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Home My WebLink About09-1597Leon 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. JOSEPH S. SPEECE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ?l 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 RAN 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 "ISO. 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, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE JOSEPH S. SPEECE, Defendant 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. JOSEPH S. SPEECE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 01 - /S"? 7 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE 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 the Pennsylvania Housing Finance Agency, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. 2. Defendant, JOSEPH S. SPEECE, is an adult individual whose last known address is 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050. 3. On or about, November 21, 2007, the said Defendant executed and delivered a Mortgage Note in the sum of $131,929.00 payable to PHILADELPHIA FINANCIAL MORTGAGE a division of 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 on November 29, 2007 as Instrument Number 200744593 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on November 29, 2007 as Instrument Number 200744596. 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: 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 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 August O1, 2008 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $130,941.50 Interest at $21.37 per day $5,876.75 From 07/01/2008 To 04/01/2009 ( based on contract rate of 5.8750%) Accumulated Late Charges $218.54 Late Charges $31.22 $249.76 From 08/01/2008 to 04/01/2009 Escrow Deficit $442.31 Attorney's Fee at 5% of Principal Balance $6,547.08 TOTAL $144,275.94 "Together with interest at the per diem rate noted above after April 01, 2009 and other charges and costs to date of Sheriffs 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 to accelerate the loan balance was sent to the Defendant by letter dated October 17, 2008 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the October 17, 2008 Act 6 Notice is attached hereto and marked Exhibit "C". 10. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 11. The 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. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure 66IN REM" for the aforementioned total amount due together with interest at the rate of 5.8750% ($21.37 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: P C,RUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) OI 44 lAl NOTE as -/00 c? i&F-) 0 7 NOVEMBER 21, 2007 Patel Loan Number: 124007332 FHA CASE NO. 441-8082831 306 SAINT MARKS ROAD, MECHANICSBURG, PENNSYLVANIA 17050 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assi gns . "Lende ans r" me PHILADELPHIA FINANCIAL MORTGAGE A DIVISION rs Lsm 33o T BANK, A PENNSYLVANIA BANKING CORPORATION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED THIRTY-ONE THOUSAND NINE HUNDRED TWENTY-NINE AND 00/100 (U. S. $ 131,929.00 ), plus interest, to the order of Lender. Interest will be charged on Dollars from the date of disbursement of the loan proceeds by Lender, at the rate of FIVE AND p paid principal, until the full amount of percent ( 5 . 875 %) per Year principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on JANUARY 1, 2008 DECEMBER 1, 1 2037 , 2 • Any Principal and interest remaining on the first day of will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 1044 MACARTHUR ROAD, READING, PENNSYLVANIA 19605 or at such other place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 7 8 0 .41 This amount will be part of a larger monthly payment required by the security instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for Payment Adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. (Check applicable box.) ? Growing Equity Allonge ? Graduated Payment Allonge ? Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. MULTMAM-PHA PIEW RATE NOTE (6/96) ??C Doa,meo, SM?, &C. WCO 649-130 Page 1 of 2 Usfha.= 56A i,bl t 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR AND 000/1000 Of the overdue amount of each payment. percent ( 4 .000 q ) (B) Default If Borrower defaults by failing to Pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate in full in the case of payment defaults. This Note does not authorize acceleration when not As used in this Note, "Secrete Payment ry"means the Secretary of Housing and Urban Develo permitted HUD regulations. pment or his or her r designee, (C) Payment of Costa and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower 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 Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. S. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. 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. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. ji ? a7 SEP S SPEECE ( al) -Borrower (Seal) -Borrower BY SIGNING BELOW, Borrower accepts and a ees to the terms and covenants contained in pages 1 and 2 of this Note (Seal) -Borrower - (Seal) -Borrower MULTMATFrFRA FDtED BATE NOTE (6196) D==m syn. IM. tq 64¢1762 Page 2 of 2 (Sea l) -Borrower - (Seal) Borrower U.0 -M ALLONGE Loan Number: 124007332 Loan Date: NOVEMBER 21, 2007 Borrower(s): JOSEPH S SPEECE Property Address: 306 SAINT MARKS ROAD, MECHANICSBURG, PENNSYLVANIA 17050 Principal Balance: $131, 9 2 9. 0 0 PAY TO THE ORDER OF PENNSYLVANIA HOUSING FINANCE AGENCY Without Recourse CompanyNazne: PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK BY: (Name) DENISE DIGIOVAWI MORTGAGE DNDSBpBIyM M&NAGER (Title) MULTISTATE NOTE ALLONGE 03/08/07 ql 800.619-1361 WWW.dOCgppC.C0m A.lu ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the west side of St. Marks Road, which point is ninety-three and forty-three hundredths (93.43) feet north of the intersection of Del-Brook Road and St. Marks Road; thence South 82 degrees 13 minutes West along Lot No. 38, one hundred (100) feet to a point at Lot No. 39; thence along same North 66 degrees 5 minutes 30 seconds West, one hundred twenty-three and seventy-two hundredths (123.72) feet to a point at Lot No. 36; thence along same North 82 degrees 13 minutes east, two hundred five and twenty-seven hundredths (205.27) feet to a point on the west side of St. Marks Road; thence along the west side of St. Marks Road South 17 degrees 47 minutes East sixty-five (65) feet to the point, the place of BEGINNING. BEING Lot No. 37 on Plan of St. Mark's Place, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 8. Parcel #10-22-0527-052 !J Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05-505 7 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED October 17, 2008 RE: Account No 1682079 JOSEPH S SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050-3055 RE: 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050-3055 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 306 SAINT MARKS ROAD, MECHANICSBURG, PA 17050-3055 IS IN SERIOUS DEFAULT because you have not made the monthly through October 1, 2008 for a total of $2,907.00. Late charges and NSF charges$that haveoaccrued olthis date in the amounts of $62.44 and $0.00 respectively, are also due. The total listed below includes all fees (including inspections and securing that needed to be completed) less any funds we are holding in su The total amount now required to cure this default, or in other words, get caught up in our ay speno f the date of this letter is $2,969.44. P your payments, ments, as of You may cure this default within thirty (30) DAYS of the date of this letter, by paying to us the total amount of $2,969.44, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our ri ht r? accelerate the mortgage navmentc. This means that whatever is owing on the original be considered due immediately and you may lose the chance to pay off the original amount borrowed will mortgage in monthl installments. If full payment of the amount of default'is not made within THIRTY (30 ) DAYS, we al soy intend to instruct our attorneys to start a lawsuit to foreclose vour In R ?ronertv If the mortgage is foreclosed, your mortgage property will be old by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, u to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's ?? ? ? ('6 ( 1 Pennsylvania Housing Finance Agency Accounting / Loan Servicina nivican.. 211 North Front Street, P. 0. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 include fees, even our if they reasonaareble over costs. $50.00. Any attorney's fee will be added to whatever you owe us, which may also pay attorney fees If you cure the default within the thirty day period, you will not be required to . We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirt begun, y y day Period and foreclosure proceedings have -,._-'?You still have the right to cure the def ault and nre irt rho _. any late or other char¢es then due C----l -- _ - - that such a Sheriffs sale could be held would be approximatteely fie months from the date of this Notice. Ate notice of the date of the Sheriff 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 will be by calling us at the following number: 1-800-822-7375. This payment must be made payable in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property, after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the _ RIG TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF Tproperty. MORTGAGE DEBT, R TOE BORROW MONEY FROM ANOTHER LENDING INSTITUTION MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PRORTY SUBJECT To TDHE T YOU MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED. CONTACT US DETERMINE UUNDEER W AT S CIRCUMSTANCES THIS RIGHT MIGHT EXIST., DEFAULT CURED BY ANY THIRD PARTY ACTIN ,U U Q ?l ? YOUR BEHALF. TO HAVE THIS If You cure the defaul the mort a e will be rest ored'to the same 3osition as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Pennsylvania Housing Finance Agency Accounting / Loan Servicing Divicinn 