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HomeMy WebLinkAbout09-8611Leon 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. ADAM J. WAGNER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Cat'-8?l( ?i??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 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, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE ADAM J. WAGNER, 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. ADAM J. WAGNER, Defendant ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. 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, ADAM J. WAGNER, is an adult individual whose last known address is 2459 MOSS TREE COURT ROCK HILL, SC 29730. 3. On or about, July 12, 2007, the said Defendant executed and delivered a Mortgage Note in the sum of $71,050.00 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 July 17, 2007 in Mortgage Book 1999, Page 4336 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 July 17, 2007 in Mortgage Book 1999, Page 4348. 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: 507 FACTORY STREET CARLISLE, PA 17013 and is more IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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 January 01, 2009 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $10.71 per clay From 12/01/2008 To 01/0 1 /2010 ( based on contract rate of 5.6000%) Accumulated Late Charges Late Charges $16.32 From 01/0 1 /2009 to 01 /01 /2010 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $69,785.31 $4,241.16 $195.84 $1,939.21 $3,489.27 $79,650.79 "Together with interest at the per diem rate noted above after January 01, 2010 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 to accelerate the loan balance was sent to the Defendant by letters dated March 20, 2009 as required by Pennsylvania Act No. 6 of 1974, as amended. Copies of the March 20, 2009 Act 6 Notices are 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 "IN REM" for the aforementioned total amount due together with interest at the rate of 5.6000% ($10.71 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described By: PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Jul. 31. 2009 9:38AM US BANK DOCUMENT CUSTODY No.4988 F. 27/47 yyNFL Loan Number: 124007137 NOTE -7a - 0 9 r- PHA CASE NO. / 5773 / 441-7930568 JULY 12, 2007 [Doul 507 FACTORY STREET, CARLISLE, PENNSYLVANIA 17013 [Property Address) I. PARTIES "Borrower" means each person signing at the end of this Note. and the person's successors and Assigns, "Lender" means PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, A PENNSYLVANIA BANKING CORPORATION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal Bum of SEVENTY-ONE THOUSAND FIFTY AND 00/100 Dollars (U.S,$ 71, 050.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Leader, at the rate of FIVE AND 600/1000 percent ( 5.600 %) per year until the full amount of 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 Now, 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 SEPTEMBER 1, 2007 . Any principal and interest remaining on the first day of AUGUST 1, 2037 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 Leader 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. S 4 0 7. 8 8 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 alonge providing for payment adjustments is executed by Borrower together with this Note, the coveaaata of the allouge shall be Incorporated into and shall amend and supplement the covenants of this Note as if the allouge were a part of this Note. (Check applicable box.) ? Growing Equity Allonge 13 Graduated Payment Allonge ? Other [specify) U,M- S. 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 fast day of any month. Leader 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, 14=13fAMPIIA Fum RATE NOTE (ti19A) Donate srm..,m, MOD 6M13 Q P age I of 2 11,b14 I(91i r_)(? c0ner IV. 31. 2009 9:38AM US BANK DOCUMENT CUSTODY No. 4988 F, 20147 6, BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Leader has not received the fail monthly payment required by the Security Instrument, u described in Paragraph 4(C) of this Note, by the and of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR AND 000/1000 percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in fall 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 payment in full in the ease of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, 'Secretary"mesas the Secretary of Housing and Urban Development or his or her designee. (C) Payment of costs and Expenses If Leader has requited immediate payment In full, as described above, Lender may require Borrower to pay costs and expenses including reasonable mad 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 Leader 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 lawrequires a different method, any notice that must be given to Borrower under this Note willbe 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 Leader under this Note will be given by fast class trail 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 trade 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 promisee made in this Note. Leader 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, BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in pages 1 and 2 of this Note. ADAM J W NE (Seal) (Seal) Borrower -Borrower - (Seal) -Borrower _ (Seal) -Borrower - (Seal) -Borrower _. (Seal) -Borrower ..",."- Wgftzo- cm cruets nwrtt r4ure (6196) Dm-0 *y , aA. rate 649-17n Page 2 of 2 Wim- Ju1.31. 