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HomeMy WebLinkAbout06-3084 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff vs. Wesley J. Young and Amanda I. Young 1402 Pine Road Carlisle, PA 17013 Defendants #l9108-TM CFC o Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: O(p- 36ti ~ CIVIL ACTION - MORTGAGE FORECLO$URE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFOllMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO Yau 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 pl.intiff. You m.y 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 mE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, mIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demand.do . uSled en I. corle. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo .1 partir de I. fech. de I. demand. y I. nOlitic.cion. Hace falta a sentar una comparencia escrita 0 en persona () con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones a Jas demandtts en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya !Sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros efe rechos importantes para usted. LLEVE ESTA DEMAl'IDA A UN ABOGADO INMEDIA TAMENTE: I SI NO TIENE ABOGADO VA Y A EN PERSONA 0 TELEFCu.,A A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PEDE PROVEER INFORMACION SOBRE COMO CONTRATAR~ UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIE TE PARA CONTRA TAR A UN ABOGADO, LE PODE~OS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGlBLE PARA SE VICIOS A COSTO REDUCIDO 0 GRA TUITO. CUMBERLAND COUNTY BAR ASSOCIA no'! 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMA nON OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM T~IS 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 RltCEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANt{S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSU~D TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT F THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT{S) THE NAME A D 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 TillS COM AINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MA Y OBTAIN AN EX ENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED T IS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME A 0 ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE TillRTY (30) DAY PERIOD THAT EGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE . UR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE Mj\IL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 COURT OF COMMON PLEAS Cumberland COUNTY Case No: Plaintiff vs. Wesley J. Amanda I. 1402 Pine Carlisle, Young and Young Road PA 17013 Defendants THIS IS CIVIL ACTION - MORTGAGE FORECLOSURE AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is NationsCredit Financial Services Corporation, a corporation organized and existing under state law, with offices for the conduct of business at c/o Select Portfolio Servicing, Inc., 3815 South West Temple, Salt Lake City, Utah 84165. 2. Defendants, Wesley J. Young and Amanda I. Young are the mortgagors and real owners of premises 315 Pinedale Road, Carlisle, PA 17013, hereinafter described, whos last known address is listed in the caption. 3. Plaintiff brings this action in mortga e foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to EquiCredit Corporation of Pennsylvania on November 1, 1996, which mortgage was recorded on November 6, 19916 in the Office of the Recorder of Deeds of Cumberland County in ~ecord Book 1350, Page 399, secured on premises 315 Pinedale Road, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to First Bank, N.A., which assignment was recorded on April 1~, 1997 in the Office of the Recorder of Deeds of Cumberland County in Record Book 544, Page 1109. 5. The mortgage has since been assigned to NationsCredit Financial Services Corporation, which assignment was recorded on October 4, 2005 in the Office of the Recorder of Deeds in Record Book 721, Page 1929. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not' been made conformity with the terms of the mortgage, froml October 2005 the resent time. and each month thereafter, up to and inCluding 8. Under the terms of the aforesaid mortg ge, upon default of payments set forth in the mortgage documents the entire 1- principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized stateme~t of the amount due plaintiff under the terms of the aforesai~ mortgage: Principal Balance Interest from 09/10/05 to OS/26/06 At $16.20 per diem Accrued late charges to OS/26/06 Attorney's fee (5% of unpaid Principal Balance) Title Information Certificate Photostats and Postage Notarizations $55,011.12 $ 4,179.60 $ 594.13 $ 2,750.56 $ 475.00 $ 50.00 $ 10.00 TOTAL $63,070.41 10. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Lqw and will be collected in the event of a third party purchader at Sheriff's sale. If the mortgage is reinstated prior to ~he Sheriff's reasonable attorney's fees will be chargJd based on work sale, actually performed. 11. The original principal balance of the mortgage involved in this action was $59,500.00, therefore this action does not come within the purview of Act 6 of 19174. 