COUNlRYSIDE LANE CAMP HILL, PA 17011 3. On 12/13/2004 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1891, Page: 3836. 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 03/13/2005 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 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File#: 123186 1,250.00 417.30 6. The following amounts are due on the mortgage: Principal Balance Interest 02/13/2005 through 09/27/2005 (Per Diem $42.59) Attorney's Fees Cumulative Late Charges 12/13/2004 to 09/27/2005 Cost of Suit and Title Search Subtotal $181,676.08 9,667.93 $ 550.00 $ 193,561.31 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $ 193,561.31 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, 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) haslhave 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. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of$ 193,561.31, together with interest from 09/27/2005 at the rate of $42.59 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP ~~~ -<f )~ By: /s/{r~ncis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File#: 123186 LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel ofland and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the westerly right-of-way line of Countryside Lane, a 50.00 foot wide right-of-way, which said point of beginning is located at the intersection of the westerly right -of-way line of Countryside Lane and the dividing line between Lots Nos. 114 and 115 on the Plan of Lots known as Countryside, Section (B); thence from said point of beginning along the dividing line between Lots Nos. 114 and 115 South 81 degrees 16 minutes, West, a distance of 106.84 feet to a point on the easterly property line of Lot No.1 05 on the aforesaid Plan of Lots; thence from said point along the easterly property line of Lot No. 105 North 08 degrees 44 minutes West, a distance of 89.55 feet to a point on the southerly property line of Countryside, Section (A); thence from said point along the southerly property line of Countryside, Section (A) North 76 degrees 29 minutes East, a distance of 107.21 feet to a point on the westerly right-of-way line of Countryside Lane; thence from said point along the westerly line of Countryside Lane south 08 degrees 44 minutes East, a distance of98.50 feet to a point, and place of BEGINNING. BEING Lot No. 115 on the Plan of Lots known as 'Countryside', Section (B), prepared by John C. Brilhart, dated December 4, 1973 and recorded on April 11 , 1974 in Plan Book 25, Page 7. HAVING thereon erected a dwelling house known and numbered as premises 3507 Countryside Lane, Camp Hill, Pennsylvania. PROPERTY BEING: 3507 COUNTRYSIDE LANE File #: 123186 d"~; VERIFICA IION I, NICOLA BIGENHO - ASSISTANT VICE PRESIDENT, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief I understand that false statements therein are made subject to the penalties of ] 8 Pa C. S 4904 relating to unsworn falsification to authorities. Date:~ Name: NICOLA BIGENHO - ASSISTANT VICE PRESIDENT COUNTRYWIDE HOME LOANS INC. r;w ---....--.. ~ ""'} ~ ~ en. ~ U\ .....:> C) ~~~ --n C.l" ::? ut <f) f"~ - ~ C> 01 \ C-. --0 -rj ~~ ~ 1" - 'J-r Ul ~ >.~") -1J CO ~"'''.l........'l. ""- ..2:: -'" -~,~ ~ ~ ~'.>. p -:- (::'\ ~ -- ., ;E'" .:::~ 1') :l r --< 0" ------- -- ~ PHELAN HALLINAN & SCHMIEG, LLP LA WRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. BRIAN S. SCHREINER HEATHER L. SCHREINER NKJ A HEATHER L. STIRLING No. 05-5072 CIVIL TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP By: ~~ S. H~ FRANCIS S. HALLINAN, ESQUIRE LA WRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attomeys for Plaintiff Date: November 21. 