2009 9:3BAM US BANK DOCUMENT CUSTODY ALLONGE Lose Number: 124007137 Loan Date: JULY 12 , 2007 Borrower(s): ADAM J WAGNER No.4986 P. 29/47 PropertyAddrus:507.FACTORY STREET, CARLISLE, PENNSYLVANIA 17013 Principal Bnlauce: $ 71, 0 5 D. 0 0 PAY TO THE ORDER OF P=BTLVANu BAIISIiitG FnTAUM ACRR" Without Recourse Company Name: PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK BY: (Name) D1D1I8RfDIGI0VAlIvItI (Title) 031013/07ATE NOTE ALLONOE www.db=4v1c."a A.I. ALL THAT CERTAIN tract of land with the Improvements thereon erected, situate In the 5" Ward of the Borough of CBdIsle, Cumberland County,, bounded and described as follows: BEGINNING at a point on the East side of Factory Street, which point is at line of land now ar formerly of Emma J. Cline; thence by the East side of Factory Street In a northerly direction, 25 feet to a p*t at of land now or formerly of Levl Stum; thence by said land In an easterly dlrectton, 69 teat to a point t encellby the some In e southerly direction, 03 feet to a point; thence by the same In an easterly direction, 49 feet to an Iron pin at One of land now or formerly of Albert C. Tritt thence by sold land In a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by sold land In a westerly dkecdon, 49 feet to a point at One of land now or formerly of Emma J. Cline; thence by sold land In a northerly direcdon 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. Pennsylvania Musing Finance Agency Accounting / Loan Servicing Division 211 North rrout Street, P. 0. Box 15057 Harrisburg, A4 17105-5057 (1-800-822-737,5) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 CERTIFIED MAIL - RETURN RF.,CEIPT REQUESTED March 20, 2009 RE: Account No 1597731 ADAM J WAGNER 2459 MOSS TREE CT ROCK I-III.I.., SC 17013-9009 RE: 507 FACTORY ST CARLISLE, PA 17011-1853 Dear Occupant(s): NOTICL OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 507 FACTORY ST, CARLISLE, PA 17013-1853 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $548.00 for January 1, 2009 through March 1, 2009 for a total of $1,644.00. Late charges and NSF charges that have accrued to this date in the amounts of $48.96 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 suspense. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $1,712.95. You may cure this default within thirty (30) DAYS of the date of this letter, by paying; to us the total amount of $1,712.96, 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 STREE-17P.0. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or T`I'Y (800) 346-3597 If you do not cure the default within TIIIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This mcuns that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your moil aaeed Aroperty If the mortgage is foreclosed, your mortgage property will be sold 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, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's U4 Pennsylvania Housing Finance Agency 1-01 Accounting / Loan Servicing Division 211 North Front Street, P.O. Box 15057 NarK burg PA 17145-5057 (1-800-822-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney fees. 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 thirty 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 sheriff s_ foreclosure sale. You may do so by paving the total amount of the unpaid monthly payments and any late or other charges then due as well as the reasonable attomcv's fees and const connected with the foreclosure sale and perform any other renuirements under the mortgage It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately five months from the date; of this Notice. A 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 Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL, THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER T.FNDING INSTITUTION TO PAY Ott THIS DEBT. YOU MAY HAVE THE , RIGHT TO SELL OR TRANSFER THE PROPERIY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE W140 WILL ASSUME THE MORTGAGE DEBT, PROVIDED TIIAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARR PAID PRIOR TO OR AT THE SALE AND THAT THE, OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINF UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default the mortgage will be restored to the same position 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 Ho`usinb Finance Agency Accounting / Loan Servicing Division Sincerely, "1'LG/j rd 21I North Front Street, P. 0. Box 15057 Harrisburg, PA 1 71 05-505 7 (1-8OM22-7375) Or (717-780-3870) FAX (717) 780-3804 TTY (717) 780-1869 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 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 NOTICE March 20, 2009 ADAM J WAGNER 2459 MOSS TREE CT ROCK HILL, SC 17013-9009 RE: Account# 1597731 TO: ADAM J WAGNER 507 FACTORY ST CARLISLE, PA 17013-1853 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 ("MUD") and 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 agencies. Enclosure Housing Counseling List Pennsylvania Housing Finance Agency Accounting / Loan Servicing Division 211 North Front Street, P. O. Box 15057 11ur?-iSburg, 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. CCCS OF WESTERN PA-HARRISRURG 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone: 888-599-2227 IIOUSING ALLIANCE OF YORK 34 S. Duke St. York, PA 17401-1106 Phone: 800-864-4909 TABOR COMMUNITY SERVICES 208 E Kin; St. Lancaster, PA 17608-1676 Phone: 717-397-5182 NACA 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 1'hone:888-297-5568 PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT ONE PENN CENTER; 1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone: 800-930-4663 TOTAL P.07 7160 3901 9848 1753 2798 To.. ADAM J WAGNE1Z 507 FACTORY ST CARLISLE, PA 17013-1853 SENDER: BASSETT REFERENCE: 1597731 US Postal Service Receipt for Certified Mail Nolnsurance Coverage Prowdeo Do Not use for Intormetonw kw d ^? to o a r+a o0 7 0. t` O Ell m m 9 w i i i 0 A' I i n v D t-A i C D a. W > n W 00 w a ro V ru . y v IRA 24j w m !r oa Y o- Q) A X ? { N _ Cn CD ? ? a a ?. Vj v 9 > to $ a e ra, Z; t o 3 ii err c x ? a m ??