12. The mortgagors involved in this actiof do not reside at the mortgaged premises and therefore are not'eligible for the assistance made available through the Homeowner s Emergency Mortgage Assistance Act of 1983. WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $63,070.41, plus per diem interest at $16.20 from May 27, 2006 ~o the date of judgment plus costs thereon. /' / Martha E. Von Rosenstlei Attorney for Pleintifl - VERIFICATION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating tb unsworn falsification to authorities. By: Title: Vice President LEGAL DESCRIPTION ALL ~hat certain tract of lAnd with lmprovemene:Shereon eree't:ecl si\;uate in toDwoe ?rankford Townsllip, C r111\4 County, ~ennsylv.ni., more DAreicularly bo~n~ 104 descri1>ecl as tOllows, to wit: . : " DZClIllJl%NG 4't a point in elul center of a publ' road. (town_hip rOAd) at corner of lanaa now or fo1'lll t'ly of Albert Gutshall; thence along the center of sllid 1: ship roed, North 85 degrees 31 minutes Bait, 260 fee to.. point; thence by other lands now or fOCUBrly of harl.. L.Hyers, lit wt, the following cour... and dJ.s cu: North 04 degrees 54 minutes West, 154.2 feet to iron pin; Nortb 46 degrees 22 ;inutes W8se, 244.95 fee to an iron pin; North 73 degree. 38 minlle.. w..t, llil. feet to e po~, iron pin, in line of land naw OC form ly ~f Albert Gutshall; thenca aloDq land. now or far= 17 ot Albert Gutshall, South 12 degree. 30 z1Au~e. eaet, 391.9 feet to a 9O'\n1: in the center of the .aid, township roa:d, the Place ot BZGtRRIIG. COftUKtHG 2.<147 acres, more or leu, sccordinC]\ to a survey made by Roger St.Germein , As.oc~aees, aaq14tered Surveyor, on the 23rd day of March, 1963. . .,..- 'tl ~ i.' ,L .,. 110lT > ...... I 9~~ ~0~ -- "' ...j\.)l Ql) G) CJ\\ ~ 0 "" c.~ 0 r- C~~ ;:.,.- c" -n ...... ~~..,,~ ::c..,., -...:-,: rl1F {,.", -npj Cl ;':)\1"7 -0 :=~ ~f~ .,..;,c:--n :::1;:. '~;:.! ("') r:-? 0 en ~~ (.n .n (,.;, .", #19108-TM Martha E. Yon Rosenstiel, P.C. Martha E. Yon Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney 1.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley J. Young and Amanda 1. Young 315 Pinedale Road Carlisle, P A 17013 No: 06-3084 Defendants PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $64,074.81 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: 3815 South West Temple Salt Lake City, Utah 84165 Defendants: 1402 Pine Road Carlisle, P A 17013 315 Pinedale Road Carlisle, PA 17013 ------- -~. //' Martha E. Yon Rosenstiel Attorney for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley 1. Young and Amanda I. Young 315 Pinedale Road Carlisle, PA 17013 Defendants No: 06-3084 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from OS/27/06 to 07/27/06 at $16.20 per diem $63,070.41 $ 1,004.40 Total assessment I Martha E. Von Rosenstiel Attorney for Plaintiff AND NOW, to wit, this day of , 2006, damages are assessed as above. Pro Prothy .' ... Martha E. Yon Rosenstiel, P.c. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney LD.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley J. Young and Amanda I. Young 1402 Pine Road Carlisle, P A 170 J3 No: 06-3084 Defendants CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on July 14, 2006, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstie1, Esquire Attorney for Plaintiff DATED: July 27, 2006 ,: '. #19108-~ ~~ Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff - Martha E. Von Rosenstiel 649 South Avenue, Unit 7 Secane, PA 19018 610328-2887 Attorney 1.0.# 52634 NationsCredit Financial Services Corporation c/o COURT OF COMMON PLEAS Select Portfolio Servicing, Inc. Cumberland COUNTY 3815 South West Temple Salt Lake City, Utah 84165 Plaintiff vs, Case No: 06-3084 Wesley J. Young and Amanda 1. Young 1402 Pine Road Carlisle, PA 17013 Defendant @@(ftJ}f TO: WesleyJ. Young and Amanda 1. Young 315 Pinedale Road Carlisle, PA 17013 1402 Pine Road Carlisle, PA 17013 Date of Notice : July 14,2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI1TEN 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 TRT!; NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER. GO TO OR TELEPHONE THE OFll'ICE SET FORTH BELOW. TRT!; OFll'ICE CAN PROVIDE YOU WITH INJ'ORMATION ABOUT lIIRING A LAWYER. IF YOU CANNOT AFFORD TO lIIRR A LAWYER. TRT!; OFll'ICE MAY BE ,ABI.E TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIJ'S THAT MAY OFFER LEGAL SERVICES TO ELJGTRI.R PERSONS AT A }lRDnCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 717-249-3166 J __~---8 -990-9108 i ~ I IMartha E. Von Rosenstiel \Attorney for .Plaintiff NO'''' .. AfIix~in"""" Or .......-... nl PIIIt..... Inqllh of ""'Tll!)~ . r J~~) ;' \ <,In ...."t . ..!:'~=~~ >O"'N o CO "'0"" 0000.00. .1 . . . us POSTAL SD.VlCK MAY BI! USI!D fOR PROVIDE FOR Received FRNIt MA 011o piece or ordIlary Wes Carl PS Form 3817, Mar.1 u.s. POln'AL MAY BI USIlD PROVIDE FOR Received Fro One pioc:e of PS Form 3817, CERTIFICATE OF MAILING DOMI!STIC AND INTERNATIONAL MAIL. DOES NOT 1NSIJIlANC&-PllSTMAST1lR --- R1llA YON ROSENSTIEL, P.C. 649 scum AVENUE UNIT 7 SECANE, PA 19018 maillddrossed 10: ley J, Y oong and Amanda I. Young isle, PA 17013 989 62$lt ""Th'--- SI!IIVr.R CERTIFICATE OFMAn.TNG FOR IlClNBSnc AND INRRNAnONAL MAIL, DOES NOT INSUJtANcE-poSTMASTIiR or MAR1llA YON ROSENSTIEL, P.c,.-._ 649S0UTHAVENuE ...:~,:. ,,'''''., . SECA~~71901,8 r(~Il)''\':'' ordllOl)' mail lMldrened to: \, ( "Ii:, \~~ .;> TO: WesleyJ,' YOllll8l11ldrdal. ~:../' 114; 1>>0.........1.