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 Sincerely, TLG/jrd Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 Pennsylvania Housing Finance Agency NO- T- ICE October 17, 2008 JOSEPH S SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050-3055 RE: Account# 1682079 TO: JOSEPH S SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050-3055 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 The Federal Housing and Development Act homeowners who are delinquent of 1987 (as amended) directs creditors to notify in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary and Urban Development ("HUD" and ?' of the Department of Housing experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. If these agencies are not near you, you can [call ,HUD's toll free number (800) 569-4287 for financially distressed mortgagors for information concerning HUD-approved housing counseling a encies. g Enclosure Housing Counseling List Pennsylvania Housing Finance Agency Accounting / Loan Servicing 211 North Front Street, P. 0. Box 15057 Harrisburg, PA 17105-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 * Please be sure the agency of your choice services your county. HOUSING COUNCIL OF YORK 116 N George St TABOR COMMUNI Ty SERVICES York, PA 17401-1106 439 E King St. Phone: 717-854-1541 Lancaster, PA 17602-3004 Phone: 717-397-5182 ao ao o 110 .4 to oo o o ;; co Go b O tD N t A d'~ n o 0 ems, o 0 ?d n O A J .r O n \ ° ?O C N "'? ?r b 0 0 0 L 13 O w, 0 M O° O Q C N o O o C M M n zz Z A 7 00 41 e N n .1 ° ri ,-1 A 04 L 4+ is A 7 m o N N v X o x 41 1 .. ..a y O ¦ ., ,i ; ? rl N re H dz to nLL .? ?+ A LL N N O C H O C C C F N . I N L LL W J J in in N M 91 N C C O in N O . oz O O M M L j ° ? ?"' d in in > W < N •? O P2 ° n a U. CL AI - 41 <19 J .r .r 9 7 O d -C t7V N Z d A IL C T v N W N A .. .. ° b Nd ° w W aJ • N iL W I+ .r Z > .Cr * * N H L L C' IL . o C N W c O A C N ,., s cc tY 040 N y 4J" LL o 19 Y came u .y a C* .1 1=9 -C w .r ., o m m o y W O? x z 916 Vz V 41 LLA > A b z M '' w a • N 0 h N O <N < L C A N p b V b V N O J N CLL Oz .• ° W0 W e N YI e < 'y M •• N .. Z M Z A V C P- in " N AO • V c w I- L .40 x A•• r-14-0L•-t. ya L N Q AAL.AAOv .,v 1 Q J(? as Wwgo Wd< _ " < J LL L 7160 3901 9845 9529 6165 TO: JOSEPH S SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050-3055 SENDER: REFERENCE: 1682079 RETURN Post RECEIPT CertMed Fee SERVICE Relum Receipt Fee Restridw Delve Total Pbsyps A Fees US Postal Service ?OSTWRK OR DATE Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail CARTAGINA 4 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. Anthony J. Jul Director of Accounting and Loan Servicing PENNSYLVANIA HOUSING FINANCE AGENCY Q SERVICING AGENT FOR U.S. BANK, NATIONAL Date: ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY._ IJ T? i Sheriffs Office of Cumberland County R Thomas Kline ? 0'? of Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy `"AFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Occupant at 306 Saint Marks Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050m but was unable to locate him/her in his bailiwick he therefore returns the within Complaint as not served as to the defendant, Occupant. Service was attempted nine times. 04/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Joseph S. Speece, 306 Saint Marks Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 but was unable to serve him in his bailiwick he therefore return, the within Complaint as not served as to the defendant, Joseph S. Speece. Service was attepted nine time SHERIFF COST: $71.00 April 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Docket No. 2009-1597 U.S. Bank National Assoc, v Joseph S. Speece OF E R'''O H a NARY 2009 APR -7 PM 3* 49 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY CIVIL ACTION - LAW Plaintiff NO. 09-1597 CIVIL TERM VS. IN MORTGAGE FORECLOSURE JOSEPH S. SPEECE Defendant MOTION FOR SERVICE OF PROCESS IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 410 & 430 OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, U.S. Bank National Association Trustee for The Pennsylvania Housing Finance Agency, through it's counsel, Leon P. Haller, Esquire, hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by the Defendant located at 306 Saint Marks Road, Mechanicsburg, Pennsylvania 17050. 2. The Sheriff attempted service upon Defendant, Joseph S. Speece, at the property address nine times and was unable to serve Defendant. An investigation was commenced and no alternative addresses were provided. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, Joseph S. Speece, as set forth on the attached Affidavit. 4. Notwithstanding the investigation as set forth in the within Affidavit, Plaintiff has been unable to serve said Defendant, Joseph S. Speece. 