2005 /jmr, Svc Dept. File# 123186 ,,' ,v C:j /"-'- L~- " SHERIFF'S RETURN - REGULAR . CASE NO: 2005-05072 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SCHREINER BRIAN S ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHREINER HEATHER L AKA HEATHER L STIRLING the DEFENDANT , at 1025:00 HOURS, on the 5th day of December, 2005 at 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 by handing to BRIAN SCHREINER, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 13 .44 .00 10.00 .00 29.44 y ....,<, R. Thomas Kline 12/07/2005 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before me this / I-/~h pQceMlv." ~ _ A.D. jJJt1!itik1 By: day of , SHERIFF'S RETURN - REGULAR . CASE NO: 2005-05072 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SCHREINER BRIAN S ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHREINER BRIAN S the DEFENDANT at 1146:00 HOURS, on the 25th day of October ,2005 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to BRIAN SCHREINER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Aft idavi t Surcharge So Answers: 18.00 .00 .00 10.00 .00 28.00 R. Thomas Kline Sworn and Subscribed to me this Nil before 12/07/2005 ~ PHELAN HALLIN, CHIVJIEG g By: ~ ~f~ Deputy Sheriff day of ncn')j d. A.D. Pro ary; PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. 8201 GREENBORO DRIVE, SUITE 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 05-5072 CIVIL TERM BRIAN S. SCHREINER HEATHER L. SCHREINER a/kJa HEATHER L. STIRLING Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor ofthe Plaintiff and against BRIAN S. SCHREINER and HEATHER L. SCHREINER a/kJa HEATHER L. STIRLING, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 9/28/05 to 1/24/06 TOTAL $193,561.31 $5,068.21 $198,629.52 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 'ff~t!1 J ~~I DANIEL G. SCHMIEG, Ei'QUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE:..JedA 1 :LS ,;;U)O~ I PRO PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENBORO DRIVE, SUITE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 05-5072 CIVIL TERM BRIAN S. SCHREINER HEATHER L. SCHREINER alkla HEATHER L. STIRLING Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant BRIAN S. SCHREINER is over 18 years of age and resides at , 3507 COUNTRYSIDE LANE, CAMP HILL, P A 17011 . (c) that defendant HEATHER L. SCHREINER a/k1a HEATHER L. STIRLING is over 18 years of age, and resides at, 3507 COUNTRYSIDE LANE, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.s. Section 4904 relating to unsworn falsification to authorities. :f(~ JfJ(~utE DANIEL G. SCHMIEG, ESQ Attorney for Plaintiff PHELAN HALLINAN AND SCHMIEG By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, P A 19103 (? 1 'i) 'i61-7000 MORTGAGE ELECTRONIC REGISTRATION: COURT OF COMMON PLEAS SYSTEMS, INe. Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY BRIAN S. SCHREINER HEATHER L. SCHREINER A!KI A HEATHER L. STIRLING : NO. 05-5072 CIVIL TERM Defendants TO: HEATHER L. SCHREINER AIK/ A HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 DATE OF NOTICE: DFCFMRFR 2R 2005 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 '~A .1)k1f2,~ FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN AND SCHMIEG By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PAl 9 I 03 (? 1)) ';/\1-7000 MORTGAGE ELECTRONIC REGISTRATION: COURT OF COMMON PLEAS SYSTEMS, INe. Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY BRIAN S. SCHREINER HEATHER L. SCHREINER NK/ A HEATHER L. STIRLING : NO. 05-5072 CIVIL TERM Defendants TO: BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 DATE OF NOTICE: OFCFMRFR 2R 200, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT 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 THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 '~J.I)~ FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff t -p P -"+ ~\h ..0 1- \t \) , .:;~ ~l ~ C7 ,..., -- -l::: ...:t 1',1 -r:J ---" ~ -.:( :.....; r ?