- D.....I oung Carli,le. PA 17013 623'1 Mar. 1989 ~~iPt, '...... ~1IId PoIII _. Inquire of Po___ ~ Out.Y1t;, ?j 0...'''' ~. f:) y~ f ~l') :"''01 ..ear 1'"00' --: -0....... o 00 "'0"" ODa-oo. .._ oOOt, #19108-TM MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 (610) 328-2887 AttomeyID# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select: Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 COURT OF COMMON PLEAS Cumberland COUNTY Case No: 06-3084 Plaintiff vs. Wesley J. Young and Amanda I. Young 1402 Pine Road Carlisle,PA 17013 Defendants NON.MILITARY AFFIDAVIT ST A IE OF PENNSYLVANIA SS COUNTY OF DELAWARE Martha E. Von Rosenstiel, Esquire, deposes and says: I. That I am the attorney for the plaintiff herein. 2. That the individual involved in this action is the owner of the Premises described in the mortgage or deed of trust. 3. That the procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. That said procedures were followed in connection with the instant foreclosure )..-1' , proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. That, on information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 D.S.C. Appx. Section 501 et sea. This verification is made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Martha E. nstiel AJ (':) \t-~ _ - 1-J ~ ~ -J _ OJ ~ ~ ~ - ~ -c.g. ..0 . C> C> -J f- t. --L. c~ .-\ 7~;; --; PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. v. NO. 06-3084 Wesley 1. Young and Amanda I. Young Praecipe for Writ of Executij)n TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $64,074.81 INTEREST from 07/28/06 to SALE DATE At $16.20 per diem $ (Costs to be added) $ Martha E. Von Rosenstiel Attorney for Plaintiff -,:::) r.J R~~ gJ - )j ~ ~ ~ M - W ,. --0 t: ~ 'E. + ij i f' ~ ~- . . V\ \> ~ c t-~ ~ ~~ - ~--~~~ " ,. -" ~ \' ~. . . "'0 "" .......... - .l: \) . 'frl'oItlC~f"CC ~ l\) C C C \ I \ '~'~. ': I:: '::; :: ~ ~ ~ ~ ~tJ:) ..."" ......~ ... -- ... ....... . .-\ 4- O;,~ , f"':: .-.:"., .' ,,-- WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3084 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONSCREDIT FINANCIAL SERVICES CORPORATION C/O SELECT PORTFOLIO SERVICING, INC., Plaintiff (s) From WESLEY J. YOUNG AND AMANDA I. YOUNG (I) 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $64,074.81 L.L. $.50 Interest FROM 7/28/06 TO SALE DATE AT $16.20 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $168.56 Other Costs Plaintiffpaid Date: AUGUST 2, 2006 CURTIS R. LONG (Seal) Proth02 g ~ '-J3y: "-4--<.. . _ "/JA;- I. r- Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQillRE Address: 649 SOUTH AVENUE, UNIT 7 P. O. BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ill No. 52634 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley 1. Young and Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 Defendants No: 06-3084 CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any false statements given herein. Martha. osenstlel Attorney for Plaintiff Dated: July 27,2006 :..~ , r..) ... .. Martha E. Yon Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley J. Young and Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 Defendants No: 06-3084 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELA WARE MARTHA E. YON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 315 Pinedale Road, Carlisle, P A 17013. I. Name and address of owners(s) or reputed owner(s) Wesley 1. Young 1402 Pine Road Carlisle, PA 17013 Amanda I. Young 315 Pinedale Road Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Wesley J. Young 1402 Pine Road Carlisle, P A 17013 Amanda I. Young 315 Pinedale Road Carlisle, PA 17013 ~ ... 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company 419 Stonebridge Drive, Suite 2 Carlisle, P A 17013 Redevelopment Authority of Cumberland County 114 N. Hanover Street Carlisle, P A 17013 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, P A 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128-1100 Family CourtlDomestic Relations Office One Courthouse Square Carlisle, PA 17013 ~ ... Bureau of Compliance Clearance Support SectionJATTN: Sheriffs Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 OCCUP ANTSrrENANTS 315 Pinedale Road Carlisle, P A 17013 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. .,~. . Martha . on Rosenstiel Attorney for Plaintiff ,.. ... ....<::> :~ :';'1 t t.o --:-:J :~ ~, ; , , r.:'~: . Martha E. Yon Rosenstiel, P.C. Martha E. Yon Rosenstiel 649 South A venue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley J. Young and Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 No: 06-3084 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wesley J. Young 1402 Pine Road Carlisle, P A 17013 Wesley J. Young 1628 Newville Road Carlisle, P A 17013 Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 Your house and/or real estate at 315 Pinedale Road, Carlisle, P A 17013 is scheduled to be sold at Sheriff's Sale on December 6, 2006 at 10:00 a.m. to enforce the court judgment of $64,074.81 obtained by NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. against you. NOTICE OF OWNERS RIGHTS YOU MAYBE 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 NationsCredit Financial Services Corporation c/o . Select Portfolio Servicing, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may call (610) 328-2887. 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 contact 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. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCA TION 2 LIBERTY AVENUE CARLISLE, P A 17013 (800) 990-9108 (717) 249-3166 , CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717240-6391 MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH A VENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27,2006 TO: Wesley J. Young and Amanda I. Young 1402 Pine Road Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road, Carlisle, PA 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and improvements, if any, located at and known as 315 Pinedale Road Carlisle, P A, 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerel s Martha E. Yon Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Van Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Wesley 1. Young and Amanda 1. Young 315 Pinedale Road Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road, Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation clo Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear SirlMadam: Please be advised that the property and improvements, if any, located at and known as 315 Pinedale Road Carlisle, P A, 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley 1. Young and Amanda 1. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely Martha E. Von Rosenstiel ; MVR# 19108 TM " WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 NationsCredit Financial Services Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06-3084 Civil Tenn No. Term,20.......E.D. Term,20-.....A.D. Wesley J. Young and Amanda 1. Young WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYL VANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 315 Pinedale Road Carlisle, PA 17013 Amount Due $ 64,074.81 Interest from 7/28/06 to to Sale Date @ $16.20 per diem Attorney's fees Total $ 2,138.40 $ $ $ Costs as endorsed. Datt'd Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy \ ~ . . ~ .) ~ ... ~ ,; ~ ci ~ \><< ~~ <'? ~s: p...~ 67,; ~~ ~. ~\ Ou ~~ Bg ~~ ~u ,; ~ A < g .~ ';j k 3 .\1. i oa ., \J.< .~ '" Q U ~ .S ';j 7- .;, ? "" S o >' ... .~ ~ ~ 1 "" s o >' ~'O) 0'" ...... ::l ~ '" 0.2 ug ~~ ~\>< ., \><"" o~ ~t: ~o ~6 ...; ~ ..- 3 ~ ~ o U -d p... o .... p... ., ., \>< oil '" ::l ~ 6 ... ... .... ... " .... '" .-< '" ~ if' $ -oS .~ lA ~ ~ ~ C:" ~r- o~r-"'= '?....j'i',<('" ~.,a,.p...~ \~ &: '":; ~O ... -.op:. -.0 '. ~ o ... ;'1 " ~ ~ " '" ,., '" " ~ o ... ~ , ... '" "is.o ~ ~ S i ~ ~ .1 J: ~ ~ ~:: ~ ~ ~ .. '" '" '" ~ ." ." ... ~ LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in Lower Frankford Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of a public road (township road) at corner of lands now or formerly of Albert Gutshall; thence along the center of said township road, North 85 degrees 31 minutes East, 260 feet to a point; thence by other lands now or formerly of Charles L. Myers, et ux, the following courses and distances; North 04 degrees 54 minutes West, 154.2 feet to an iron pin; North 46 degrees 22 minutes West, 244.95 feet to an iron pin; North 73 degrees 38 minutes West, 161.40 feet to a point, iron pin, in line of land now or formerly of Albert Gutshall; thence along lands now or formerly of Albert Gutshall, South 12 degrees 30 minutes East, 397.9 feet to a point in the center of the said township road, the Place of beginning. CONTAINING 2.047 acres, more or less, according to a survey made by Roger St. Germain and Associates, registered Surveyor, on the 23rd day of March, 1963. Tax Parcel #14-05-0421-026 , , , r..) c; " , ;\ ;\ .~'... ,. #19108-TM . Martha E. Yon Rosenstiel, P.C. Martha E. Yon Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney 1.D.# 52634 Attorney for Plaintiff \?-' NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley 1. Young and Amanda 1. Young 315 Pinedale Road Carlisle, P A 17013 Defendants No: 06-3084 AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYL VANIA: SS COUNTY OF DELA WARE MARTHA E. YON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of the last recorded holder of every mortgage of record: Beneficial Consumer Discount Company ..; d/b/a Beneficial Mortgage Company 419 Stonebridge Drive, Suite 2 Carlisle, P A 17013 Redevelopment Authority of Cumberland County J 114 N. Hanover Street Carlisle, P A 17013 2. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Tax Claim Burea/ I Courthouse Square Carlisle, P A 17013 .. Cumberland County Register of Wills J County Courthouse Carlisle, PA 17013 . j Attorney General of the Umted States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 P A Department of Revenue j Inheritance Tax Bureau Strawberry Square, II th Floor Harrisburg, PA 17128-1100 . J Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Bureau of Compliance I Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare .I Box 2675 Harrisburg, PA 17105 ) OCCUP ANTS/TENANTS 315 Pinedale Road Carlisle, P A 17013 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. Martha E. Von Rosenstiel Attorney for Plaintiff For Accountable M8I. 19(0'0 Jj. ii ~ ... .j>. '" '" ... i I ~ z 0 to co .... '" '" 9.111 ~I ... ::.s . .... w . CD iPo ... Ii 'Y 0 ~." co ~I !~i 3_ Ii" ~ 9. - J d) q 9. 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'.:I1!.; 0~'- ~~) z ::;! . ,..., => => "" U) ....., -0 I 0' o -n ...... r1iiJ] -om -,,0 ?':~~) >,.~~~l~ '"Sf'. ::.:~t ~ :r.