-' 7160 3901 9648 1753 2781 !" x t Q m D' TO: ADAM J WAGNER C7 tin ?, 3 0• mom-moM ` U. ` 2459 MOSS TREE CT m r -j - q f- ROCK HILL, SC 29730-9009 v C? Ln d nW,? mop. ?7 es?.??e? 9 N '. V E+ Q U.: R 6 0 Q w C SENDER: BASSETT 1597731 REFERENCE: z? L G+ • re IL > c 10 PS Form 38D0 Jana 2005 RETURN Postage 5 RECEIPT Certified Fee 2,70 $ b SERVICE Retum Recdpt Fee 2.20 q3 4m iG - b m Restricted Delivery 3 U. ° -'" 48 Total Postage & Fees o R DATE ?p ? US Posted Service POSTAAdK.O ? Q - x a Receipt for i IL a Certified Mail ?0 00 too SNs' ?, -Z1 H (.? 5? : No inswmnce C Nera9e Provid*d QL) Do Not'--4w imma6anal Mall b08?08?L T L ON 1 SFIGH dd ET :E T 60Oc'-6 T-Sf1d M * d 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. J ' an Director of Accounting and Loan Servicing PENNSYLVANIA HOUSING FINANCE AGENCY Date: --d _ SERVICING AGENT FOR I)--S ASSOCIATION AS TRUSTEE FOR BANK, NATIONAL HOUSING FINANCE AGENCY ey/ 4- /S3SGS ? za sobs SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline I FILE" Sheriff OF THE pF#Ol°HC?WMAW Ronny RAnderson "a??utr a? ?ittrt?rr?r?'dChief Deputy 206 JAN -6 AN 8:43 Jody S Smith Civil Process Sergeant FAc?A Edward L Schorpp Solicitor US Bank National Association vs. Case Number Adam J. Wagner 2009-8611 SHERIFF'S RETURN OF SERVICE 12/28/2009 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: Adam J. Wagner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Adam J. Wagner. The Carlisle Postmaster has advised the defendant has moved and left no forwarding address. SHERIFF COST: $33.00 December 28, 2009 SO RTOMAS KLINE, SHERIFF eL tCi Cou^tpSuitF Shen'f. Tflecsott. Inc. t U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. ADAM J. WAGNER Defendant RETURN OF SERVICE TO THE PROTHONOTARY: No. 09-8611 CIVIL Kindly file the Out of State Service Return on the above captioned matter DATE: February 1, 2010 PURCELL, KRUG, & HALLER BY Leon P. aller 1719 North ont Street Harrisb , Pa. 17102 Atto ey for Plaintiff At rney ID# 15700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE _ v For: Commonwealth of Pennsylvania Case Number: 09-8611 CIVIL AFFIDAVIT OF SERVICE County of Cumberland Plaintiff: US Bank National Association Trustee for The Pennsylvania Housing Finance Agency vs. Defendant: Adam J. Wagner PURCELL KRUG & HALLER Common Pleas Court Received by FALCON EXPRESS S-5$VICES, LLC to be served on Adam J. Wagner, 2459 Moss Tree Court, Rock Hill, SC 29730. I, LA-9 011!j d'A Si( O , being duly sworn, depose and say that on the day of . M _,2010 at j :gy m., executed service by delivering a true copy of the NOTICE, COMPLAINT IN A MORTGAGE FORECLOSURE, VERIFICATION and EXHIBITS in accordance with state statutes in the manner marked below: ?<NDIVIDUAL SERVICE: Served the within-named person. () SUBSTITUTE SERVICE: By serving as ( ) POSTED SERVICE: After attempting service on -/, at and on _/- at to a conspicuous place on the property described herein. ( ) NON SERVICE: For the reason detailed in the Comments below. Military Status: ( ) Yes or (9-1 No If yes, what branch? Marital Status: (-rmarried or ( ) Single Name of Spouse COMMENTS: I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. Subscr?4&d and Sworn to before me on the ??3 day of JQ , ZOM by the affiant who is personally wn to rne. P S ERVER # Appointed in accordance with State Statutes / FALCON EXPRESS SERVICES, LLC NOTARY BLIC P.O. Box 874 Charleston, SC 29402-0874 (843) 577-9696 Our Job Serial Number: 2010000086 Copyright* 1992-2008 Database Services, Inc. - Process Server's Toolbox V6.3e U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF' ADAM J. WAGNER, VS. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL MORTGAGE FORECLOSURE PRAECIPE C7 C R 0 i Xu cn r r ti9 TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) ADAM J. WAGNER 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 $69,785.31 Interest $4,241.16 Per diem of $10.71 From 12/01/2008 To 01/01/2010 Late Charges $195.84 ($16.32 per month to 01/01/2010) Escrow Deficit $1,939.21 5% Attorney's Commission $3,489.27 TOTAL $79,650.79 **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 B Leon P. Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 clth:? IS-5-0 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on _ against you in the above-captioned matter: the following judgment has been entered $79,650.79 and for the sale and foreclosure of your property located at: 507 FACTORY STREET CARLISLE, PA 17013 Dated: March 5, 2010 _a?)_ PRO ONOTARY Attorney for Plaintiff. Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236 ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 r d AM U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. ADAM J. WAGNER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL DEFENDANT(S) IN MORTGAGE FORECLOSURE FZ :7P 1t' N n 0 i ut w '- -a Mm i 5-1 CERTIFICATE OF SERVICE = - PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on February 17, 2010 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. