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HomeMy WebLinkAbout08-5307Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. ALMEDIN SALKIC Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE oS - sso7 &?J THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ALMEDIN SALKIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ALMEDIN SALKIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Finance Agency, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. 2. Defendant, ALMEDIN SALKIC, is an adult individual whose last known address is 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013. 3. On or about, February 28, 2006, the said Defendant executed and delivered a Mortgage Note in the sum of $71,600.00 payable to PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION ON LEESPORT BANK, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1941, Page 3889 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County in Mortgage Book 725, Page 804. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on March 01, 2008 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $69,495.52 Interest at $9.89 per day $2,393.38 From 02/01/2008 To 10/01/2008 ( based on contract rate of 5.1250%) Accumulated Late Charges $389.39 Late Charges $19.49 $136.43 From 03/01/2008 to 10/01/2008 Escrow Credit ($37.82) Attorney's Fee at 5% of Principal Balance $3,474.78 TOTAL $75,851.68 "Together with interest at the per diem rate noted above after October 01, 2008 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act No. 91 of 1983 (Homeowners' Emergency mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. A copy of said notices is attached hereto as Exhibit T". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.1250% ($9.89 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: < PURCELL, ICRUG & HAL ER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) r rya - 0 9 -2- A9 sb?NOTE Loan Number: 12306031 FEBRUARY 28, 2006 BLUE BELL PENNSYLVANIA [Dawl [City] [State]. 1408 BRADLEY DRIVE L214, CARLISLE, PENNSYLVANIA 17013 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U. S. $ 71, 6 0 0. 0 0 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is PHILADELPHIA FINANCTAL M R GAGE A DIVISICN OF L1 PORT BANK, A PE[NSMVANIA BANIC1 U CORPCRATIaN I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.125 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1 s t day of each month beginning on APRIL 1 2006 - I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on MARCH 1, 2 0 3 6 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 1767 SENTRY PARKWAY WEST, SUITE 220, BLUE BELL, PENNSYLVANIA 19422 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U. S. $ 389.85 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; n-c 1 ` wv i c--aingle ramily DpG `Q, 800-649-1362 Fannie Mae/Freddie Mac UNIFORM INSTRUMENT www.docme9k com Form 3200 1 /01 Page 1 of 3 3zoD.? +?' ? t, 1 and (b) any sums already collected from me which excdeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5 . 0 0 0 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a.written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep MULTISTATE FIXED RATE NOTE--Single Family DocAftgkdWftum= Boo-649-1362 Fannie Mae/Freddie Mac UNIFORM INSTRUMENT www.dbcmegk.com Form 3200 1 /01 Page 2 of 3 3200.mt the promises which I make in this Note. That Security 1'nstrumetit describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. (Seal) irrower (Seal) -Borrower (Seal) -Borrower - (Seal) -Borrower - (Seal) -Borrower - (Seal) -Borrower [Sign Original Only] ?cv n., i c ivv i c-oingle family Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3200 1/01 Page 3 of 3 Dochfagic9ft mo 800-649-1362 www.d0cmagfc.c0m a32M.mt ALLONGE LOAN#: 12306031 Borrower(s): ALMEDIN SALKIC Property Address: 1408 BRADLEY DRIVE L214, CARLISLE, PENNSYLVANIA 17013 Principal Balance: $71,600.00 Loan Date: FEBRUARY 2 8, 2 0 0 6 PAY TO THE ORDER OF Recourse Company Nav f- A By' SR VICE PRESIDENT JOHN MtTS " (Name) (Title) ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Commonwealth of Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II as more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. KNOWN AND NUMBERED as Unit L-214,1408 Bradley Drive, Carlisle, Pennsylvania 17013. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such changes for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. G? (" b (' t (16 (( J ) Date: May 7, zoos ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving Your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. (-?4q 1 b G HOMEOWNER'S NAME(S): rt GIEDIN SA MC PROPERTY ADDRESS: LOAN ACCT. NO.: 1408 BRADLEY DRIVE L214 CARLISLE, PA 17013-1271 0001350727 CURRENT LENDER/SERVICER: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 15057 Harrisburg, PA 17105-5057 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to- face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are eery limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 1408 BRADLEY DRIVE L214, CARLISLE, PA 17013-1271 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months March, 2008 thru the first of May, 2008 in the amount of $1,536.00 plus late charges that have accrued in the amount of $161.43. THE TOTAL AMOUNT DUE IS $1,761.43. This includes all payments, fees, and expenses due, less any funds we are holding in suspense. HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,761.43 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: PENNSYLVANIA HOUSING FINANCE AGENCY 211 N FRONT STREET P.O. BOX 15057 HARRISBURG. PA 17105-5057 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the morteage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY aeriod you will not be required to aay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due, plus anv late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately three months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 717-780-3804 (fax) Contact Person: II(IMMBERLEY AYALA Counseling Agencies: In addition to mailing the Appendix B, Notice of Face-of-Face Meeting, please notify PHFA (when we are the first lien holder) of the face-to-face meeting and pending submission of application for HEMAP assistance by sending an e-mail to Kayalaaawhfa.org. If you do not have access to e-mail, please call Kim Ayala at 717-780-1815 and advise of the face-to-face meeting. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. (This does not apply if your mortgage was originated under the HomeStart Program.) YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY PHFA CCCS of Western PA Community Action Commission of 211 North Front Street 2000 Linglestown Road Captial Region 1514 Deny Street Harrisburg, PA 17110 Harrisburg, PA 17102 Harrisburg, PA 17104 717.780.3940 888.511.2227 717.232.9757 Maranatha Adams County Interfaith Housing Loveship, Inc. 43 Philadelphia Avenue Authority 2320 North 5th Street 40 E High Street Harrisburg, PA 17110 Waynesboro, PA 17268 Gettysburg, PA 17325 717.232.2207 717.762.3285 717.334.1518 F1 PENNSYLVANIA HOUSING FINANCE AGENCY Single Family Programs Division 211 North Front Street P.O. Box 15057 Harrisburg, PA 17105-5057 (717) 780-3870 / (717) 780-1869 TDD # For The Hearing Impaired NOTICE May 7, 2008 ALMEDIN SALKIC 1408 BRADLEY DRIVE L214 CARLISLE, PA 17013-1271 RE: Account #: 0001350727 TO: ALMEDIN SALKIC 1408 BRADLEY DRIVE L214 CARLISLE, PA 17013 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. Enclosure: Housing Counseling List HOUSING COUNCIL OF YORK 116 N George St York, PA 17401-1106 Phone: 717-854-1541 TABOR COMMUNITY SERVICES 439 E King St. Lancaster, PA 17602-3004 Phone: 717-397-5182 7160 3401 4645 4603 1621 TO: ALMEDIN SALKIC 1408 BRADLEY DRIVE L214 PHEASANT RUN CARLISLE, PA 17013-1271 SENDER: BASSETT REFERENCE: 1350727 Go Co -+ b o O b \\ L a ..? a o N o M 111 dM \\ O I •• M M M O m N w ~ fV wag 0 0 , G S i o 90 r a a? c ?Q d Q W 1 N V w I:° M Cr N OQ r ? o 14 V O 1,Jf ro fo c u @I 0 s i,,"3 a 1 . c zip r, ODE ` 7 b RETURN POMP RECEIPT C.rWW Fee .59 SERVICE 2.65 RNurr1 RWIpt Pei Rea Tm Post"* & Fep US Postal Service Receipt for Certified Mail ' ?y No IMUrarlp Covsrap Provided Do Not Use for Irnemauorlsl MaN G?iO -------- - ---- -- - ---- ----------- -------- W CJI O N b ? a P m 0 J p ?C Q 1 d 4 A .d ff" 00 r i'1G rC 0 ?." A ? n r W cr .? 0 W N I mss ~ on fU ba 000 VERIFICATION Anthony J. Julian hereby states that he is the Director of Accounting and Loan Servicing of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: (?13Q F Anthony J. Juli Director of Accounting and Loan Servicing PENNSYLVANIA HOUSING FINANCE AGENCY SERVICING AGENT FOR U. S. BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY v ? ?a 9.1 ;? .?(? "1/ \, \,, ?`) V N A C? r,? ,. `? =ii t?_' G-' ._..t r ;.? ; i- J _ U} ??, 3 ?.? ?? ??,'? SHERIFF'S RETURN - REGULAR CASE NO: 2008-05307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS SALKIC ALMEDIN STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SALKIC ALMEDIN the DEFENDANT , at 2110:00 HOURS, on the 11th day of September, 2008 at 1408 BRADLEY DRIVE L-214 CARLISLE, PA 17013 was served upon by handing to DIJANA SALKIC, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 00 /b/b 40y 3 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 09/15/2008 PURCELL KRUG HALLER By: eputy Sheriff A. D. CASE NO: 2008-05307 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS SALKIC ALMEDIN STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TENANT the DEFENDANT at 2110:00 HOURS, on the 11th day of September, 2008 at 1408 BRADLEY DRIVE L-214 CARLISLE, PA 17013 by handing to DIJANA SALKIC, WIFE OF ALMEDIN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 10/6 46, 6s Q- Sworn and Subscibed to before me this of So Answers: 6.00 .00 * 00 10.00 R. Thomas Kline .00 16.00 09/15/2008 PURCELL KRUG HALLER By: day pu y IM-e A. D. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF ALMEDIN SALKIC, vs. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) ALMEDIN SALKIC for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest Per diem of $9.89 From 02/01/2008 To 10/01/2008 Accumulated Late Charges Late Charges ($19.49 per month to 10/01/2008) Escrow Credit 5% Attorney's Commission TOTAL $69,495.52 $2,393.38 $389.39 $136.43 ($37.82) $3,474.78 $75,851.68 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HALLER By Leon P. Haller PA I.D. # 15760 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 If U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on October 6, 2008 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. # 5700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 If U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ALMEDIN SALKIC Defendant DATE OF THIS NOTICE: October 6, 2008 TO: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-05307 CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALLER By -? LEON P. LLER, Att ey for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this L19- day of 2061F otary Public LEON P. HALLER, ESQUIRE COMMONWEALTH OF PENNSYLVANIA Notauial SCI Traci M. Bernstein. Notary F21, City Of Harrisburg, Dauphin y My Cornmission E)ires Aug. 11 Member, Peirmsvty ;,!