>> :;: (}1 .r;' SHERIFF'S RETURN - REGULAR CA8E NO: 2006-03084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONS CREDIT FINANCIAL SERVIC VS YOUNG WESLEY J ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon YOUNG WESLEY J the DEFENDANT , at 1515:00 HOURS, on the 23rd day of June 2006 at 1402 PINE ROAD CARLISLE, PA 17013 by handing to WESLEY YOUNG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT WAS SERVED AT 1628 NEWVILLE ROAD CARLISLE, PA Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.40 .00 10.00 .00 32.40/ /'f /17/ fJ (, So Answers: ~~-t:.~J R. Thomas Kline ~ 06/28/2006 MARTHA VON ROSENSTIEL Sworn and Subscibed to By: ~~ff before me this day of A.D. ~ SHERIFF'S RETURN - REGULAR ChSE NO: 2006-03084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONSCREDIT FINANCIAL SERVIC VS YOUNG WESLEY J ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon YOUNG AMANDA I the DEFENDANT , at 1640:00 HOURS, on the 23rd day of June 2006 at 1402 PINE ROAD CARLISLE, PA 17013 by handing to MARK CLEPPER, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT WAS SERVED AT 315 PINEDALE ROAD CARLISLE. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and 06/28/2006 MARTHA VON ROSENSTIEL C)m 1- t1-of" Subscibed to 6.00 6.16 .00 10.00 .00 22.16/ So Answers: f'~<:~ R. Thomas Kline By: before me this day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONSCREDIT FINANCIAL SERVIC VS YOUNG WESLEY J ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon YOUNG WESLEY J the DEFENDANT , at 1515:00 HOURS, on the 23rd day of June 2006 at 315 PINEDALE ROAD CARLISLE, PA 17013 by handing to WESLEY YOUNG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT WAS SERVED AT 1628 NEWVILLE ROAD CARLISLE 6.00 .00 .00 10.00 .00 16.00./ ~ "/11/~1, Sworn and Subscibed to Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ., ~......, "",,;'1" --, ~:r...J',;j;.'" ~. :<'.: /:,:-~ ~,'. " ,/...-:/ .,.'~'. . .' . .,. ",::..P' R. Thomas Kline 06/28/2006 MARTHA VON ROSENSTIEL By: ~yrf4f before me this day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONS CREDIT FINANCIAL SERVIC VS YOUNG WESLEY J ET AL KENNETH GaSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon YOUNG AMANDA I the DEFENDANT , at 1640:00 HOURS, on the 23rd day of June , 2006 at 315 PINEDALE ROAD CARLISLE, PA 17013 by handing to MARK CLEPPER, ADULT IN CHARGE 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 .00 .00 10.00 .00 16.00./ ~ 1/11/0(, Sworn and Subscibed to -p'''.'.'' l' .. ;1-' 'l<!>' R. Thomas Kline 06/28/2006 MARTHA VaN ROSENSTIEL By: ~ I -ep - ,--Sheriff before me this day of A.D. ... , ' Martha E. Von Rosenstiel~ P.C. Martha E. Von Rosenstiel 649 South A venue~ Unit 7 P.O. Box 307 Secane~ PA 19018 610328-2887 Attorney 1.D.# 52634 NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Plaintiff vs. Wesley J. Young and Amanda 1. Young Defendant Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 06-3084 ASSIGNMENT OF JUDGMENT To the Prothonotary: #19108 Kindly assign the Judgment in the amount of $64~074.81 to: Equicredit Corporation of America c/o Select Portfolio Servicing~ Inc at 3815 South West Tern le~ Salt Lake City~ UT 84115-4412 in the above '~aptioned matter. Dated: December 4~ 2006 M ha E. Von Rosenstiel orney for Plaintiff ~ ~ ~ ~ V'\ c;:;> ~ 0..... ..-\ . c::> :J:;-n ~ () P" f\ "\ r:: n ~m -;:) c:? C> t "") 1., C'f"'\ ~~~ """- -- f"" -J -0 ~ :::J;': "';:: rn '" ~ ~ - '::.{ ., ~ p.J (J1 ~ .....l ~ - COMMONWEAL TH ~F PENNSYLVANIA COUNTY OF C}lMBERLAND }SS: i I, Robert P. Ziegl~, Recorder of Deeds in and for said County and State do hereby certify that ! I the Sheriffs Deed in wh~ch EauiCredit Corp of America is the grantee the same having been sold to said grantee on the 6th day o~Dec A.D., 2006, under and by virtue of a writ Execution issued on the 2nd day of Aug, A.D., 2006, out <)fthe Court of Common Pleas of said County as of Civil Term, 2006 Number 3084, at the suit of ~sCredit Fin Ser Corp against Weslev J Young & Amanda I is duly recorded in Deed Book No. 278, Pag~ 2313. o c:- , '" c. ~ IN TESTIMONY WHEREOF, I have hereunto set my hand -tt:- and al of said office this /9 day of , , A.D. d dtJ ( RecofdIr of Cumbef\8IId County, Cad8Ie. PA My Com/iIII8Ion Exi*" the F"1ISt Monday of JIll. 2010 NationsCredit Financial Services Corporation VS Wesley 1. Young and Amanda I. Young In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-3084 Civil Term Kenneth Gosselrt, Deputy Sheriff, who being duly sworn according to law, states that on September 18, 2006 at.1933 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Wesley J. Young, by making kndwn unto Wesley Young personally, at 1402 Pine Road, Carlisle, Cumberland County, Pennsylvania hs contents and at the same time handing to him personally the said true and correct copy of the saqIe. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 04,2006 at 1237 hourS he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Amanda I. Young, by making known unto Amanda Young personally, at 276 Airport Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 12, 2006 at 1930 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Wesley J. Young and Amanda I. Young located at 315 Pinedale Rd., Carlisle, Cumberland County, Pennsylvania 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 defendant, to wit: Wesley 1. Young, by regular mail to his last known address of 1402 Pine Road, Carlisle, PA 17013. This letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. 