- (..': ~ )J ...:? -c.., ~ - Q - f:: ~ - _.- ff .. -; C -~ (~ " r -- (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. 8201 GREENBORO DRIVE, SUITE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 05-5072 CIVIL TERM BRIAN S. SCHREINER HEATHER L. SCHREINER a/kfa HEATHER L. STIRLING Det'endant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on '- ).::2A."...::1. ~ 200l. . By: If you have any questions concerning this matter, please contact: 'Jf~ J/-4 e-L ' DANIEL G. SCHMIEG, ES~E Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST AnON 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" ( J PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. No. 05-5072 CIVIL TERM BRIAN S. SCHREINER HEATHER L. SCHREINER a/k/a HEATHER L. STIRLING Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $198,629.52 Interest from 1/24/06 to JUNE 7, 2006 (per diem -$32.65) $4,375.10 and Costs TOTAL $203,004.62 ;p~;j.)j J~~ DANIEL G. SCHMIEG, ES IRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. .......... ........ aa ........ ........ ~~ ~~ ~~ ~~ ~ ~~ ~ ~~ g UU ~~ t; z ~~ 0 ~~ o~ ~ ';. 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LYING AND BEING IN THE TOWNSHIP OF HAMPDEN IN THE COUNTY OF CUMJlIJU.AND AND COMMONWUL TH OF PENI<SYl. VANIA. I\tOIIIt PAIlTICUI.ARL Y DIliCR1Bm AS fOlLOWS: II&GINNING AT A POINT ON THE WE8"l"DLY RIGHT-of.WAY LINE OF COCNTItYSIDE LAM!. A 50.00 fOOT WIDE RIGHT-Of-WAY, WIII(:ll SAID POIl'T OF IlEGINNlNG IS LOCATED AT THE tI!lTERIlECTION Of TIll! WI!STI:III. Y RlUIlT..oF-W AY LINE Of CO(JNJRYSlDl LANlt AND nil: DIVIDING LINE IlE1WIlIlN NCIS. II. AND liS oN TRI PLAN Of LO\"S KNOWN AS COVJml_ SIlCTION (B)<: TUl!NCE _ SAID POINT OF BEGI1'/NDlG ALONG T1IE DlVIDlNG LINE RTWUN LO\"S NOS. 11. AND 11$ SOUTH II DIGIIII$ I' MINIITES WIST, A DIln"ANCt: Of IOU. fHT TO A POINT ON 11lE EA8TEIIL Y PIl.OI'EIITY LINE 01' LOT NO. 1U5 ON THE AFORESAJD PLAN 01' WTS: THEIOCE FROM SAID I'OII'tT ALONG THE EASTERLY PROPItATY LINE OF LA>T NO. 105 "OUll81 DEGUI!S 44 MINV11!S WEST, A DISTANCE Of' "-55 Fl!Ef TO A POINT ON TIm SO\ITIIEIILY I'ROt'E&TY UNE OF COONT1lVSIDlt, SIOCTION (A), TIIl!NCE PIlOM SAID POINT ALOJ<<; THE SOII11IEIU. V PllOPEIlTY LINC OF COUNTRYSIDE, sECTION (AI NORTH 16 DWtu:" 19 MINU11!S !!AST. A DISTANCE OF 1t1.11 PUT TO A POINT ON THE WESTERLY RIGBT..()F.WAY UNE OF COlINTRYSlllE LANE, THENCE PROM SAID P01I'IT ALONG THE W1lST1llL Y LINE Of COVNTRVSlllli: LANE 90VTIl 01 DEGIlEElI44 MINVJU 1tAST, A DISTANCE OF_ FEET TO A POINT, AND PLACEOf' 1lEG1NN1I'IG. BEING LOTPlO.II5 01'1 TlIIl PLAN OF LOTS KNOWN AS 'COVIm\\'SIDE".SECTION (B~ PIllPAJUlJ) BY IOBN C. 8RIUlART, DATED DECEMIlER', 19"IJ AND RECORDItDON APRIL ll, 1974- IN PlAN BOOK 15. 'Act!- 7, HAVlNGTHEIlBON ERECTED A OWD..UNC ROuse BEING KNOWN AND NlJMBEREJ) At Hll!MISES JllI7 t()tIN'nlYSlDE LANI. CAMP KILL,I'DINSnYANlA. Vft1IM1! ."'I'1IlatMm; V"te4 bY' Speebl WarrHIt)' Dwd dWJd UIl3l1N t &lV9l:l by E4wlllnl J, Gembtr. ru 10 BrIan S. Sdll'flMr utd K,dltf L Scb..lncr,..,ooJed 11IlOI041o Boole l66-hgt JEI1 PARCEL # 10-19-1596-108 PREMISES BEING: 3507 COUNTRYSIDE LANE, CAMP HILL, PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5072 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC., Plaintiff (s) From BRIAN S, SCHREINER, HEATHER 1. SCHREINER A/K/A HEATHER 1. STIRLING (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other tlian a named garnishee, you are directed to notify him/her that he/she lias been added as a garnishee and is enjoined as above stated. Amount Due $198,629.52 L.L. $.50 Interest FROM 1/24106 TO 617106 (PER DIEM - $32.65) - $4,375.10 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $139.44 Plaintiff Paid Date: JANUARY 31, 2006 Other Costs (Seal) Prothonota~ By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 PHELAN HALLINAN AND SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION BRIAN S. SCHREINER REA TRER 1. SCHREINER a/kla HEATHERL. STIRLING NO. 05-5072 CIVIL TERM Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,~/~ Jf J~,~ DANIEL G. SCHMIEG, ESQU~ Attorney for Plaintiff (') ~ ~: "" CC'> C:~ 0' ~J '::;.n ..... :J:-n rl1 r:- -n(=S .UT "JCJ -~~:..