-, A s-,, i3tion of Notaries r-s df IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2008-05307 U.S. BANK NATIONAL ASSOCIATION TRUSTEE Total Judgment Amount $75,851.68 FOR THE PENNSYLVANIA HOUSING FINANCE Interest $1,523.06 AGENCY, Per diem of $9.89 to sale PLAINTIFF date 3/4/2009 Late Charges $603.78 VS. $19.49 per month to sale date 3/4/2009 ALMEDIN SALKIC, Escrow Deficit $1,428.25 DEFENDANT(S) Property Inspection $124.00 TOTAL WRIT $79,529.77 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, March 04, 2009 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: November 18, 2008 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY 4L ?k ~ W ?' r ril Ir ?s °Qo°°$g= J v b" O r = _ -nom Wit,, (0) U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Philadlephia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 J 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unworn falsification to authorities. Leon P. Haller PA I.D. # 157-0 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 18, 2008 c:: U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: Wednesday, March 04, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC Ij v A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5307 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From ALMEDIN SALKIC (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 $75,851.68 L.L. $.50 Interest per diem of $9.89 to sale date 3/04/09 -- $1,523.06 Atty's Comm % Due Prothy $2.00 Atty Paid $168.00 Other Costs: Late Charges - $19.49 per month to sale date 3/04/09 -- $603.78 Escrow Deficit - $1,428.25 Property Inspection - $$124.00 **Plus additional interest, late charges and other costs to date of sheriffs sale. Plaintiff Paid Date: 11/19/08 nn k ti Long, Prothonota (Seal) By: Deputy REQUESTING PARTY: Name: LEON P HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-2344178 Supreme Court ID No. 15700 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on A5 1:2 M, a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 Philadlephia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINEKA NICHOLE M. STALEY O'GORMAN LISA A. RYNARD LATOYA C. WINFIELD lax0a, g% t y ? V 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 233-1149 HERSHEY (717) 533.3836 JOSEPH NISSLEY (1910.1982) JOHN W. PURCELL VALERIE A. GUNN Of Counsel ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 Philadlephia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1' Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. 50? - By: Leon P. Haller PA I.D.1 700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 04, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $759851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L 7160 3401 1645 7318 6211 T0: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 SENDER: NOS 03/04/09 REFERENCE: PHFA/SALKIC 71LD 3101 4645 7316 6204 TO: ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 SENDER: NOS 03/04/08 REFERENCE: PHFA/SALKIC RETURN FOG" j RECEIPT CerWW Fes t SERVICE Return Receipt Fee Restricted Delivery Total Posteps 3 Fen 4,10 I 4 US Postal Service POSTMARK OR DATE i Receipt for Certified Mail No Insurs,%ce Coverage Provided Do Not Use for Intemational Mall ---------------- ------- --------------- - ------------ --------- RETURN ape RECEIPT Cw"ed Fee SERVICE ReWm Receipt Fee i- nY. -i r,eIa.s... I ToW Poetepe & Fees US Postal Service Receipt for Certified Mail No insurance Coverage Provided Do Not Use for krtemational Mail POSTMARK OR DATE y, PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 3/412009 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street •1 Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 O P% o ?. ,? -apyr q PITNEY 60WF5 ti 02 1A $ 01.100 0004353871 NOV 25 2008 MAILED FROM ZIP CODE 1 710 2 J- PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 3/4/2009 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Philadlephia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Members 1" Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 ??P?ES P03T? MOW 'MOMMOOMW O ' A RINEY BOM7E5 02 1A $ 01.100 0004353871 PrDV 25 2008 MAILED FROM ZIP CODE 1 710 2 PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 3/4/2009 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 "es PCs)! 0 49 - PITNEY Bowl 5 02 1A $ 01.10° 0004353871 NOV 25 2008 MAILED FROM ZIP CODE 1 71 02 ° 4 ? C7 ?,' ? `? ? ` ? ?? ` t_ , r? f..> ? ? i -9 . 11 ?.? 4???. '_'?' f ?y may' ? j ? ?" '?? ?? '^? ..1L, ?` U.S. Bank National Association Trustee In The Court of Common. Pleas of For the Pennsylvania Housing Finance Cumberland County, Pennsylvania Agency Writ No. 2008-5307 Civil Term VS Almedin Salkic Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 06, 2008 at 1339 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: Almedin Salkic, by making known unto Almedin Salkic personally, at 1408 Bradley Drive, L 214, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 16, 2009 at 1052 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property, of Almedin Salkic located at 1408 Bradley Drive, L 214, 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: Almedin Salkic, by regular mail to his last known address of 1408 Bradley Drive, L 214, Carlisle, PA 17013. This letter was mailed under the date of January 9, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Levy Surcharge; Postpone sale Law Journal Patriot News Share of bills 30.00 27.72 15.00 15.00 50 n _J . 2.00 9.00 15.00 20.00 20 00 _ . . ; J 647.00 .3 596.84 ..