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 defendant, to wit: Amanda I. Young, by regular ma~l to her last known address of276 Airport Road, Shippensburg, PA 17257. This letter was mailed 'under the date of October 10, 2006 and returned to the Sheriffs Office on October 19,2006 with reason marked "Return to Sender, Unclaimed. II R. Thomas Klihe, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 6, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Martha Von Rosenstiel on behalf or EquiCredit Corporation of America, its successors and assigns. It being the highest bid and best pIiice received for the same, EquiCredit Corporation of America, its successors and assigns of c/o Select Portfolio Servicing Inc, 3815 South West Temple, Salt Lake City, UT 84165, being the buyet in this execution, paid to SheriffR. Thomas Kline the sum of $821.04. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 16.1 0 15.00 15.00 30.00 10.00 .50 1.00 Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 43.12 5.22 15.00 30.00 269.00 260.66 15.94 25.00 39.50 $ 821.04 So Answers: ~~~<<;~ R. Thomas Kline, Sheriff \ ~e~ os:-\!- cP $~\. SO . ,\0 '" 5lP:o..OPP c~ \'0'/ . , #19108-TM I I i Martha E. Yon Rosentiel, P.C. Martha E. Von Rosen tiel 649 South Avenue, U 't 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 I I Attorney for Plaintiff (Ccg~1f I NationsCredit Financi~ Services Corporation c/o Select Portfolio Servicing, Inc. ! 3815 South West Teuwle Salt Lake City Utah 84165 I COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff No: 06-3084 I vs. I Wesley J . Young and .f\manda I. Young 315 Pinedale Road I Carlisle,PA17013 : DefendFts I I ! ! AFFIDA YIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 I COMMONWEALTH IOF PENNSYLVANIA: ! SS COUNTY OF DELA Vi ARE ! MARTHA Ef,VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service 0 the Notice under Rule 3129.1, in the above matter was made on all interested parties, set rth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates 0 mailing: I , 1. Name and laddress of the last recorded holder of every mortgage of record: I I Beneficial C o~umer Discount Company d/b/a Benefici Mortgage Company 419 Stonebrid e Drive, Suite 2 Carlisle, PAl 013 ! Redevelopme Authority of Cumberland County 114 N. Hanov r Street Carlisle, PAl 013 2. Name and dress of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland C unty Tax Claim Bureau 1 Courthouse quare Carlisle, PAl 013 ! Cumberland C~unty Register of Wills County Courthpuse Carlisle, PA 11013 ! ! Attorney Gene~al of the United States c/o Assistant ~orney' General, Tax Division ! U.S. Departmert of Justice Post Office BOf 227 W ashington, D~ 20044 I I P A Department of Revenue Inheritance T~ Bureau Strawberry Sqqare, 11 th Floor Harrisburg, PAl 17128-1100 I , Family Co~omestic Relations Office One Courthou~ Square Carlisle, PAl ~O 13 ! ! ! Bureau of COI~p1iance Clearance Sup~ort Section! A TTN: Sheriff s Sale Dept. 281230 ! Harrisburg, Pj 17129-1230 Dept. of Publi . Welfare Box 2675 .1 Harrisburg, P Ai 17105 OCCUPANTS tENANTS 315 Pinedale oad Carlisle, PAl 013 ! ! I ! I verify that tht statements made in this affidavit are true and correct to the best of my personal knowledge o~ information and belief. I understand that false statements herein are made subject to the penaltie, of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 , Martha E. Von Rosenstiel,IEsquire Phone: (610)328-2887 Fax: (610)328-2649 Leslie J. Rase, Esquire July 27,2006 TO: Beneficial Consumer Discount Company d/b/a mmeficial Mortgage Company 419 Stdnebridge Drive, Suite 2 Carlisle,PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 ! Amount of JuUgment: 564,074.81 Date of Jud~ent: July 27, 2006 Court Term aod Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NadonsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisl~, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. ih the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property ahd improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of t~e owners, real owners, and reputed owners of the aforementioned property are Wesley.lr. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days afte~ said sale, and distribution will be made in accordance with the schedule unl ess exceptions are iled thereto within ten (10) days after the date of the filing of said schedule. You should check wit the Sheriffs Office by calling 717-240-6391 to determine the actual date of the filing of th schedule. If you have any questions regarding the type of lien of the effect of the sheriffs sale upon your lien, we ur e you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. Sincere ------. . ,...-."..~~.- _.-~~'~ . i _....,,"'~....-~fi""" rr ! I , M MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH A VENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, :Esquire . Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Redev~opment Authority of Cumberland County 114 N. Hanover Street Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount ofJu~gment: $64,074.81 Date of Judg.,ent: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland tounty, Docket# 06-3084 Plaintiff: Na.,onsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advi~ed that the property and residential dwelling, located at and known as 315 Pinedale Road Carlislt, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is ~ing sent to you because research of public records indicate that you are, or may be a lienholder 011 the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the 1bove named plaintiff, and against the above named defendants. The name of t~e owners, real owners, and reputed owners of the aforementioned property are Wesley~. Young and Amanda I. Young. A schedule of ~istribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days afte~said sale, and distribution will be made in accordance with the schedule unless exceptions ar. e led thereto within ten (10) days after the date of the filing of said schedule. You should check wi b the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of t e schedule. If you have a~y questions rega.rding the type of lien of the effect of the sheriff's sale upon your lien, we u ge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give yo legal advice. ! , ~ MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27,2006 TO: Cumberland CCl>unty Tax Claim Bureau 1 Courthouse Square Carlisle,PA 17013 RE: NOTICE OF $ALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Jud~ent: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland ~ounty, Docket# 06-3084 Plaintiff: NadonsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. ih the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is qeing sent to you because research of public records indicate that you are, or may be a lienholder OIl the property secondary to the first mortgage, which is being foreclosed. This property alnd improvements are being sold pursuant to a judgment entered as indicated above in favor of the a~ove named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days afte~Said sale, and distribution will be made in accordance with the schedule unless exceptions are led thereto within ten (10) days after the date of the filing of said schedule. You should check wi h the Sheriffs Office by calling 717-240-6391 to determine the actual date of the filing of t e schedule. If you have a1 questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we u ge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. ! I I S' __-H M MARTHA: E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTIt A VENuE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. ../ /------- MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. MARTHA: E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: P A Department of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, P A 17128-1100 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder 011 the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. . . MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, P A 17013 Bureau of Compliance RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: WesleyJ. Young and Amanda I. Young Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. ~ Martha E. Von Rosenstiel . . MARTHA: E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTlI A VENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Clearance Support Section!ATTN: Sheriffs Sale Dept. 281230 Harrisburg, PA 17129-1230 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of tile owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. ~ Martha E. Von Rosenstiel . . MARTHA: E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire , Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27, 2006 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley.J. Young and Amanda I. Young Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are WesleyJ. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717-240-6391 to determine the actual date of the filing of tbe schedule. Uyou have any questions regarding the type of lien of the effect of the sheriffs sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. Martha E. Von Rosenstiel . . . . MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610)328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27,2006 TO: OCCUP ANTS/TENANTS 315 Pinedale Road Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation clo Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 315 Pinedale Road Carlisle, P A 17013 will be sold by the Sheriff of Cumberland County on December 6,2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because research of public records indicate that you are, or may be a lienholder on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717-240-6391 to determine the actual date of the filing of the schedule. If you have any questions regarding the type of lien of the effect of the sheriff's sale upon your lien, we urge you to CONTACT YOUR OWN.ATTORNEY, as we are not permitted to give you legal advice. ~--- Martha E. Von Rosenstiel bZ :( dOl 9nv QDDZ Vd 'A1U, :.; \ i i' _ d,U ~~l~::;t--!S :iF J ~~J j:JL:L:1(J L;r f;:r/"& ... . />.~' (,t ) fg; \V/ ~~ \:~:/ U U ) Martha E. Yon Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. 