~. ':'~O '-;:''1m ~ ~ <- ;t:: ,".v "" ~ ,.v c,,; - ... MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION BRIAN S. SCHREINER HEATHER L. SCHREINER a/kla HEATHER L. STIRLING NO. 05-5072 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,3507 COUNTRYSIDE LANE, CAMP HILL, P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 HEATHER L. SCHREINER a/kJa HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 Domestic Relations of Cumberland Connty 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 30,2006 DATE 'Pa/lA{Q'P J! ~ ~1 DANIEL G. SCHMIEG, ESQl1IRE Attorney for Plaintiff o t;'. r;'?, ~:,~ 'd' <-- -p;~ :.- u:> .- q, ..A--<\ ~~ f\ \-'0 ~S\q ~.... ..'" '(~\~:l, '1~~ .....(1 :")[j '/. \'f' 'l~ -:.~? }J? '.-::c ~;. :- .- .' u:> ~ ------ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, CUMBERLAND COUNTY No. 05-5672 CIVIL TERM v. BRIAN S. SCHREINER HEATHER L. SCHREINER a/kIa HEATHER L. STIRLING Defendant(s). January 30, 2006 TO: BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 HEATHER L. SCHREINER alkla HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY ** Your house (real estate) at, 3507 COUNTRYSIDE LANE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on JUNE 7, 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $198,629.52 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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: l. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 notice on page two 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 find out the price bid by calling (215) 563-7000. 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 ifthe buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 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 the 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 . , ........ Deerkrtlen: 'ILII........ _ MM'fnH} ALL 'JlL\T CEIlTAIN '!1V.cr 011 'ARCU 01' lAl'ID AND PRllM15l$, srnJATIE, LYIlI'G AND Bl1.1NG IN THE TOWNSIIIl' or WlM1'D1!J< IN THE COUNTY OF ctIMIlll.lll..ANl) AND C~T11 Of' PENNSYLVANIA. _'AIl'I'lCIlLARLY DESCRIIIIJ) AS l'OI.LOWlI: II&IlINNJNO AT A MlNT ON THE W1!STDLY RIGIlToOF.WAY LINE OF COIlNTlIWlDE LANE. A 50.00 FOOT wIDE lUIlBT-oF-WAY, WJII(:H SAJI) POll'IT OF 1lEG1NNJN1l1S LllC\TI!D AT TBJ: QlITD!lBCI1ON OF THE '\1Il!S\'I:RL Y IllGBT.oF-WAY LINII OF C~ LMIE AND 'I1R DIVII>INIl LINIIIlETWlIIlH Nos' 114 J\/lD Its oN TIIJI: PLAN OF LOIS KNOWN AS COIlNTlIYlIIM. S-.cnoN lBl; TBENCII PROM lLW) ronn OF 81!GlNN1N1l ALIlI'IG THE DIVIDIIIG LINE Hl'W-' LOI"S -. 114 AND I" S01lTB II D_ 16 M_ war, A DI8T ANCE OF IOU4 RET TO A POINT Ofi TBE &-ISTERLY I'IlOtEllTY LINE or LOT NO. IllS OI'IllfE AJIORIlWP I'IANOI'LOTS; THEIICE I1lOMlWD I'OINI' ALONG 11IE EASTERLY I'IIOPERTY LINE OF LOT 1'10. 105 ltOllTH " DIlIlII.U6 44 M1Nl111!S WEST, A DISTANCE Of' tI.55 FI!