5. Plaintiff requests an order directing service by posting a copy of the original Complaint on the most public part of the property and sending copies of the Complaint by ordinary and registered/certified mail to the Defendant's last known address; Plaintiff avers that the method of service sought here is the most likely method to achieve the notice requirements of due process, while at the same time permitting the Plaintiff to proceed with it's in rem action. WHEREFORE, Plaintiff requests that your Honorable Court direct service as above requested. PURCELL, KRUG & HALLER By n P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: May 6, 2009 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. JOSEPH S. SPEECE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-1597 CIVIL TERM IN MORTGAGE FORECLOSURE CERTIFICATION I hereby certify that a copy of this document has been served on all parties or their counsel of record. PURCELL, KRUG & HALLER By: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: May 6, 2009 PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. JOSEPH S. SPEECE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-1597 CIVIL TERM IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss: Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Process Pursuant to Rule 430, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant, Joseph S. Speece, in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has utilized Lexis Smart Links Person Summary Report, a national search database, with respect to the location of Defendant. None were provided. X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listings. X That he has conducted a search of the Pennsylvania Department of Transportation's records with .respect to the location of the Defendant, copies of the results are attached hereto and made a part hereof. No additional address has been bound. Leon P. Haller further deposes and says that after attempting to locate the Defendant, Joseph S. Speece, by conducting a reasonable search as indicated above, he has been unable to confirm the Defendant's whereabouts and location. Defendant is believed, however, to continue to reside at 306 Saint Marks Road, Mechanicsburg, Pennsylvania 17050. PURCELL G, ALLER BY: ?. Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 (717)234-4178 Attorney for Plaintiff Attorney I D# 15700 Sworn to and sub 4day before me on thi a of May, 2009. Notary Public COMMONWE&TH OF PENNSYLVANIA My commission expires: NotarW Seal Bonita E. Pnmack Notary Public (SEAL) MycoamiWw sept,26 2W Member. Penm*si is M.odadw of Wain Sheriffs Office of Cumberland County R Thomas Kline ?g utr of clun a".', h? Edward L Schorpp Sheriff Solicitor Ronny R Anderson F Jody S Smith Chief Deputy OF ICE OF rkE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Occupant at 306 Saint Marks Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050m but was unable to locate him/her in his bailiwick he therefore returns the within Complaint as not served as to the defendant, Occupant. Service was attempted nine times. 04/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Joseph S. Speece, 306 Saint Marks Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 but was unable to serve him in his bailiwick he therefore return: the within Complaint as not served as to the defendant, Joseph S. Speece. Service was attepted nine time SHERIFF COST: $71.00 SO ANSWERS, April 06, 2009 R THOMAS KLINE, SHERIFF Docket No. 2009-1597 U.S. Bank National Assoc. v Joseph S. Speece March 6, 2009 PURCELL KRUG & HALLER L.? 1719 N. FRONT STREET HARRISBURG, PA 17102-2392 Postmaster MECHANICSBURG, PA 17050 City, State, Zip Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address of a boxholder for the following JOSEPH S. SPEECE Address: 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.5(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manuel 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party except a corporation acting pro se must cite statute): NOT APPLICABLE 3. The names of all known parties to the litigation: JOSEPH S. SPEECE, Defendant; U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff 4. The court in which the case has been or will be heard. CUMBERLAND COUNTY COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: None as of above date 6. The capacity in which this individual is to be served (e.g. defendant or witness) DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,0000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I Certify that the above information is true and that the address information is needed and will be used solely for Service of legal process in onnection with actual or prospective litigation. Address: Signature 1719 N. Front Street Harrisburg, PA 17102 Leon P. Haller, Esquire Printed Name POST OFFICE USE ONLY A?- No Change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK Not known at address given. Moved. Left no forwarding address. No such address NAME and STREET ADDRESS WhitePages.com - Online Directory Assistance WhitePa es.corW search. find. connect. 