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ADAM J. WAGNER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8611 CIVIL CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: February 17, 2010 TO: ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 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 Bx `/ LEON R HALLER, Attorney 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. ADAM J. WAGNER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL IN MORTGAGE FORECLOSURE 0 NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Q 7l Z =? rz73 r ?o ILO r- ij -17 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 i before me this J? day of 20 -/ 0 i t ti t C?y6t1f LEON P. UAfLER, ESQUIRE otar P Ile x. ?rp??. ? i 1, ?iolz?rY Publ'c LY", 104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW AT NO. 09-8611 CIVIL U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ADAM J. WAGNER, DEFENDANT(S) TO THE PROTHONOTARY/CLERK OF SAID COURT: Total Judgment Amount $79,650.79 Interest $1,606.50 Per diem of $10.71 to sale date 6/2/2010 Late Charges $81.60 $16.32 per month to sale date 6/2/2010 Escrow Deficit $1,995.57 TOTAL WRIT $83,334.46 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, June 02, 2010 (PROTHONOTARY'S USE) Pltf. Paid T T Paid Deft . Due Proth/Clerk i 70 Other Costs . 1- MORTGAGE FORECLOSU "r Q ca = Issue Writ of Execution in the above captioned case. Date: March 5, 2010 Attorney for Plaintiff I--,- 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS P d- ? 3 &-& 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 507 FACTORY STREET CARLISLE, PA 17013 Date: 0A4•0 U?oL n? PROTH TARY/ ILERK CIVIL DIVISION 33.00 -(?,%+12. 9;.OO- ?r tr I A4.GC> - r? rr .?.rG _ tr cr ?'Zeo C6 f. ra LL' BY DEPUTY /L.T.ro - rr e r 1 ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the East side of Factory Street, which point is at line of land now or formerly of Emma J. Cline; thence by the East side of Factory Street in a northerly direction, 25 feet to a point at line of land now or formerly of Levi Stum; thence by said land in an easterly direction, 59 feet to a point; thence by the same in a southerly direction, 03 feet to a point; thence by the same in an easterly direction, 49 feet to an iron pin at line of land now or formerly of Albert C. Tritt; thence by said land in a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by said land in a westerly direction, 49 feet to a point at line of land now or formerly of Emma J. Cline; thence by said land in a northerly direction 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. BEING PART OF Lot No. 10 and Lot No. 11, Block 8, as shown in Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Cumberland County Recorder of Deeds Office in Misc. Book 11, Page 572. HAVING thereon erected a dwelling known and numbered as 507 Factory Street, Carlisle, PA 17013. PARCEL NO.: 06-20-1798-110. SUBJECT to all covenants, restrictions, reservations, easements, conditions and rights appearing of record; and SUBJECT to any state of facts an accurate survey would show. BEING THE SAME PREMISES WHICH Joseph R. Podlucky et al by deed dated 7/12/07 and recorded 7/17/07 in Cumberland County Record Book 280 Page 4907, granted and conveyed unto Adam J. Wagner. Coal and coal bed methane gas and mining rights and all rights incident to the extraction or development of coal or coal bed methane gas heretofore conveyed, excepted and reserved by instruments of record; the right of surface, lateral or subjacent support; or any surface subsidence. NOTICE: "THIS DOCUMENT MAY NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBED OR REFERRED TO HEREIN AND THE OWNER OR OWNERS OF SUCH COAL MAY HAVE THE COMPLETE LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAGE MAY RESULT TO THE SURFACE OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND" [This notice is set forth in the manner provided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of unrecorded instruments, if any.] OIL AND GAS EXCEPTION: Oil and gas and minerals and all rights incident to the extraction or development of oil and gas or minerals heretofore conveyed, leased, excepted or reserved by instruments of record. Jc U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL 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 507 FACTORY STREET CARLISLE, PA 17013: Name and address of the Owner(s) or Reputed Owner(s): 1 . r, r ADAM J. WAGNER - T 2459 MOSS TREE COURT r' ROCK HILL, SC 29730 - r7l 1-0 ` _. z- ADAM J. WAGNER -« 507 FACTORY STREET -cy q CARLISLE, PA 17013 ° c 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): Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Harrisburg, PA 17105-8029 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 507 FACTORY STREET 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 1. D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 5, 2010 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL IN MORTGAGE FORECLOSURE G 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: 507 FACTORY STREET 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. 