3815 South West Temple Salt Lake City, Utah 84165 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Wesley J. Young and Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 No: 06-3084 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wesley J. Young 1402 Pine Road Carlisle, P A 17013 Wesley J. Young 1628 Newville Road Carlisle, P A 17013 Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 Your house and! or real estate at 315 Pinedale Road, Carlisle, PAl 70 13 is scheduled to be sold at Sheriffs Sale on December 6, 2006 at 10:00 a.m. to enforce the court judgment of $64,074.81 obtained by NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. against you. NOTICE OF OWNERS RIGHTS YOU MA Y BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 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 contact 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 bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house 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. CUMBERLAND COUNTY BAR ASSOCA nON 2 LIBERTY A VENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717240-6391 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie J. Rase, Esquire July 27,2006 TO: Wesley 1. Young and Amanda I. Young 1402 Pine Road Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road, Carlisle, PA 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear SirIMadam: Please be advised that the property and improvements, if any, located at and known as 315 Pinedale Road Carlisle, P A, 17013 will be sold by the Sheriff of Cumberland County on December 6, 2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley 1. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. ~----- ----~..--_. Martha E. Von Rosenstiel MARTHA. E. VON ROSENSTIEL, P.e. ATTORNEY AT LAW 649 SOUTH A VENUE, UNIT 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 Leslie 1. Rase, Esquire July 27, 2006 TO: Wesley J. Young and Amanda I. Young 315 Pinedale Road Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 315 Pinedale Road, Carlisle, P A 17013 Amount of Judgment: $64,074.81 Date of Judgment: July 27, 2006 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-3084 Plaintiff: NationsCredit Financial Services Corporation c/o Select Portfolio Servicing, Inc. Defendants: Wesley J. Young and Amanda I. Young Dear SirIMadam: Please be advised that the property and improvements, if any, located at and known as 315 Pinedale Road Carlisle, P A, 17013 will be sold by the Sheriff of Cumberland County on December 6,2006 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wesley J. Young and Amanda I. Young. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. SinCe~relY. ------- ~"'~...",...~'- _"..,m_~".'" ~-- Martha E. V o:;osenstiel bZ :E dOl 80\! QOOl '~/J 'Alhl.l :l.:lltJ3HS ~~ .~ j() :LLUJ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3084 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONS CREDIT FINANCIAL SERVICES CORPORATION C/O SELECT PORTFOLIO SERVICING, INC., Plaintiff (s) From WESLEY J. YOUNG AND AMANDA I. YOUNG (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 gamishee(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 than a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $64,074.81 L.L. $.50 Interest FROM 7/28/06 TO SALE DATE AT $16.20 PER DIEM Atty's Comm % Atty Paid $168.56 Plaintiff Paid Due Prothy $1.00 Other Costs Date: AUGUST 2, 2006 (Seal) CURTIS R. LONG pr~thono~ rJ c:n/ ~. -Ud.~~~L ~~ Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P. O. BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Real Estate Sale # 47 On September 8, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as 315 Pinedale Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 8, 2006 By: UdLt J~ Real Estate Sergeant bl :f dO' 90V qUal "1ill/ dHi~ LJ J H ~L f ~~o Ijidl~J \j' j ~ ~ ~ ,- 1. ..... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot 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 25th day(s) of October and the 1st and 8th day(s) of November 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 #47 efore me thido~!\b~gALTW~~4.t~ Notarial Seal Teny L. Russell, Notary Public City Of Harrisburg, Dauphin County MyCommiss' Expires e6.2010 Member po"" 1I\I~r\iF A 0~' lion of Notaries I~ ~ NOTARY PUBLIC , CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA 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: October 20, October 27 and November 3, 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 T AND SUBSCRIBED before me this 3 day of November. 2006 NOT tAL SEAl lOIS E. SNYDER, Notary Public Carlisle 8oro, Cumberland County My Commission Expires March 5. 2009 IlEAL E8TATE St\Ut NO. 47 Writ No. 2006-3084 Civil NationsCredit Financial Services Corporation vs. Wesley J. Young and Amanda 1. Young Atty.: Martha Von Rosenstie1 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in Lower Frankford Town- ship, Cumberland County, Pennsyl- vania. more particularly bounded and described as follows, to wit: BEGINNING at a point in the cen- ter of a public road (township road) at corner of lands now or formerly of Albert Gutshall; thence along the center of said township road. North 85 degrees 31 minutes East, 260 feet to a point; thence by other lands now or formerly of Charles L. Myers. et UX, the following courses and dis- tances; North 04 degrees 54 min- utes West, 154.2 feet to an iron pin; North 46 degrees 22 minutes West. 244.95 feet to an iron pin; North 73 degrees 38 minutes West, 161.40 feet to a point, iron pin, in line of land now or formerly of Albert Gutshall; thence along lands now or formerly of Albert Gutshall. South 12 degrees 30 minutes East, 397.9 feet to a point In the center of the said township road, the Place of beginning. CONTAINING 2.047 acres, more or less, according to a survey made by Roger St. Germain and Associ- ates. registered Surveyor, on the 23rd day .of March, 1963. Tax Parcel #14-05-0421-026.