&T TO " POINT oN THE sotTI'IIEIlL Y 1'IlOPia'IY LINE OF COONTB'I'8ID'I, SIICTION (A); 'TIIIU<<:II; PIlOM SAID \'OINT ALONG TIDl SOIl'I'lIERL Y I'llOt'EIlTY LINII Of COIlNTlIY8ID'I, SICTION W NC)1fl'II 76 DItIlUIS 19 MINURS EAST. " DIST4NCE Of' 11'7.21 FEET TO A POINT ON TIlE WISI'EIlL Y RlGHT_.WAY LINE Of' COIlllTRYSlll& LANEl TBENCII JlIlOM lWD POINT 4LONG THE WESTItRLY LINE OF COIlNTRYSllIe LANE flOlTnt 01 DWll.l:1tS 441011l'11.1US 1lAST," DISTANCE OF _FEET TO "POINT. AIiD I'LACE OP ar.GINllII'IG, lIElNG LOT NO. liS oN TBE PUJ< Of' LOTS KNOWN AS 'COIJI<TRYSIDI:" .SECJ'ION (B~ 'JlEPAJlI!I) BY IO~ C.IlIlJUIART. D"TItD DIIlCDfBEIl4, 19'1' AND RECOllDItD ON APRIL II, ,,"IN PL.Vt BOOK 2$, '''C1l 7, HAVING TBEIlEON ERECJ'ID A DWELLING ROt/51! BEING KNOWN ANI) NUMBEllED AS MlIlMlftS l~ OOIJN11lVSIDt LAl'II. CUIP HIU, Pfl'IIiSYLV MIA. Vad_ "'lH'Iftatimt; V..lC<I b;r. 5p.da. W.......,. Doo<l _1:11I3184, Ii- by -..... J. c._, ID 10 'Brian S. Sclu-or- nd KnAber I- kb..1nu ROOnlod 11/1OI041n Bool<; 1M l'1gt :1817 PARCEL# 10-19-1596-108 PREMISES BEING: 3507 COUNTRYSIDE LANE, CAMP HILL, P A 17011 '-:,1' n c ,....., c.~ c:.'" >J" c.._ .~ ~, '" - v) - -P' :.~,.,.. -~,. Q. ~-n rn~ -0..-: :JY '~)'(J '--,?~'~ -:-;(.>) .<-rO C:> _I >lJ :~ - - ,,,) w . AFFIDAVIT OF SERVICE PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. CUMBERLAND COUNTY PMB No. 05-5072 CML TERM DEFENDANT(S) BRIAN S. SCHREINER HEATHER L. SCHREINER aikia HEATHER L. STIRLING ACCT. #90230037 SERVE HEATHER L. SCHREINER aIki. HEATHER L. STIRLING AT 3507 COUNTRYSIDE LANE CAMP HILL, PA t701l Type of ActioD - Notice of She.-ifrs Sale Sale Date: JUNE 7,2006 SERVED Served and made known to I~ ~"+ l..... y <;'Cbll' ~ I <'1 ~ r , Defendan~ on the ,2001~at 7:00 , o'clockLm., at .j,O? Co".~+rj s:J... Ln. Lc<"'P H',II I i.{ fJ.. day of f; hro)', "y vA 17011 . Conunonwealth ofPeIUlSylvania, in the marmer described below: JX.. Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name aud Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant( s) reside( s). Agent or person in charge of Defendant(s)'s office or usual place of business. ___ an officer of said Defendant(s)'s company. Other: Description: Age~ RaceW_ Sex ~ Other Height r-' 'f " Weight m I, '- \r. ,...."../l F: II,~ ~ ,a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice ofSheritrs Sale in the marmer as set forth herein, issued in the captioned case on the date and at the address indicated above. 1'.;');~r'J t',<.:::'.c State cf Ne:1 Je;:~y PAT:",;ICi,4, E HAH~:<:S r.ommission Expires June; G, 2Gee Un the __~ day of NOT SERVED ,200_, at o'clock _.m., Defendant NOT }'OUND because: Moved Unknown No Answer Vacant 1" Attempt: 2nd Attempt: / I Time: I I Time: /' 3rd Attempt: I I Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esqnire - I.D. No. 62205 3( ? \0 ; ) -.. ~.,.. " l ~'. .~- . ( . AFFIDAVIT OF SERVICE PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CUMBERLAND CotJNfY PMB No. 05-5072 CIVIL TERM DEFENDANT(S) BRIAN S. SCHREINER HEATHER 1. SCHREINER a/kIa HEATHER L. STIRLING ACCT. #90230037 Type of Action - Notice of Sheriff's Sale SERVE BRIAN S. SCHREINER AT 3507 COUNTRYSIDE LANE CAMP HlI~L, PA 17011 Sale Date: JUNE 7, 2006 SERVED Served and made known to _f)"-;UFl Sch re;'rl€, , Defendan~ on the 14.n PA- Il(')JI day of f--<br"(J~. 200b, at 7:06 , o'clock2-.m., at oS 0' (oun -+ r::f,;J", L(\ (~..,.,p ),,11 of Pennsylvania, in the manner descnbed below: , Commonwealth Defendant personally served. f)l Adult family member with whom Defendant(s) reside(s). Name and Relationship is W;t, Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. __ManagerIClerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age323s Height J 'p' Weight~ Race..ioL....Sex~ Other I. f 4 <; 1:..--. E J 1"<; . a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. NOT SERVED 00 the day of .200_, at o'clock _.m, Defendant NOT FOUND because: Moved Unknown No Answer _ Vacant 1" Attempt: / / Time: 2bd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this ~ day of . 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - I.D. No. 62205 --z. ,~ ,) t~ . "~, '; ~., - c,:. c .. j SALE DATE: JUNE 7. 