09-8611 CIVIL JUDGMENT AMOUNT $79,650.79 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ADAM J. WAGNER 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 tract of land with the improvements thereon erected, situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the East side of Factory Street, which point is at line of land now or formerly of Emma J. Cline; thence by the East side of Factory Street in a northerly direction, 25 feet to a point at line of land now or formerly of Levi Stum; thence by said land in an easterly direction, 59 feet to a point; thence by the same in a southerly direction, 03 feet to a point; thence by the same in an easterly direction, 49 feet to an iron pin at line of land now or formerly of Albert C. Tritt; thence by said land in a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by said land in a westerly direction, 49 feet to a point at line of land now or formerly of Emma J. Cline; thence by said land in a northerly direction 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. BEING PART OF Lot No. 10 and Lot No. 11, Block 8, as shown in Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Cumberland County Recorder of Deeds Office in Misc. Book 11, Page 572. HAVING thereon erected a dwelling known and numbered as 507 Factory Street, Carlisle, PA 17013. PARCEL NO.: 06-20-1798-110. SUBJECT to all covenants, restrictions, reservations, easements, conditions and rights appearing of record; and SUBJECT to any state of facts an accurate survey would show. BEING THE SAME PREMISES WHICH Joseph R. Podlucky et al by deed dated 7/12/07 and recorded 7/17/07 in Cumberland County Record Book 280 Page 4907, granted and conveyed unto Adam J. Wagner. Coal and coal bed methane gas and mining rights and all rights incident to the extraction or development of coal or coal bed methane gas heretofore conveyed, excepted and reserved by instruments of record; the right of surface, lateral or subjacent support; or any surface subsidence. NOTICE: "THIS DOCUMENT MAY NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBED OR REFERRED TO HEREIN AND THE OWNER OR OWNERS OF SUCH COAL MAY HAVE THE COMPLETE LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAGE MAY RESULT TO THE SURFACE OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND" [This notice is set forth in the manner provided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of unrecorded instruments, if any.] OIL AND GAS EXCEPTION: Oil and gas and minerals and all rights incident to the extraction or development of oil and gas or minerals heretofore conveyed, leased, excepted or reserved by instruments of record. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8611 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 ADAM J. WAGNER (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 $79,650.79 L.L. $.50 Interest $1,606.50 - PER DIEM OF $10.71 TO SALE DATE 6/2/2010 Atty's Comm % Due Prothy $2.00 Atty Paid $165.50 Other Costs LATE CHARGES $16.32 PER MONTH TO SALE DATE 6/2/2010 -- ESCROW DEFICIT $1,995.57 Plaintiff Paid Date: MARCH 9, 2010 f David D. Buell, Pr honotary (Sea.) By: Deputy REQUESTING. PARTY: Name LEON-P. HALLLER, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET 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. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSN5NANi?, CIVIL ACTION LAW 1 NO. 09-8611 CIVIL mil) Xs IN MORTGAGE FORECLOSURE,> r• A RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 31 i a 1 An I (-) , 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: ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 ADAM J. WAGNER 507 FACTORY STREET CARLISLE, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 507 FACTORY STREET CARLISLE, PA 17013 Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Harrisburg, PA 17105-8029 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. PURCELL JR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 ADAM J. WAGNER 507 FACTORY STREET CARLISLE, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 507 FACTORY STREET CARLISLE, PA 17013 A 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 Pennsylvania Housing Finance Agency 211 North 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 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. 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. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL 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: 507 FACTORY STREET 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. 09-8611 CIVIL JUDGMENT AMOUNT $79,650.79 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ADAM J. WAGNER 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 tract of land with the improvements thereon erected, situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the East side of Factory Street, which point is at line of land now or formerly of Emma J. Cline; thence by the East side of Factory Street in a northerly direction, 25 feet to a point at line of land now or formerly of Levi Stum; thence by said land in an easterly direction, 59 feet to a point; thence by the same in a southerly direction, 03 feet to a point; thence by the same in an easterly direction, 49 feet to an iron pin at line of land now or formerly of Albert C. Tritt; thence by said land in a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by said land in a westerly direction, 49 feet to a point at line of land now or formerly of Emma J. Cline; thence by said land in a northerly direction 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. BEING PART OF Lot No. 10 and Lot No. 11, Block 8, as shown in Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Cumberland County Recorder of Deeds Office in Misc. Book 11, Page 572. HAVING thereon erected a dwelling known and numbered as 507 Factory Street, Carlisle, PA 17013. PARCEL NO.: 06-20-1798-110. SUBJECT to all covenants, restrictions, reservations, easements, conditions and rights appearing of record; and SUBJECT to any state of facts an accurate survey would show. BEING THE SAME PREMISES WHICH Joseph R. Podlucky et al by deed dated 7/12/07 and recorded 7/17/07 in Cumberland County Record Book 280 Page 4907, granted and conveyed unto Adam J. Wagner. Coal and coal bed methane gas and mining rights and all rights incident to the extraction or development of coal or coal bed methane gas heretofore conveyed, excepted and reserved by instruments of record; the right of surface, lateral or subjacent support; or any surface subsidence. NOTICE: "THIS DOCUMENT MAY NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBED OR REFERRED TO HEREIN AND THE OWNER OR OWNERS OF SUCH COAL MAY HAVE THE COMPLETE LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAGE MAY RESULT TO THE SURFACE OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND" [This notice is set forth in the manner provided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of unrecorded instruments, if any.] OIL AND GAS EXCEPTION: Oil and gas and minerals and all rights incident to the extraction or development of oil and gas or minerals heretofore conveyed, leased, excepted or reserved by instruments of record. 