< 15.52 1,413.58 ? `' ?a Y? n So Answers: R. Thomas Kline, Sher' f B Rea Estate Coordinator G?t? Cc . J 5'D lti tom, a ;? ?/? y U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Philadlephia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA, 19422 Members I" Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, 13A 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 117013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, 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. Leon P. Haller PA I.D. # 15706 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 18, 2008 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 04, 2009 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY: IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights.. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. 'You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and :recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania„ as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, :PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/l/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLE) AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L WRIT OF EXECUTION and/or A'T'TACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-5307 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, Trustee for THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From ALMEDIN SALKIC (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 $75,851.68 L.L. $.50 Interest per diem of $9.89 to sale date 3/04/09 -- $1,523.06 Atty's Comm %> Due Prothy $2.00 Atty Paid $168.00 Other Costs: Late Charges - $19.49 per month to sale date 3/04/09 -- $603.78 Escrow Deficit - $1,428.25 Property Inspection - $$124.00 **Plus additional interest, late charges and other costs to date of sheriff's sale. Plainti$' Paid Date: 11/19/08 Long, Prothonotary (Seal) By: L Ni°Lao- K , Deputy REQUESTING PARTY: Name: LEON P HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Real Estate Sale #57 On November 24, 2008 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 1408 Bradley Drive, L 214, Carlisle more fully described on Exhibit ``A" filed with this writ and by this reference incorporated herein. Date: November 24, 2008 By: Real Estate Sergcaii, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. 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: January 30, February 6, and February 13, 2009 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. Marie Coyne, SWORKTO AND SUBSCRIBED before me this 13 day of Februa 13 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMSERLA 41) COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 57 Writ No. 2008-5307 Civil U.S. Bank National Association Trustee for the Pennsylvania Housing Finance Agency vs. Almedin SaMe Atty.: Leon Haller ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Town- ship, Cumberland County, Penn- sylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amend- ment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et, seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the here- inafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II tts more fully descnbea ir, saif; Declaration and Plans, together wgtl a proportionate undivided interest ii the Common Elements of .005952-; percent as more fully set forth ,i the aforesaid Declaration and Plans. There are no recorded amendment,,, to the above-mentioned Declaration Code of Regulations or Plans, except as aforementioned THE GRANTEE, for ai ct oii -lli ' of the Grantee and her Heirs, pc sonal representatives, successor,, and assigns, by the acceptance of this deed covenants and agrees to pa,\ such charges for the maintenance of, repairs to, replacement of and expenses in connection with the com mon elements as may be assessed from time to time by the Council in accordance with the J_Tnit. Property' Act of Pennsylvania, as amended. and further covenants and agrees that the Unit conveyed by this deed shall be subject to a ,:harge foi aUiIoun is so assvsseO, I th,,` cept insofar as Sections 705 and 700 of said Unit Property Act mav relieve. a subsequent unit owner of_liability; for prior unpaid assessments, thi?, covenant shall run with and bind th e land or unit hereby conveyed and all subsequent owners thereof. = l i UNDER AND SUBJECT to agreements, conditions; easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in th( Declaration of Condominium, Coder of Regulations and Declaration Plan as amended. HAVING THEREON ERECTED P. DWELLING KNOWN AS 1408 BIadle\r Drive L 214, Carlisle, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald .! Wilson, by Deed dated 2?70/06 anel recorded 3/1/06 i,r, ?11`umberlan,' Countv Deed Book 273. Page 1733 granted and conveyed Canto Alrnedl' Salkic. TO BE SOLD AS l tlr PROA:;,R OF ALMEDIN SALKIC ON IUDC, MENT NO. 2008-05307 ASSESSMENT NO. 29 015B-02214-L. The Patriot-News Co. 812 Market St.. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe patriot-News Now you know 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 on the date(s) indicated below. 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 This ad ran on the date(s) shown below: REAL ESTATE SALE NO. 57 01/21/09 Writ No. 2008.5307 Civil Term U.S. Bank National Association 01/28/09 Trustee for the Pennsylvania Housing Finance Agency 02/04/09 VS Almedin SaUdc Attorney Leon Haller LEGAL DESCRIPTION nit,nln CEKrAWcondominium unit inthe Sworn to anX scribed before me this 25 day of.february, 2009 A.D. property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland Tr- County, Pennsylvania and which Declaration of Notary Public Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named COMMONWEALTH OF Rn=NNSYLVAl+iIA Recorder's Office in Miscellaneous Record Not, laai sk, I ?- Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated Sherrie L , lVuY. ty Pt?blic November 14,1985, and recorded December 23, CKy Of Hamst?ta±e, C)°LPhbt COrMI(y 1985, in the hereinafter mentioned Recorders MlrCommlesion Et?ir' Nov. 26, 2011 office in Miscellaneous Record Book 312, Page 14e"11W, Fmnsylva o iat(on of Nola s 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mooed Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together a,:a, . r,.a. .1 Q.A2fimc for Pheasant Run Coodom mum Association dated September 17, 19M and mcmded 24,19K in the bemalft named Rooorder's Office rn Mmellamem Food Book 258, Page 25 et seq., and 109rd r WA pleas recorded in the hereinafter named Rooardtr's in plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: Ir214 (1 Be&wms) Floor, Second Building: 11 As mute fully deKaW w said Declaration and P1W *Pdwr WA a ptppolumate undivided iBftW in ft of .OrA524 percent as mw #*_dp kft is the aforesaid Declambon and BIm Tbme are no recorded amendments to the above-mentitmed Decluatton, Code of Regulations or mans, esoeptas eforemwtioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, persmal mp ueatati es, succrosm, and aasignc, by the acceptance of this deed covenants Aodl apees to pay such charges for the maigetuace of_,-repairs -W. replacement of and expenses in connection with the common elements as may be assessed from tune to time by the Council rn accoiianae with the Unit Property Act of Pennsylvania, as amended, and feet w cmu uts and agrees that the Unit convteyed by this deal sleek be *ject to a charge for all amamts so assessed and that; except insofar as Sections 705 and 766 of said Unit Pmpeq Act may relieve a subsequent unit owner of h* ft for prior unpaid assessments, this covenant shall nm with and bind the land or unit hereby.caavepad SW al *6sogaaut acmers thereof. UNDER AND SUBJECT to all agreements, coraRtim, eammmts and r stiictim of record and to the ptoivrsrbns, easemmts, wveo " and restritkim as contained in the Declaration of Coadombk m, Code of Rgduwns and Declaration Platt, as amended. HAVING THERBGN ERECTED A DWE[3.11!iG KNOWN As 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME MWISES WHICH Dmtme;G. EBis nNm Dome G. Wilson and Ronald 7. Wilm by Deed dated 2tlW and recorded 3(146 in Cmbmbnd Cmmty Deed Book 273, Page 1733, pasted and conveyed unto Abudin SWW. TO BE SOLD AS THE PROPERTY OF ALWWW SALIUC ON AWMENT NO. ASWRNWW,F-NO. 29-17-1583-015B-02214- L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2008-05307 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) Total Judgment Amount $75,851.68 Interest $8,032.48 Per diem of $9.89 to sale date 6/2/2010 Late Charges $1,349.91 $19.49 per month to sale date 6/2/2010 Escrow Deficit $3,043.02 Property Preservation $487.93 TOTAL WRIT $88,765.02 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, June 02, 2010 (PROTHONOTARY'S USE) Plt£ Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: February 16, 2010 Attorney for Plaintiff 1719 North Front Street Leon . Haller Harrisburg, PA 17102 PA I.D. #157 0 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L Fi ED _ 20 10 FEB 17 API 13: 3 J S.. ©o ?. IV13. -5 )0 a? 06- a .Oo 6 - U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF ALMEDIN SALKIC, VS. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN n C-_ may. 9 N C= cn ?.I Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this &- day of (--Q b 2016) " IW( Notary Public LEON P. HALLER, ESQUI COMMONWEALTH OF PENNSYLVANIA NOW1815ea1 Traci M. 5amateln, Notary Public City of HarrllbwZ Dauphin County My CommMpon HXOM Aug. al, 2011 Member, l e ylvanla Amoladun of Notaries ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC1. GMENT N 2008-05307 C f 83.E d IOZ ASSESSMENTNO.29-17-1583-015B-02214-L U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1408 BRADLEY DRIVE, L 214 CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ALMEDIN SALKIC 1408 BRADLEY DRIVE w L 214 ='- -- - +T CARLISLE, PA 17013 ALMEDIN SALKIC t CD 1008 PHEASANT DRIVE, NORTH = w CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Philadelphia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, 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. Leon P. Haller PA I.D. # 15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 16, 2010 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALVIEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: : That the Sheriff s Sale of Real Property (real estate) will be held: -„ DATE: Wednesday, June 02, 2010 =;- „r TIME: 10:00 O'clock A.M. ' `? ? c ca . , LOCATION: Cumberland County Courthouse ?a Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-5307 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U. S. Bank National Association Trustee for The Pennsylvania Housing Finance Agency Plaintiff (s) From Almedin Salkic (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 $75,851.68 L.L. Interest per diem of $9.89 to sale date 6/2/2010 $8,032.48 Atty's Comm % Due Prothy $2.00 Atty Paid $1603.08 Other CostsLate charges $19.49 per month to sale Escrow Deficit $3,043.02 date 6/2/2010 $1349.91 Property Preservation $487.93 *Plus additional interest, late charges and other costs to date of sheriffs sale. Plaintiff Paid Date: 2/17/2010 l Davi . Buell, P othonotary (Seal) By: Deputy REQUESTING PARTY: Name Leon P. Haller, Esq Address: 1719 North Front St. Harrisburg, PA 17102 Attorney for: PLAINTIFF Telephone: (717) 234-4178 Supreme Court ID No. 15700 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C? c?