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 05-5072 CIVIL TERM VS. BRIAN S. SCHREINER HEATHER L. SCHREINER a/k/a HEATHER L. STIRLING AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. RoC.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 3507 COUNTRYSIDE LANE. CAMP HILL. PA 17011. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.c.P. 3129.2(c) on each ofthe persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. TJ~ Jj .~ DANIEL SCHMIEG, ESQ Attorney for Plaintiff June 2, 2006 1& MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION BRIAN S. SCHREINER HEATHER L. SCHREINER a/k1a HEATHER L. STIRLING NO. 05-5072 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .3507 COUNTRYSIDE LANE. CAMP HILL. P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 HEATHER L. SCHREINER a/kJa HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 2, Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3507 COUNTRYSIDE LANE CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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, Sec. 4904 relating to unsworn falsification to authorities. J anuarv 30. 2006 DATE 1J~ J!.-J~ DANIEL G. SCHMIEG, ESQl3'iRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. vs. BRIAN S. SCHREINER HEATHER L. SCHREINER alk/a HEATHER L. STIRLING TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): BRIAN S. SCHREINER HEATHER L. SCHREINER alk/a HEATHER L. STIRLING PROPERTY: 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 Improvements: Residential dwelling Judgment Amount: $198,629.52 CUMBERLAND COUNTY NO. 05-5072 CIVIL TERM The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on JUNE 7, 2006, at the Cumberland County Courthouse, South Hanover Street, Carlisle, P A at 10:00 a.m.. Our records indicate that you may hold a mortgage, judgment, or other interest on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. If you have any questions regarding the type oflien or the effect ofthe Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. 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"'tl.......o"'tl g:2:;::r::r: ;"-.:J<>>tr1 o..~"'tll' j8-g~ ;;)' "T1 (') ~ . . <>> --c~:a. >g~l' .......::s~Z ~8..~> 0'-< ~ Z \f1J:10'" CX;oa.~ .......~ J:>,~~ <: c..,~tzltzl ~ P. g (')~ tI!l .... '"d 0 =a::Sti1 c;')(D' 0 ~~ ~ tI!l 0 . t'" ~ t'" ...... en -0 :l S 0 ,...." 0 c...:; ~:: c::;, ., 0"' .~ ~ :JJ nl r- CT1 I C) c.n Cl _. ' , z:-", , , --- t. ) D rn c:> . ----, ~t~.... j~:=) ~IJ {,f -<:: Mortgage Electronic Registration Systems, Inc. VS Brian S. Schreiner & Heather L. Schreiner alk/a Heather L. Stirling In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5072 Civil Term Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on March 13, 2006 at 1 :26 0' clock PM, she served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Brian S. Schreiner and Heather L. Schreiner, by making known unto Brian Schreiner, personally, and husband of Heather L. Schreiner, at 3507 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2006 at 6:04 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Brian S. Schreiner and Heather L. Schreiner a/k/a Heather L. Stirling located at 3507 Countryside Lane, Camp Hill, P A, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Brian S. Schreiner and Heather L. Schreiner a/k/a Heather L. Stirling by regular mail to their last known address of3507 Countryside Lane, Camp Hill, PA 17011. These letters were mailed under the date of April 06, 2006 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriffwho being duly sworn according to law, states this writ is returned stayed per instructions from attorney Daniel Schmieg. Sheriffs costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Certified mail Levy Surcharge Law Journal Patriot