1 AFFIDAVIT OF SERVICE ( ommonwealth of Pennsylvania C ase Number: 09-8611 CIVIL County of Cumberland F laintiff: L S Bank National Association Trustee for The Pennsylvania Housing Finance Agency v C efendant: ? dam J. Wagner For Mindy Horley PURCELL KRUG & HALLER Common Pleas Court F eceived by FALCON EXP iS,? YICES, LLC to be served on Adam J Wagner, 2459 Moss Tree,,?c?rt, Rock F' I Ja29730. I, a ?r?S' being duly sworn, depose and say that on the _Lat -day of 20ly at executed service by delivering a true copy of the NOTICE OF SHERIFF'S S SALE F REAL ESTATE in accordance with state statutes in the manner marked below: ?'INDIVIDUAL SERVICE: Served the within-named person. (i SUBSTITUTE SERVICE: By serving ( ' POSTED SERVICE: After attempting service on at p ace on the property described herein. ( ' NON SERVICE: For the reason detailed in the Comments below. N ilitary Status: ( ) Yes or ( lyqO If yes, what branch? N arital Status: ( ) Married or ( ) Single Name of Spouse C OMMENTS: PP( f <9 I .ertify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in w rich this service was made. FALCON EXPRESS SERVICES, LLC P.O. Box 874 Charleston, SC 29402-0874 (843) 577-9696 Our Job Serial Number: 2010000606 Cofri I ?a08 Database Services, Inc. - Process Server's Toolbox V6.3e N?)TARY PUBLIC ••• •.•••••••?F C: 7 '(. Sibs 'bed nd Sworn to before me on the S day of, -, _YAL by the affiant who is pE Irsona ly known me. as and on _/_ at to a conspicuous Appointed in accordance with State Statutes 7160 3401 4848 7275 6141 TO: ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 SENDER:PHFA/WAGNER REFERENCE IOS 06/02/10 RETURN Postage RECEIPT SERVICE Certified Fee Return Receipt Fee Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail -------------------------------------------- 7160 3401 4848 7275 6184 TO: ADAM J. WAGNER 507 FACTORY STREET CARLISLE, PA 17013 SENDER:PHFA/WAGNER REFERENCEpOS 06/02/10 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees OSTMARK OR DATE US Postal Service Receipt for ? Certified ?q'i? ,. Mail 010 R ! ?? * No Insurance Coverage Provided Do Not Use for International Mail POSTMAR?OR DATE 010? Q s rt ort a+ 4- - . , PENNSYLVANIA HOUSING FINANCE AGENCY v. ADAM J. WAGNER 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: ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 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: ADAM J. WAGNER 507 FACTORY STREET 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 ? PIENEY BOWES 02 1M $ 01.150 0004284324 MAR 1 8 20010 MAILED FROM ZIP CODE 17102 PENNSYLVANIA HOUSING FINANCE AGENCY v. ADAM J. WAGNER Cumberland County Sale 6/2/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 507 FACTORY STREET 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: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Harrisburg, PA 17105-8029 '!t7 r nCb J „ AN? ??v® 3 1? Affinwow PITNEY BOWUS 02 1M $ 02.300 0004284324 ;AA.R 1 8 2010 •• MAILED FROM ZIPCODE 1 710 2 ~. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor • SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~.°~`~xr ct ~~[~mbrr~~~ ~~i ,' '~~, ;~.u; tiY; .,. oF~aGE of ~ ~~e °~~~ttwF 7 >-E~l~~ «- t~ r t }~~~~ r. ~~fO,~J~ I2 t~~ ~,~ b2 US Bank National Association vs. Case Number Adam J. Wagner 2009-8611 c~A~t~ .. - ~~~ t;~A~;.~,- JJ ~~r.n.. ~~~~L ~.rJ tir-~. SHERIFF'S RETURN OF SERVICE 03/30/2010 06:24 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on 3/30/10 at 1824 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 Adam J. Wagner, located at, 507 Factory Street, Carlisle, Cumberland County, Pennsylvania according to law. 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 P. Haller, on behalf of US Bank National Associatin, Trustee for the Pennsylvania Housing Finance Agency, 211 North Front Street, Harrisburg, PA, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1242.94 SHERIFF COST: $1,242.94 SO ANSWERS, July 09, 2010 RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Telecsoft, inc. a.~Pdp,Ca. ,~ ~ ~~d- ~ '~ 7709 ~~s as~f U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL 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 507 FACTORY STREET CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ADAM J. WAGNER 2459 MOSS TREE COURT ROCK HILL, SC 29730 ADAM J. WAGNER 507 FACTORY STREET 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): Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Hamsburg, PA 17105-8029 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 507 FACTORY STREET 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: March 5, 2010 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ADAM J. WAGNER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-8611 CIVIL 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: 507 FACTORY STREET 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. 