1 Result matching "Joseph Speece, Mechanicsburg, PA". .......... ._... Joseph Speece 306 Saint Marks Rd Mechanicsburg, PA 17050-3055 phone number unavailable s Cl"Rl ew Or ?e71 Brian Rd Saint Johns ChL r?inie Rd Cematet ? & W IF L [1 K a ?t Fza 5 yds Close Listing date Dec. 2007 sPOlisoR l i e ages - including exciusive Re earch Background info on 11twu Name 1-cation Age Free mere p,shrp requiredP2 Jose S.peece• Jos .ph..Soeece W?st 59 Jos f Pittsburgh, PA 32 CIOSe Already a member? Sian in Jos, .pb?Speece Levittown, PA 75 LI C?on'i remind me again nd Info ,ackground Report Sao. .nsorad._by.._US_S.garch. Page 1 of 2 listing=mixed&form mode=ont b&nost back=l&... 4/17/2009 PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING BASIC DRIVER INFORMATION APR 27 2009 PAGE 1 DRIVER: JOSEPH SCOTT SPEECE DRIVER LICENSE NO : 26606275 306 ST MARKS RD DATE OF BIRTH : JUN 15 1983 MECHANICSBURG, PA 17050 SEX : MALE RECORD TYPE : REG LIC/ID DRIVER LICENSE (DL) COMMERCIAL DRIVER LICENSE (CDL) LICENSE CLASS : C LICENSE ISSUE DATE: AUG 15 2006 LICENSE EXPIRES : JUN 16 2008 ORIG ISSUE DATE : OCT 12 2000 MED RESTRICTIONS : NONE LEARNER PERMITS LICENSE STATUS CDL LICENSE CLASS . CDL LICENSE ISSUED : CDL LICENSE EXPIRES: CDL ENDORSEMENTS : NONE CDL RESTRICTIONS : NONE CDL LEARNER PERMITS: CDL LICENSE STATUS : SB ENDORSEMENT PROBATIONARY LICENSE (PL) PL LICENSE CLASS PL LICENSE ORIG ISS: PL LICENSE ISSUED . PL LICENSE EXPIRES : PL LICENSE STATUS . OCCUPATIONAL LIMITED LICENSE (OLL) OLL LICENSE CLASS . OLL LICENSE ISSUED : OLL LICENSE EXPIRES: OLL LICENSE STATUS : *** END OF RECORD *** Page 1 1 OF 1 RECORD(S) FOR INFORMATIONAL PURPOSES ONLY Copyright 2008 LexisNexis a division of Reed Elsevier Inc. All Rights Reserved. Full Name Address County SPEECE, JOSEPH S 306 SAINT MARKS RD CUMBERLAND MECHANICSBURG, PA 17050-3055 ADDITIONAL PERSONAL INFORMATION SSN DOB Gender 176-70-XXXX 6/1984 zr :: (Age:24) Subject Summary Name Variations 1: BLACKBURN, JOEY 2: SPEECE, JOSEPH 3: SPEECE, JOSEPH S SSNs Summary No. SSN State Iss. Date Iss. Warnings Most frequent SSN attributed to subject: 1: 176-70-XXXX Pennsylvania 1989-1990 DOBs Reported DOBs: 6/1984 Address Summary - 3 records found for subject. No. Address 1: 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 CUMBERLAND COUNTY 410 SPEECE LN DAUPHIN, PA 17018-9521 DAUPHIN COUNTY 3: 205 N 45TH ST SWATARA, PA 17111-2743 DAUPHIN COUNTY Address Details 1: 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 Address 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 CUMBERLAND COUNTY Census Data for Geographical Region Median Head of Household Age: 48 Median Income: $33,149 Median Home Value: $103,900 Median Education: 13 years Household Members None Listed Phone None Listed Dates Phone 2/2009 Page 2 Other Associates None Listed 2:410 SPEECE LN DAUPHIN, PA 17018-9521 Address 410 SPEECE LN DAUPHIN, PA 17018-9521 DAUPHIN COUNTY Census Data for Geographical Region Median Head of Household Age: 38 Median Income: $54,000 Median Home Value: $114,100 Median Education: 13 years Household Members BLACKBRUN, DEBRA A BLACKBURN, CATRINA MARIE SHERRY, L BLACKBURN SPEECE, STEPHEN S SPEECE, TAMARYM JO Other Associates None Listed Dates 11/2007 Phone (717) 921-8414 3: 205 N 45TH ST SWATARA, PA 17111-2743 Address 205 N 45TH ST SWATARA, PA 17111-2743 DAUPHIN COUNTY Census Data for Geographical Region Median Head of Household Age: 41 Median Income: $40,777 Median Home Value: $96,800 Median Education: 12 years Household Members None Listed Other Associates None Listed Real Property 1: Assessment Record for CUMBERLAND County, PA Dates 4/2006 Phone (717) 564- 1908(717) 558- 8357 Owner Information Name: SPEECE JOSEPH Property Information Address: 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 County/FIPS: CUMBERLAND Legal Information Assessor's Parcel Number: 22-0527-0052-0000000-10 Recording Date: 11/29/2007 Book/Page: 2007/2007 Sale Information Sale Date: 11/21/2007 Sale Price: $134000 Mortgage Information Loan Type: FEDERAL HOUSING AUTHORITY Loan Amount: $131929 Lender Name: LEESPORT BK Assessment Information Assessed Value: $102340 Market Land Value: $40000 Page 3 Market Improvement Value: $62340 Total Market Value: $102340 2: Deed Record for CUMBERLAND County Buyer Information Name: SPEECE, JOSEPH Seller Information Name: KISLAN BLAISE B Property Information Address: 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 County/FIPS: CUMBERLAND Lender Information Name: LEESPORT BK Legal Information Assessor's Parcel Number: 22-0527-0052-0000000-10 Contract Date: 11/21/2007 Recording Date: 11/29/2007 Document Type: GRANT DEED Book/Page: 2007/2007 Sale Information Sale Price: $134000 Potential Relatives No. Full Name Address/Phone SPEECE, TAMARYM JO 1640 MOUNTAIN RD -AKA SPEECE, TAMARYN J DAUPHIN, PA 17018-9707 -AKA SPEECE, TAMARYN JO (717) 921-2826 SSN:175-70-XXXX (717) 921-3291 a SSN linked to multiple people 410 SPEECE LN DAUPHIN, PA 17018-9521 DOB:9/1981 (717) 921-8414 (Age: 27) 2. SPEECE, STEPHEN S 410 SPEECE LN -AKA SPEECE, STEPHENS DAUPHIN, PA 17018-9521 SSN:179-44-XXXX (717) 921-8414 13013:2/1954 250 SPEECE LN (Age: 55) DAUPHIN, PA 17018-9710 (717) 921-2898 311 SPEECE LN DAUPHIN, PA 17018-9008 (717) 921-2898 1503 HIGH POINTE DR APT G HARRISBURG, PA 17110-9255 2a. SPEECE, LUCILLE E'T Deceased 250 SPEECE LN SSN:183-12-XXXX