- NO. 2008-05307 IN MORTGAGE FORECLOSE SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 a s? --r W -st r The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013: Name and address of the Owner(s) or Reputed Owner(s): ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: Leesport Bank P.O. Box 741 Leesport, PA 19533 5. Name and address of every other person who has any record lien on the property: North Municipal Authority 240 Clearwater Drive Carlisle, PA 17013 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: UNKNOWN U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLE na CUMBERLAND COUNTY, PENNSYAI1 'V CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE D c u's RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on IllQ ?;C? I CJ , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 Philadelphia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 By PURCELL, KMUG% HALLE Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINEKA WHOLE M. STALEY O'GORMAN LISA A. RYNARD Po4a&j Gj 94 HAM. 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 233-1149 HERSHEY (717) 533-3836 JOHN W. PURCELL(1924-2009) JOSEPH NISSLEY (1910-1982) ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 Philadelphia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1St Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. -1-1?01 By: Leon P. Haller P/K I.D.15700 Attorney for Pl ntiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 02, 2010 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg., PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 2008-05307 AFFIDAVIT OF SERVICE U.S. Bank National Association Trustee for the Pennsylvania Housing Finance Agency vs. Almedin SaUdc Commonwealth of Pennsylvania County of Dauphin ss. I, Jack C. Garner, a competent adult, being duly sworn according to law, depose and say that at 3:45 PM on 05/01/2010,1 served Ahnedin Salkic at 537 North Hanover Street, Apt. #10 , Carlisle, PA 17013 in the manner described below: ? Defendant(s) personally served. ® Adult family member with whom said Defendant(s) reside(s). Relationship is Alem Salkic, Brother. ? Adult in charge of Defendant(s) residence who refused to give name and/or relationship. ? Manager/Clerk of place of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? an officer of said Defendant's company. ? Other: a true and correct copy of Notice of Sheriffs Sale of Real Estate Pursuant to Pennsylvania Rule of Civil Procedure 3129.1 issued in the above captioned matter. Description: Sex: Male - Age: 25 - Skin: White - Hair: Black - Height: 5'10" - Weight: 165 X l Sworn to and subscr'bed before me on this J k C. Garner day of / 20?, nkowsky Investigations st Office Box 126538 Harrisburg, PA 17112 (800) 276-0202 KTH OF PENNSYLVANIA Notarial Seal Atty File#: P01455/34374-08 - Our File# 11338 Inkowsky, Notary Public w TWp., Dauphin County 'nn EYnirm Seot. 28, 20 00 Law Firm: Purcell, Krug and Haller Address: 1719 North Front Street, Harrisburg, PA, 17102-2392 Telephone: (717) 234-4178 7160 3901 9848 7275 5569 TO: ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 SENDER:PHFA/SALKIC REFERENCENOS 06/02/10 RETURN Postage 061 RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service POSTMARK OR DATE Receipt for '%; Certified Mail No insurance Coverage Provided Do Not Use for Internation, Mail y' 7160 3901 4848 7275 5590 TO: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 SENDERpHFA/SALKIC REFERENCEKOS 06/02/10 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted (;elivery Total Postage & Fees US Postal Service ' Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ---------°---..... POSTMARK OR DATE i PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 6/2/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Postage: Postmark: O?P? P?Tg4 F 7 NTrrv nowEs 0 2 11Ui $ 01.150 0004284324 FEB 1 9 2010 ti MAILED FROM ZIP CODE 17 10 2 PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 6/2/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Philadelphia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 U. S. POSTAL SERVICE CERTIFICATE OF MAILING In compliance with Postal Service Form 3877 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Members 1" Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 vSesPOSTF J 7 PI7 NEY ROWES 02 1M $ 01.15° 0004284324 FEB 1 9 2010 f MAILED FROM ZIP CODE 1 710 2 PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 6/2/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comaliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 'wes P% , 5 461d RIENEY BOy/E'S„ 02 1M $ 01.150 0004284324 FEB 19 2010 MAILED FROM ZIP CODE 17102 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. ALMEDIN SALKIC, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSY?VAN4A c? CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE,. SUPPLEMENTAL RETURN OF SERVICE ti r ?Q ? I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on L. -193 120) 0 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Leesport Bank P.O. Box 741 Leesport, PA 19533 Pheasant Run Condominium Association 1824 Sterretts Gap Avenue Carlisle,PA 17013 North Middleton Authority 240 Clearwater Drive Carlisle, PA 17013 PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES Purcell, Krug & Haller HOWARD B.KRUG 1719 NORTH FRONT STREET HERSHEY LEON P.HALLER HARRISBURG, PENNSYLVANIA 1 7 1 02-23 92 (717) 533-3836 JOHN W.PURCELLJR. TELEPHONE (717) 234-4178 