09-8611 CIVIL JUDGMENT AMOUNT $79,650.79 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ADAM J. WAGNER 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 Baz Association 32 South Bedford Street Cazlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Cazlisle, 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 aze 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 pazagraphs 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 tract of land with the improvements thereon erected, situate in the 5th Ward of the Borough of Cazlisle, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the East side of Factory Street, which point is at line of land now or formerly of Emma J. Cline; thence by the East side of Factory Street in a northerly direction, 25 feet to a point at line of land now or formerly of Levi Stum; thence by said land in an easterly direction, 59 feet to a point; thence by the same in a southerly direction, 03 feet to a point; thence by the same in an easterly direction, 49 feet to an iron pin at line of land now or formerly of Albert C. Tritt; thence by said land in a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by said land in a westerly direction, 49 feet to a point at line of land now or formerly of Emma J. Cline; thence by said land in a northerly direction 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. BEING PART OF Lot No. 10 and Lot No. 11, Block 8, as shown in Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Cumberland County Recorder of Deeds Office in Misc. Book 11, Page 572. HAVING thereon erected a dwelling known and numbered as 507 Factory Street, Carlisle, PA 17013. PARCEL NO.: 06-20-1798-110. SUBJECT to all covenants, restrictions, reservations, easements, conditions and rights appearing of record; and SUBJECT to any state of facts an accurate survey would show. BEING THE SAME PREMISES WHICH Joseph R. Podlucky et al by deed dated 7/12/07 and recorded 7/17/07 in Cumberland County Record Book 280 Page 4907, granted and conveyed unto Adam J. Wagner. Coal and coal bed methane gas and mining rights and all rights incident to the extraction or development of coal or coal bed methane gas heretofore conveyed, excepted and reserved by instruments of record; the right of surface, lateral or subjacent support; or any surface subsidence. NOTICE: "THIS DOCUMENT MAY NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBED OR REFERRED TO HEREIN AND THE OWNER OR OWNERS OF SUCH COAL MAY HAVE THE COMPLETE LEGAL RIGHT TO REMOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAGE MAY RESULT TO THE SURFACE OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND" [This notice is set forth in the manner provided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of unrecorded instruments, if any.] OIL AND GAS EXCEPTION: Oil and gas and minerals and all rights incident to the extraction or development of oil and gas or minerals heretofore conveyed, leased, excepted or reserved by instruments of record. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEgLTH OF PENNSYLVANIA) NO 09-8611 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 ADAM J. WAGNER (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 $79,650.79 L.L. $.50 Interest $1,606.50 -PER DIEM OF $10.71 TO SALE DATE 6/2/2010 Atty's Comm Due Prothy $2.00 Atty Paid $165.50 Other Costs LATE CHARGES $16.32 PER MONTH TO SALE DATE 6/2!2010 -- ESCROW DEFICIT $1,995.57 Plaintiff Paid Date: MARCH 9, 2010 (Seal) REQ'~S i ING PARTY: Davi D. Buell, rothonotary By: Deputy Na.ne LE01~1 P. HALLER, ESQUIRE Address: PI3RCELL, KRUG &HALLER 1719 NORTH FRONT STREET 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 Carlisle Borough, Cumberland County, PA, Known and numbered as, 507 Factory Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Rea Estate Coordinator Z~..v~ ,,~ 0 ~ ~1}~ CiiOL __ - 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, V1Z: April 16, Apri123, and Apri130, 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. Li Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 0 da of Aril 2010 /~ Gt. Notary NUiARIAL SEAL DE80RAH A COLUNS Notary Public CARLISLE 80ROtiGH, CUMBERLAND COUNTY My Commission Expins Apr 26, 2014 watt xe. xoox-as1>< ciu US Bank National Association as Trustee for JP Morgan 2005-51 vs. Adam J. Wagner Atty: Leon P. Haller ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point on the East aide of Factory Street, which point is at line of land now or formerly of Emma J. Cline; thence by the East side of Factory Street in a northerly direction, 25 feet to a point at line of land now or formerly of Levi Stum; thence by said land in an easterly direction, 59 feet to a point; thence by the same in a southerly direction, 03 feet to a point; thence by the same in an easterly direction, 49 feet to an iron pin at line of land now or formerly of Albert C. Tritt; thence by said land in a southerly direction, 46 feet to a point at line of land now or formerly of Harry Kauffman; thence by said land in a westerly direction, 49 feet to a point at line of land now or formerly of Emma J. Cline; thence by said land in a northerly direction 24 feet to a point; thence by the same in a westerly direction, 59 feet to the place of BEGINNING. BEING PART OF Lot No. 10 and Lot No. 11, Block 8, as shown in Plan of Lots of Carlisle Land and Improvements Company, as recorded in the Cumberland County Recorder of Deeds Office in Misc. Book 11, Page 572. HAVING thereon erected a dwell- ing known and numbered as 507 Factory Street, Carlisle, PA 17013. PARCEL NO.: 06-20-1798-110. SUBJECT