DAUPHIN, PA 17018-9710 (717) 921-2898 Deceased DOB:7/1921 (Age: 87) 2b. SPEECE, ROBERT WALTER 3007 GREEN ST APT 3 SSN:165-38-XXXX HARRISBURG, PA 17110-1235 Page 4 No. Full Name Address/Phone DOBA/1949 2002 FORSTER ST (Age: 59) HARRISBURG, PA 17103-1619 3007 DEER ST HARRISBURG, PA 17110 250 SPEECE LN DAUPHIN, PA 17018-9710 (717) 921-2898 311 SPEECE LN DAUPHIN, PA 17018-9008 (717) 921-2898 SHERRY, L BLACKBURN 3 5325 EARL DR . -AKA BLACKBURN, SHERRY L HARRISBURG, PA 17112-2444 SSN:199-60-XXXX (717) 545-4039 DOB 5/1974 1063 POND RIDGE DR (Age. 34) HARRISBURG, PA 17111-4688 (717) 651-1043 1503 HIGH POINTE DR APT G HARRISBURG, PA 17110-9255 NONE HARRISBURG, PA 17110 410 SPEECE LN DAUPHIN, PA 17018-9521 (717) 921-8414 4. BLACKBRUN, DEBRA A 410 SPEECE LN -AKA BLACKBURN, DEBRA A DAUPHIN, PA 17018-9521 -AKA SPEECE, DEBRA (717) 921-8414 SSN:391-58-XXXX -'I DOB:3/1955 (Age: 53) 5. BLACKBURN, CATRINA MARIE 606 FILLMORE ST -AKA EVANS, CATRINA MARIE HARRISBURG, PA 17104-2128 SSN:199-60-XXXX (717) 558-0623 l DOB:7/1975 742 MEADOWBROOK LN (Age: 33) CHAMBERSBURG, PA 17201-3827 304 CENTER ST FL 2ND MILLERSBURG, PA 17061-1614 RM 236 KUTZTOW N, PA 19530 410 SPEECE LN DAUPHIN, PA 17018-9521 (717) 921-8414 5a. EVANS, IRA J 3188 RIDGEWAY RD -AKA EVANS, J HARRISBURG, PA 17109-1019 Page 5 No. Full Name Address/Phone -AKA IRA, J EVANS (717) 545-5096 SSN:184-36-XXXX `•:' 606 FILLMORE ST HARRISBURG, PA 17104-2128 (717) 558-0623 3254 WAKEFIELD RD APT HARRISBURG, PA 17109-6134 (717) 695-4580 (717) 652-3646 5b. EVANS, JUSTIN R 606 FILLMORE ST SSN:175-64-XXXX HARRISBURG, PA 17104-2128 <•a (717) 558-0623 DOB:2/1975 (Age: 34) 3188 RIDGEWAY RD HARRISBURG, PA 17109-1019 (717) 545-5096 5c. KESSLER, NICHOLE E 44 THORNWOOD RD -AKA EVANS, NICOLE ELAINE HARRISBURG, PA 17112-2955 •AKA KESSLER, NICOLE (717) 671-5882 ELAINE -AKA SCHAERTEL, NICOLE E 606 FILLMORE ST SSN:163-52-XXXX HARRISBURG, PA 17104-2128 (717) 558-0623 DOB: 12/1971 (Age: 37) 3188 RIDGEWAY RD HARRISBURG, PA 17109-1019 (717) 545-5096 Neighbors 306 SAINT MARKS RD MECHANICSBURG, PA 17050-3055 Name Address Phone BAIR, JONATHAN A 302 SAINT MARKS RD HERTZ, NANCY A MECHANICSBURG, PA 17050-3055 BUEHLER, RALPH C 303 SAINT MARKS RD (717) 731-0359 NICHOLSON, COURTNEYA MECHANICSBURG, PA 17050-3056 NICHOLSON, DEBRA K NICHOLSON, JOSHUA AARON NICHOLSON, MARK C AINSWORTH, HELEN KAY 304 SAINT MARKS RD (717) 737-8593 MECHANICSBURG, PA 17050-3055 Sources All Sources 9 Source Document(s) Deed Transfers 2 Source Document(s) Historical Person Locator 3 Source Document(s) Person Locator 1 1 Source Document(s) Phone 1 Source Document(s) Tax Assessor Records 2 Source Document(s) Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department of State. Your DPPA Permissible Use is: Litigation Your GLBA Permissible Use is: Legal Compliance ?s? Tyr ? f `:?'MnnV 2 Iuu 1 AY 12 A. 9. 14 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. JOSEPH S. SPEECE Defendant CIVIL ACTION - LAW NO. 09-1597 CIVIL TERM IN MORTGAGE FORECLOSURE AMENDMENT TO MOTION FOR SERVICE OF PROCESS IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 410 & 430 OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, U.S. Bank National Association Trustee for The Pennsylvania Housing Finance Agency, through it's counsel, Leon P. Haller, Esquire, hereby respectfully submits: 1. A Judge has not ruled upon any other issue in the above matter. 2. Plaintiff has been unable to serve the Defendant, has been unable to contact Defendant and therefore unable to obtain concurrence. PURCELL, KrR, UG & HALLER By: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: May 15, 2009 r OI r ?2 C1, 1- f I l s t 3 r U.S. BANK NATIONAL : IN THE COURT OF COMMON PLEAS OF ASSOCIATION TRUSTEE FOR : CUMBERLAND COUNTY, PENNSYLVANIA THE PENNSYLVANIA FINANCE AGENCY Plaintiff V. JOSEPH S. SPEECE Defendant CIVIL ACTION - LAW NO. 09-1597 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of May, 2009, upon consideration of Plaintiffs Motion for Service of Process in Real Property Action in Accordance with Rules 410 & 430 of Pennsylvania Rules of Civil Procedure, and the affidavit accompanying the motion, the motion is granted and it is ordered and directed as follows: 1. Service of the Complaint on Defendant may be made by (1) posting a copy of the Complaint on the most public part of the property located at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, (2) sending a copy of the Complaint by certified and ordinary mail to Defendant at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, service to be deemed to be complete upon mailing, and (3) publication once in the Cumberland Law Journal and once in a newspaper of general circulation in Cumberland County. 2. Service of additional papers and notices upon Defendant shall be (1) by regular mail addressed to him at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, service to be deemed complete upon mailing, and (2) posting of the property at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050. BY THE COURT, -? I ?' , J esley Ol ., J. l ._ C-' ;=Zl C-1 Leon P. Haller, Esq. 1719 North Front Street Harrisburg, PA 17102-2392 Attorney for Plaintiff A (2c> ? Y ?