JILL M. WINEKA FAX (717) 233-1149 JOHN W. PURCELL(] 924-2009) NICHOLE M.STALEY O'GORMAN LISA A. RYNARD JOSEPH NISSLEY (1910-1982) Leesport Bank P.O. Box 741 Leesport, PA 19533 Pheasant Run Condominium Association 1824 Sterretts Gap Avenue Carlisle,PA 17013 North Middleton Authority 240 Clearwater Drive Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your inter7?t any, by being notified of said Sheriffs Sale. By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 02, 2010 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L <Y PENNSYLVANIA HOUSING FINANCE AGENCY v. ALMEDIN SALKIC Cumberland County Sale 6/2/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Leesport Bank P.O. Box 741 Leesport, PA 19533 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Pheasant Run Condominium Association 1824 Sterretts Gap Avenue Carlisle,PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: North Middleton Authority 240 Clearwater Drive Carlisle, PA 17013 ±Sij OIOl ' Z r z ?q- ges PONr .? PITNEY BOWES 5 4 02 1M $ 01.150 0004284324 A.PR23 2010 MAILED FROM ZIP CODE 1 710 2 SHER141S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson • L. Sheriff 7 0??1? 01 ?a?nber'? . tt , .. ^ .A^,tn,Y Jody S SmithA Chief Deputy Cs ,, 2 E " r Richard W Stewart Solicitor OFFCE,.-'?E SgERIFF U S Bank National Association vs. Case Number Almedin Salkic 2008-5307 SHERIFF'S RETURN OF SERVICE 03/30/2010 07:17 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2010 at 1915 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 Almedin Salkic, located at 1408 Bradley Drive L 214, Carlisle, Cumberland County, Pennsylvania according to law. 04/28/2010 02:38 PM - Valarie Weary, Deputy Sheriff, who being duly sworn according to law, states that on 4/28/10 at 1438 hours, she 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: Almedin Salkic, by making known unto, Almedin Salkic, personally, at, 537 N. Hanover Street, Apartment 10, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same 06/03/2010 Ronny R. Anderson, 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 June 2, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon Haller, on behalf of U. Bank National Association, Trustee for the Pennsylvania Housing Finance Agency, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,341.57 SHERIFF COST: $1,341.57 July 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF I 00 rd, 04k loc.00, 77? 9? (c) CountySuite Sheriff. Teleosott. Inc. .. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT10N LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1408 BRADLEY DRIVE, L 214 CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ALMEDIN SALKIC 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ALMEDIN SALKIC 1008 PHEASANT DRIVE, NORTH CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Philadelphia Financial Mortgage a division of Leesport Bank 1767 Sentry Parkway West Suite 220 Blue Bell, PA 19422 Members 1 s` Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 i 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 Deanna Salkic 1800 Pheasant Drive, North Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 16, 2010 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ALMEDIN SALKIC, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2008-05307 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL, PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: Wednesday, June 02, 2010 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2008-05307 JUDGMENT AMOUNT $75,851.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ALMEDIN SALKIC A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. R YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg PA 17102 (717) 234-4178 ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, personal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED A DWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2008-05307 ASSESSMENT NO. 29-17-1583-015B-02214-L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N008-5307 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U. S. Bank National Association Trustee for The Pennsylvania Housing Finance Agency Plaintiff (s) From Almedin Salkic (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 $75,851.68 L.L. Interest per diem of $9.89 to sale date 6/2/2010 $8,032.48 Atty's Comm % Due Prothy $2.00 Atty Paid $1603.08 Other CostsLate charges $19.49 per month to sale Escrow Deficit $3,043.02 date 6/2/2010 $1349.91 Property Preservation $487.93 *Plus additional interest, late charges and other costs to date of sheriffs sale. Plaintiff Paid Date: 2/17/2010 (Seal) ??)a Davi uell, Prothon tary By: Deputy REQUESTING PARTY: Name Leon P. Haller, Esq Address: 1719 North Front St. Harrisburg, PA 17102 Attorney for: PLAINTIFF Telephone: (717) 234-4178 Supreme Court ID No. 15700 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in o North Middleton Township, Cumberland County, PA, n rKnown and numbered as, 1408 Bradley Drive, L 214, Carlisle, - Snore fully described on Exhibit "A" filed with this writ and -by this reference incorporated herein. Date: March 22, 2010 By: Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. 