to all covenants, re- strictions, reservations, easements, conditions and rights appearing of record; and SUBJECT to any state of facts an accurate survey would show. BEING THE SAME PREMISES WHICH Joseph R. Podlucky et al by deed dated 7 / 12 / 07 and recorded 7/ 17/07 in Cumberland County Record Book 280 Page 4907, granted and conveyed unto Adam J. Wagner. Coal and coal bed methane gas and mining rights and all rights incident to the extraction or devel- opment of coal or coal bed methane gas heretofore conveyed, excepted and reserved by instruments of re- cord; the right of surface, lateral or subjacent support; or any surface subsidence. NOTICE: "THIS DOCUMENT MAY NOT SELL, CONVEY, TRANSFER, INCLUDE OR INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBED OR REFERRED TO HEREIN AND THE OWNER OR OWN- ERS OF SUCH COAL MAY HAVE THE COMPLETE LEGAL RIGHT TO RE- MOVE ALL OF SUCH COAL AND, IN THAT CONNECTION, DAMAGE MAY RESULT TO THE SURFACE OF THE LAND AND ANY HOUSE, BUILDING OR OTHER STRUCTURE ON OR IN SUCH LAND." This notice is set forth in the man- nerprovided in Section 1 of the Act of July 17, 1957, P.L. 984, as amended, and is not intended as notice of unre- corded instruments, if any.] OIL AND GAS EXCEPTION: Oil and gas and minerals and all rights incident to the extraction or develop- ment of oil and gas or minerals here- tofore conveyed, leased, exceptcd or reserved by instruments of record. ~, The Patriot; News Co. '~' 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 c'~e~latriot News NOw you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 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 orn to an , bscribed before m~ this y pf May, 2010 A. D. Notary c~MM_ OIVW~~1~ LYANL4 WopM1M MN SherrlR L. KINwr, Notary vubNc Lower rN~ TWDv DrtuQh~ County rry Commhglon ~~ troy, 26, 2011 04/23/10 04/30/10 Member, Penmyhr~nla Ateodadon of Notaries The Patriot-News Co. w ,' 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~he~latriot-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 04123/10 04/30/10 Sworn to an bscribed before m 'this~~ ypf May, 2010 A.D. ~, ~ ~~u~._ ~ Notary Public COMMdNW, N LVANIA Nt,~l ~eN Sh11M11 L. Khrler, Notary Publk Lower P#7ttor-'1'VMp., Deuphln County My CommldMofl Nov. x6, 2011 Member, PennSyNenla q~cydaHon of Notsrles a ~ tlb. t>~f1'1 ~. ~~ ~`~ ALL TEtAT'C$~iTAIN:tract of laed wjift .the, itoprovemanta iheraeu eraxcd, sites is the Sth Ward of the'$orongh of Carlisle` Cumbettund ~h:''YJ+'ania botnxled atd de.9at'be~l u f~gvts: B G at a point on thta East Heide of . ~, w1~6.poihtis at bne of land nog orfonneily of BuennsJ:Clina; thence 1ty tBe side of Factory in a.nattlKriy ditectlon,'25. fact to aat at line of land now or fotma~ly of Levi Stnm; thet~e ~ said land is ap easterly, direction; 39fedto apaint:l~ocfiy dte sartticin a so~tealy dkra~ion; 03~feefd~ a paint; tiraece by the s~o a in an ea9D~y dineedgn, 49;~Cot tb'ae iron pin at line'of land note a fsrmerly of Albat'C: Tritt; thence by said hud•'m a soly direction, 46 feet to apoint atlineof landnow or formerly of Harry Kauffman; thenceby said landing westerly diruxion, 49 feet to a point at line of land now or forhialy of Emma J. Cline; thence: by said land is a nottLaly direction 24 feetto a point;. thence by the same in a westerly direction, 59 feet to the place of BEGIlVIVING. BEMG'PART OF Lot No. 10 attd Lot No. 11, Block 8, as shownin Plan of Lots of Carlisle Land and Impmvements Company, as recorded in the Cumberland Coumy Recorder of Desds Officein Misc. Book 11, Page 532. HAVING thereon etectod a dwelling known a~ numbered as 507 Factory. Streot, Carlisle, PA 17013. - PARCEL NO.:'06-20-1798-110. SUBJECT to all covenants, restrictiots, eservatians, easements, condi6ona and rights .appearing of record; eruct SUBJ~CI' fQ any state of facts an accnratc stµvey, would sue'.: _ SJ~ , R ~ ` ' et ~ by dad dtwtl 7l1:?~tlJ atiat NC/A7, is C'~et~ad'C~9' laemd >~ ~` 49F~, ptwlltM~trieeea-~led tatibrl ~1.1N~rrtc Cd nerd Coal had inathYne gas;pnd ipining ri and al]'rlghts'incideffi to tht; extraction or developmoat of.coal ~ coal bed atttlane gas. he~o£o~re conveyed, excepted apd reserved by insdntaaetus otrecad', the tightofsotface; lateral err ttibjitcera auppott; of any stnface subsidence. Nd$iCE~: "Tkl~$ Df)CUI~tENT MAY NOT SLtEd.,, CdNV$1'; ,TRANSFER, INCLUDE 0~ IN~SiI~tE THR T1TLE Tb THE CO11L AND RltiH7' OF S1dI'PORT' UNDFaENEA'Tfi THIq 5L1~AdCE LAND bESCRIl3ED ~3R Rl~6RRlrD Tb HEitE1hI ANb Tf1E t>•V`4Vf+1t Olt; ~WNIaR$ t7F; SiICFJ COAL h1AY_ HAV'~ 'C13$,COHfPI,LE LL{3AL RIGFI'T TO RBMt)\-E ALL O31,3UC'Ii COAL AND, IN TFT~' CONIVEtfION, DA1P[AGE MAY RB$~IL.T'1'0 THE SfJRl;l1CE OIi THE LAND AID ANY 3i()U5E1 Bi11f331~1G OR O'!'HER S7~ItIJCI`f1RE Or{ OR f!`I SUCH LAND" Tins nodce~s set forth' ui the m Sscdon l pf iht Aa of hdy 17, X957 P.L. 984, as`amended,' and. is na intended as notico; of unrecorded inst+rmmemis, ~ any.] 011. AND GA$ R1CCi~''fION: Oil'and gas and adnatals and nll rigtea'incident tb the expaaron or devE~nseat of ~ asal pa or nliaaais herespd~'nte conveyed leased, excepted ix teearved s%' ianaime~nta of ancad. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which PENNSYLVANIA HOUSING FIN AGENCY TR is the grantee the same having been sold to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 9TH day of MARCH, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 8611, at the suit of PENNSYLVANIA HOUSING FINANCE AGENCY against ADAM J WAGNER is duly recorded as Instrument Number 201018448. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 9 ~~`l , A.D. ,20 / ~ day of Recorder of Deeds