(a t1? ? s?zzfo? U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. JOSEPH S. SPEECE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 09-1597 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: June 2, 2009 PURCELL, KRUG, & HALLER BY Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney 1134 15700 THE 2W JUN AM 10- 0 rr+; rwtirr?.,o- ti Sheriffs Office of Cumberland County R Thomas Kline @ ?cr ct ctc+tibe Edward L SoSchorpp licitor Sheriff r. Ronny R Anderson Jody S Smith Chief Deputy OFF'CE "`'-4RiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/05/2009 04:35 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on June 5, 2009 at 1635 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Joseph S. Speece, pursuant to order of court by posting the premises located at 306 Saint Marks Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 with a true and correct copy according to law. SHERIFF COST: $43.00 SO ANSWERS, A- ? ? 4ge--e-4 June 08, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff 2009-1597 US Bank National Assoc. V Joseph S. Speece C3 z9 C C= C U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-1597 Vs. JOSEPH S.SPEECE Defendant(s) CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PROOF OF PUBLICATION PURCELL, KRUG & HALLER _. 7 Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney ID # 15700 Attorney for Plaintiff PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13t',, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): Tune 11, 2009 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. qn P/? Sworn to and subscribed before /Imll e this i J UL 04 R Notary Public My commission expires: COMMONWEALTH OF NOTARIAL S&u BAMBI ANN HECKENDORN, Camp Hill Boro., Cumberland u,,. NAv Commission Expires January 27, YU .^? NOTICE QE ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW U iS?BAN? NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY i? JOSEPH S. SPEECE DEFENDANT MORTGAGE FORECLOSURE NO. 09-1597 CIVIL TERM TO: JOSEPH S. SPEECE: V" hereby notiffed•geat on March 13, 2009, Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA MOUSING FINANCE ARiENCY, t Forecweure Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, dockM6lOeMO.09-1587 CIVIL TERM wherein Plaintiff seeks to foreclose it's mohgage securing your property located at 306 SAINT MARKS ROAD, MECHANICSBURG, PA 17050, whereupon your property would be sold by the Sheriff of Cumberland County. You are hereby riolified to plead to the above referenced Complaint on or before 20 DAYS form the date of this publication or a Judgement will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the Court. You are warned that If you fall to do so, the case may proceed without you and a 'Judgement may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TELEPHONE THE OFFICE BELOW TO FIND OUT THERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Name: Lawyer Referral Service Address: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone number. (717) 249-3166 Leon P. Haller, Esquire Attorney ID #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff Vs. JOSEPH S. SPEECE Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-1597 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, Leon P. Haller, hereby certify that a true and correct copy of the Complaint in the above captioned action was forwarded to the following individuals by regular U. S. Mail, first class service, postage prepaid, and by certified mail, return receipt requested, postage prepaid, on JUNE 5, 2009, addressed as follows: JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 Attached hereto is the original Certificate of Mailing postmarked June 5, 2009 along with the original Receipts for Certified Mail also postmarked June 5, 2009. Leon P. Haller SWORN to and subscribed this day of , 20. Notary Public My commission expires: (SEAL) COMMONG -ANSYLVANIA Novari,' 1', I PT, L PHFA v. Speece 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: JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 7160 3901 9845 7318 3807 TO: JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 SENDER: TMB REFERENCE: P01455/34909 COURT ORDER RETURN F081419e i &i`- RECEIPT Certified Fee 280 SERVICE Return Receipt Fee 2.30 Restricted Delivery 4.5 Toted Postage & Fees US Postal Service POSTMARK OR DATE Receipt for Certified Mail 'GS No insurance Coverage Provided Do Nut Use for international Mail ?i, _ IL.. .. _ ?t r .. ?... U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JOSEPH S. SPEECE, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-1597 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 1 a V 1,100q , 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: JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 Leesport Bank P. O. Box 741 Leesport, PA 19533 Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 Y PURCELL, KR G & 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. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 Leesport Bank P. O. Box 741 Leesport, PA 19533 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 HERSHEY (717)533-3836 JOSEPH NISSLEY (1910-1982) JOHN W.PURCELL VALERIE A. GUNNOF COUNSEL 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 1 be divested by the sale and that you have an opportunity to protect your interest, if any, by bei ed of said Sheriffs Sale. B. Leon P. Ha leer PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JOSEPH S. SPEECE, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-1597 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, December 09, 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: 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-1597 JUDGMENT AMOUNT $144,275.94 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JOSEPH S. SPEECE 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 piece or parcel of land, situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the west side of St. Marks Road, which point is ninety-three and forty-three hundredths (93.43) feet north of the intersection of Del-Brook Road and St. Marks Road; thence South 82 degrees 13 minutes 00 seconds West along Lot No. 38, one hundred (100) feet to a point at Lot No. 39; thence along same North 66 degrees 05 minutes 30 seconds West, one hundred twenty-three and seventy-two hundredths (123.72) feet to a point at Lot No. 36; thence along same North 82 degrees 13 minutes 00 seconds East, two hundred five and twenty-seven hundredths (205.27) feet to a point on the West side of St. Marks Road; thence along the West side of St. Marks Road South 17 degrees 47 minutes 00 seconds East sixty-five (65) feet to the point, the place of BEGINNING. BEING Lot No. 37 on Plan of St. Mark's Place, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 8. HAVING thereon erected a single one-story brick dwelling known as 306 Saint Marks Road, Mechanicsburg, PA 17050. PARCEL NO.: 10-22-0527-052. UNDER AND SUBJECT to all restrictions, reservations, easements, rights of way and ordinances of record. BEING THE SAME PREMISES WHICH Blaise B. Kislan by deed dated 11/21/07 and recorded 11/29/07 in Cumberland County Record Book 200744592. TO BE SOLD AS THE PROPERTY OF JOSEPH S. SPEECE ON JUDGMENT NO. 09-1597 U. S. BANK NATIONAL : IN THE COURT OF COMMON PLEAS OF ASSOCIATION TRUSTEE FOR : CUMBERLAND COUNTY, PENNSYLVANIA THE PENNSYLVANIA FINANCE AGENCY Plaintiff V. JOSEPH S. SPEECE Defendant CIVIL ACTION - LAW NO. 09-1597 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of May, 2009, upon consideration of Plaintiff's Motion for Service of Process in Real Property Action in Accordance with Rules 410 & 430 of Pennsylvania Rules of Civil Procedure, and the affidavit accompanying the motion, the motion is granted and it is ordered and directed as follows: 1. Service of the Complaint on Defendant may be made by (1) posting a copy of the Complaint on the most public part of the property located at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, (2) sending a copy of the Complaint by certified and ordinary mail to Defendant at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, service to be deemed to be complete upon mailing, and (3) publication once in the Cumberland Law Journal and once in a newspaper of general circulation in Cumberland County. 2. Service of additional papers and notices upon Defendant shall be (1) by regular mail addressed to him at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050, service to be deemed complete upon mailing, and (2) posting of the property at 306 Saint Marks Road, Mechanicsburg, Pennsylvania, 17050. TWA-%t.-? wlwnC I IM Oft MY W% A-SCrl? AM- BY THE COURT, n b, ':' J/ Wesley 0 7160 3901 9848 2032 8814 70: JOSEPH S.SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 SENDER: NOS 12/09/09 REFERENCE: PHFA/SPEECE RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage & Fees US Postal Service Receipt for Certified M il POST N a No Insurance Coverage Provided ? Do Not Use for Intsmational Mail V" PENNSYLVANIA HOUSING FINANCE AGENCY v. JOSEPH S. SPEECE Cumberland County Sale 12/9/2009 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: JOSEPH S. SPEECE 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 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: Pennsylvania Housing Finance Agency 211 N. Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 • 9;r- -A do N I 991P5's ~4' 3 * m? 7 PITNEY R(1WE5 02 1M $ 01.950 0004284324 AUG28 2009 MAILED FROM ZIP CODE 1 710 2 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U. S. POSTAL SERVICE CERTIFICATE OF MAILING In com fiance with Postal Service Form 3877) Postage: One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING In comallance with Postal Service Form 3877) Postage: One piece of ordinary mail addressed to: TENANT/OCCUPANT 306 SAINT MARKS ROAD MECHANICSBURG, PA 17050 Postmark: N co 40 N O ?_ • ft ?, s..i Pf'NEv 110vff5 02 1m $ 02.300 0004284324 AUG28 2009 MAILED FROM ZIP CODE 1 710 2 THE t y ?,T ,?r_,nrf??Y 20900 NOY 25 FIN I: 2 ?P ?r>. 1 1