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 16, April 23, and April 30, 2010 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. a Marie Coyne, Ej4itor SWORN TO AND SUBSCRIBED before me this 0 day of April, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notu y Pub CARLISLE BOROUGH, CUMBERLAND COUNTY My Com"Slon Expires App 26, 2014 1Osk So. 90084307 CWK U S Bank National Association as Trustee VS. Almedin Salkic Atty: Leon P. Haller ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Town- ship, Cumberland County, Penn- sylvania and which Declaration of Condominium for Pheasant Run Condominiums dated September 17, 1980 was recorded September 24, 1980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 776 et. seq., and was further amended by Amend- ment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the here- inafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et. seq., and together with plans recorded in the hereinafter named Recorder's Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit: L-214 (2 Bedrooms) Floor: Second Building: II tr: to `; As more fully described in said Declaration and Plans, together with a proportionate undivided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. There are no recorded amendments to the above-mentioned Declaration, Code of Regulations or Plans, except as aforementioned. THE GRANTEE, for and on behalf of the Grantee and her Heirs, per- sonal representatives, successors, and assigns, by the acceptance of this deed covenants and agrees to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the com- mon elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, ex- cept insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and all subsequent owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as amended. HAVING THEREON ERECTED a dwelling known as 1408 Bradley Drive L 214, Carlisle, PA 17013. BEING THE SAME PREMISES WHICH Dorene G. Ellis n/b/m Dorene G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 3/1/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almedin Salkic. TO BE SOLD AS THE PROPERTY OF Almedin Salkic on Judgment No. 2008-05307. ASSESSMENT NO. 29-17-1583- 01513-02214-L. The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Pahiot News Now you know 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 on the date(s) indicated below. That neither she 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 she 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 This ad ran on the date(s) shown below: 04/16/10 04/23/10 c \ 04/30/10 r _Z' to? ibscribed before e to 18? y of May, 2010 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Serb Sherrie L. Klow, Notary Public Lower Paxton TWp., Dauphin County My Commisslon Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries V4rft No. 20086307 Civil Term "Oft NNIonal Assocfaft a to Thotee " va. A6nedin Shcldc Arty: Leon P. Haller ALL THAT CERTAIN condominium unit in the property known, named, and identified in the Declaration of Condominium referred to below as Pheasant Run Condominiums, located in North Middleton Township, Cumberland County, Pennsylvania and which Declaration of Condominium for Pheasant Run Condominiums datedSeptemba 17,1980wastecardedSeptgnber 24,4980 in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 6, et. seq., and which Declaration was amended by Amendment dated November 14, t985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's. Office in Miscellaneous Record Book 312, Page 776 et. seq., and was furtheramendedby Amendmed datedNovember 14, 1985, and recorded December 23, 1985, in the hereinafter-mentioned Recorder's Office in Miscellaneous Record Book 312, Page 783 et. seq., together with a Code of Regulations for Phemm gun Condominium Association dated Septem 17„ 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, Page 25 et seq., and together with plans recorded intite hereinafter awed Recordees Office in Plan Book 29, Page 7 and Plan Book 38, Page 112, and being designated as: Unit; j`214 (2 Bedrooms) Flora: Second $uilding: 11 As more fully described in said Declaration and Plans, together with a i proportionate undriided interest in the Common Elements of .0059524 percent as more fully set forth in the aforesaid Declaration and Plans. Then are no recorded amp to the above-mentioned Dectration, Code of Replationsor Pbm, except as iforememiooed. THE GRANTEE, for and on behalf of the Greelve and her Hein, pees" ruprrwetives, secee moors, and aerrgwby the aooeptam of this deed covenants and agrees to pay such charges "for`the maiatetwo of, repairs b, repiacemeat of and expo t in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and agrees that the Unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and 706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed and alt subsegmtut owners thereof. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of recofd and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plan, as HAVING4HEREONER IEDADWELLING KNOWN AS 1408 BRADLEY DRIVE L 214 CARLISLE, PA 17013 ' BEING THE SAME PREMISES WHICH Doren G. Ellis uNm Doren G. Wilson and Ronald J. Wilson, by Deed dated 2/10/06 and recorded 311/06 in Cumberland County Deed Book 273, Page 1733, granted and conveyed unto Almredin Salkic. TO BE SOLD AS THE PROPERTY OF ALMEDIN SALKIC ON JUDGMENT NO. 2*.05307 AS,%SS M- 29-17-1583-015B-02214- L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which PENNSYLVANIA HOUSING FIN AGENCY TR is the grantee the same y? _3 having been sold to said grantee on the 2ND day of JUNE A.D., 202010, under and by virtue of a writ Execution issued on the 17TH day of FEBRUARY, A.D., 2010', out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 5307, at the suit of PENNSYLVANIA HOUSING FIN AGENCY against ALMEDIN SALKIC is duly recorded as Instrument Number 201019101. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 16, ,A.D.? (L, day of of Deeds pan efoeeftegftft *9% CON' 61A