News Share of Bills Total: 30.00 567.73 15.00 15.00 .50 1.00 26.40 1.08 15.00 30.00 449.00 338.60 19.57 1508.88 ./ q... 1J/)41J~ ., f.J1.J LIt tr'lS3') 1(~.J111l'f So Answers: <~~ R. Thomas Kline, Sheriff ByJO~SwUft, Real Estate ergeant . MORTGAGE ELECfRONIC REGISTRA nON SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION BRIAN S. SCHREINER HEATHER L. SCHREINER alk/a HEATHER L. STIRLING NO. 05-5072 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .3507 COUNTRYSIDE LANE. CAMP HILL. P A 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 HEATHER L. SCHREINER a/k/a HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None .. 4. Name and address of last recorded holder of every mortgage of record: .. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 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. Sec. 4904 relating to unsworn falsification to authorities. January 30. 2006 DATE J5~ J!-1~ DANIEL G. SCHMIEG, ESQrfiRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, CUMBERLAND COUNTY No. 05-5072 CIVIL TERM v. BRIAN S. SCHREINER HEATHER L. SCHREINER aIkIa HEATHER L. STIRLING Defendant(s). January 30, 2006 TO: BRIAN S. SCHREINER 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 HEATHER L. SCHREINER aIkIa HEATHER L. STIRLING 3507 COUNTRYSIDE LANE CAMP HILL, P A 17011 UTHIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A liEN AGAINST PROPERTY. U Your house (real estate) at. 3507 COUNTRYSIDE LANE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriff's Sale on JUNE 7. 2006 at 10:00 a.m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $198.629.52 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 notice on page two 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 find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 , UnlDeRrllrtlDlIl iMP." M~} A.LI. 1'JU.T CERTAIN 1'RACT oa PARCILOF l.AND AIQ) PMMtSlS, SlTtIATR. LYlNO .AmJ UING IN 'mE TOWIfSBJP or HAMI'OIJtt IN TIll COUNrY W (;UMBtBI...UiD .uID C~TlI M PE!'IIl5YLVAMA. MOBI! 'A.R'I'lCIlIARLY DISCIUIIED AS IOUOWSt I&CIMQNG AT A JIOINT OM 1111 WESTlRl.Y lUGRT.oF.WAY un 0lI' commtWID'I .UloIE, A 5o.aDJIOOT wm. RlGBJ'-OP-WAY. WJIICII SAID POIl"T 01" 8IGINNING JS LOCATIO AT TU ~ or Tl1E WESrDl.Y JUGBJ.ol'-w.n LINI CW COClrCnn'SIDIl.AJiIE AJQJ TB&D1VIPlNG LUQ: 8EJ'WU11t"0I. UUlIlD US ON 'nil 1'LAJIII (W LOIS KNOWN AS COVNTRWIN. UCJ10Jt (8); (uaNa FROM lAID l'ODU' OF 81GDfN1NG ALQIlIG TBa DMDING LIIQ; RI'WDI'f IAJ'I'S NOS. u.t AND US S011TII.l D~.f MINlITIS war, A u.TANCE OJ' IMM IlETto A fOIPtJ' ON 1111: EASTDLY rROl'DTY LIl'fB OJ' LO'l"NO. U15 OI'I'RIE AJIORIMDJ I'Lo\NQI' LO'I'S; TBIfIIa FROM SAlJ) 1'Q1IIn' ALOI'fC THt IASTDLY PROnRTY LINE OJ'1m' NO. 185ltOlmI II DEOUIS 44' MlIWID WEST, A DMANa 0II1t.!5 I'I&T TOll POINT ON' T.IIIt sovnn:aLY PROPI&TY LINE CW COONTBl'SJD1, DCIlON ~); '1'IIBNQ noM MID :.oINT AI.OJtG "l'Q SOU'I'IIIJLy rBOPBIlTY LIIlfI Of cotIH1'RWIK. RCtJOllI (,\) JI01ml " DEGUD 29 MII'W1'IS lAST. A PIITANC& Of tf'I.21 FDT TO APOIfIlT ON THE WIS1'I'.:JlL Y RlGJrI'-Ofl'.WAY LINE OF COU1'f1'avsnm LANE, III&riCE JlJlOM SA.JD POINT AlA)NG THI wurm. Y LitE OF cotJtrI'R'Y51De LANE 11011I1I OllDIXaID 44 MU'ttI1'D lAST, A D1STANCEO:r,.". f'IIt'TO.It. PODrT.AHD n..ACEOP BU;DINING, UDTG LOTJICO. ll5 ON Tn RAN Of LOTS HNOWN AS "COUNTRYSWI''.SECTION (B). JRlPAllJ>> ISY JOHN c.1laILHAln'.DA.1'ID DECZMBEa4, 1m AM) lUtCORDJ:DON Al'RIL II. ItT-4 IN rLAN BOOK 25, ,,,OS 7, IlAVll'IC ~ DECTm A OWD.UNG ROUSlt IMUJ(O XNOWN AND NtlMBER.m Ai tuMIIIS H8't OOUN'nl\'SIIJE UNI. CAMP lOLL, PlMtlYI.VANJA. YBtIM l.........dmI: Vmc.l 'by; Speebil W.1"nIII)' n..cI dalecl Wl3lt4, ai-!Jy UMrd J. GemIw. m 10 Brlall s. SdanIaer sad HnO.tr L Scbrelner ncorded 1200I040. 8oot: 166 hie. 311' PARCEL # 10-19-1596-108 PREMISES BEING: 3507 COUNTRYSIDE LANE, CAMP HILL, PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5072 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INc', Plaintiff (s) From BRIAN S. SCHREINER, HEATHER L. SCHREINER AlK/A HEATHER L. STIRLING (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $198,629.52 L.L. $.50 Interest FROM 1/24/06 TO 6/7/06 (PER DIEM - $32,65) - $4,375.10 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $139.44 Other Costs Plaintiff Paid Date: JANUARY 31, 2006 (Seal) By: Deputy REQUESTING PARTY: Name DANIEL G, SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F, KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale # 46 On February 17,2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 3507 Countryside Lane, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: February 17,2006 By: J' Wil d~ vvuf:k Real VE~te Sergeant o I :b V Z - 93.:1 qUOl Vd 'A1NnOJ ON\rUB8WflJ j.:H~3HS 3Hl .:10 3JljjO ~ ~ ('<.~ 0" ~ "" ( ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth ofPemlsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The P~Ltriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #46 N Y PUBLIC My commission expires June 6, 2006 # CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 .. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7, 14,21,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 21 day of April, 2006 N'Y'H,\.. SEAL L('....V:~.!::". "('t:H, Noti:ry P'lblic d i r '): r County ~- 1"'. ., I'"~ ';;:':1" ~',,:L ~rc)i. S, ?'''"",\y'- j \.' ~"''n''''''''iIl<.W,,;'':l'ffiw'\ll!l\1i'fJ!''''''-.'~~-'''''''''''2''".!iIat'''''''~'''~v REAL ESTATE SALE NO, 46 Writ No. 2005-5072 Civil Mortgage Electronic Registration Systems, Inc. vs. Brian S. Schreiner and Heather L. Schreiner a/k/a Heather L. Stirling Atty.: Daniel Schmieg Legal Description: (As shown on Mortgage) ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumber- land and Commonwealth of Penn- sylvania, more particularly de- scribed as follows: BEGINNING at a point on the westerly right-of-way line of Coun- tryside Lane, a 50.00 foot wide right-of-way, which said point of beginning is located at the intersec- tion of the westerly right-of-way line of Countryside Lane and the divid- ing line between Nos. 114 and 115 on the plan of lots known as Coun- tryside, Section (B); Thence from said point of beginning along the divid- ing line between Lots Nos. 114 and 115 South 81 degrees 14 minutes West, a distance of 106.84 feet to a point on the easterly property line of Lot No. 105 on the aforesaid plan of lots; Thence from said point along the easterly property line of Lot No. 105 North 08 degrees 44 minutes West, a distance of 89.55 feet to a point on the southerly property line of Countryside, Section (A); Thence from said point along the southerly property line of Countryside, Sec- tion (A) North 76 degrees 29 min- utes East, a distance of 107.21 feet to a point on the westerly right -of- way line of Countryside Lane; Thence from said point along the westerly line of Countryside Lane South 08 degrees 44 minutes East, a distance of 98.50 feet to a point, and place of beginning, being Lot No. 115 on the plan of lots known as ~Countryside", Section (B), pre- pared by John C. Brilhart, dated December 4, 1973 and recorded on April 11, 1974 in Plan Book 25, Page 7, having thereon erected a dwelling house being known and numbered as premises 3507 Coun- tryside Lane, Camp Hill, Pennsyl- vania. Vesting Information: Vested by: Special Warranty Deed dated 12/13/04, given by Ed- ward J. Genther, III to Brian S. Schreiner and Heather L. Schreiner recorded 12/20/04 in Book 266 Page 3817. PARCEL # 10-19-1596-108. PREMISES BEING: 3507 COUN- TRYSIDE LANE, CAMP HILL, PA 17011.