Loading...
HomeMy WebLinkAbout10-5278Leon 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. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD Defendants i .: r. D E F it Flo AUG II PM 3.Oq 2013 AUG I I Pis -Ja 04 f .,E,?; Io - sa.-M C VitTer-M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 IMEPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFS CIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE *q&,I)O PA pTrY CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET all. 15? $4a CARLISLE, PA 17013 717-249-3166 244p taSY U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, 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. Defendants, MARCUS R. THOMPSON and CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, are adult individuals whose last known address is 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055. 3. On or about, June 19, 2007, the said Defendants executed and delivered a Mortgage Note in the sum of $148,900.00 payable to MEMBERS 1 ST FEDERAL CREDIT UNION, 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, Defendants 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 June 29, 2007 in Mortgage Book 1997, Page 4086 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 June 29, 2007 in Mortgage Book 738, Page 759. 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: 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on April 01, 2010 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $143,393.74 Interest at $22.31 per day $4,105.04 From 03/01/2010 To 09/01/2010 ( based on contract rate of 5.6000%) Accumulated Late Charges $170.96 Late Charges $42.74 $213.70 From 04/01/2010 to 09/01/2010 Escrow Credit ($165.05) Attorney's Fee at 5% of Principal Balance $7,169.69 TOTAL $154,888.08 **Together with interest at the per diem rate noted above after September 01, 2010 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. The Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 which contained amendments to Act 91 of 1983 (35 P.S. 1680.401c et. se ) and Pennsylvania Act 57 of 2008 which contained amendments to Act 6 of 1974 (41 P. S. 101 et. se ) by sending to each Defendant, by certified and regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notices dated June 7, 2010 is attached hereto as Exhibit "C". 10. The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. 11. The Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them 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% ($22.31 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: -1 /,.,' 4.-' L--' PUR ELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 1 1 _ U NOTE I T ` 9IIOLOAN #:HEC134654 JUNE 19TH, 2007 MECHANICSBURG PA [Date] [City] [State] 25 KIM ACRES DRIVE, MECHANICSBURG, PA 17055 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U. S. $ 148,900.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is MEMBERS 1ST FEDERAL CREDIT UNION I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.600 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1ST day of each month beginning on AUGUST 1ST, 2007 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on JULY 1ST, 2037 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 854.81 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. MULTISTATE FIXED RATE NOTE-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 32 0 1107 Wolters Kluwer Financial Services VMP®-5N (0207).01 Page 1 of 3 Iniliale: FCL 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. Form 1 1 VMP®-5N (0207).01 Papa2 of 3 Initial 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE (Seal) 4RISTIE HECKARD -Borrower - (Seal) -Borrower -(Seal) -Borrower - (Seal) -Borrower -(Seal) -Borrower - (Seal) -Borrower - (Seal) -Borrower - (Seal) -Borrower [Sign Original Only] R. THOMPSON VMP®-5N (0207).01 Pepe 3 of 3 Form 3200 1101 ALL THAT CERTAIN tract of land lying and being in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, being more particularly described according to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one- hundredths (120.32) feet East of the Center line of Berkshire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 11 on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point ; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13. North 05 degrees 07 minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. Tax Parcel # 42-24-2421-292 25 Kim Acres Mechanicsburg, Pa 17055 (?? 1 b (,, T 1, 6 " Date: 6/07/2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the Program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 717-780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT691 LR/dtmdocs/ALSW y HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NO.: .;HRISTIE R. THOMPSON MARCUS R. THOMPSON 25 KIM ACRES DR MECHANICSBURG, PA 17055-5588 1591940 CURRENT LENDER/SERVICER: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 15057 Harrisburg, PA 17105-5057 HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS; AND, * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the Consumer Credit Counseling Agencies listed at the end of this Notice. THIS MEETING MUST OCCUR _WITHIN THE NEXT (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the Consumer Credit Counseling Agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desianated Consumer Credit Counselinq Aqencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Program. To do so you must fill out, sign and file a completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated Consumer Credit Counseling ACT691 LR/dtmdocs/ALSV/ Agencies listed at the end of thin Notice. Only Consumer Credit Counsenng Agencies have applications for the Program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for Emergency Mortgage Assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 25 KIM ACRES DR, MECHANICSBURG, PA 17055-5588, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months April, 2010 thru the first of June, 2010 in the amount of $3,462.00 plus late charges that have accrued in the amount of $85.48. THE TOTAL AMOUNT DUE IS $3,547.48. This includes all payments, fees and expenses due, less any funds we are holding in suspense. HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,547.48 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash in our office, cashier's check, certified check or money order made payable and sent to: PENNSYLVANIA HOUSING FINANCE AGENCY 211 N FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 ACT691 LR/dtmdocs/ALSW IF YOU DO NOT CURE THE D`.-AULT-- If you do not cure the default witnin THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately three months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 717-780-3804 (FAX) Contact Person: KIMBERLEY AYALA Counseling Agencies: In addition to mailing Appendix B, Notice of Face-To-Face Meeting, please notify PHFA (when we are the first lien holder) of the face-to-face meeting and pending submission of application for HEMAP assistance by sending an e-mail to: Kayala@phfa.org. If you do not have access to e-mail, please call Kim Ayala at 717-780-1815 and advise of the face-to-face meeting. EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. (This does not apply if your mortgage was originated under the Home Start Program.) ACT691 LR/dtmdocs/ALSW . JU MAY ALSO HAVE THE RIGHT. * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY PHFA CCCS of Western PA 211 North Front Street 2000 Linglestown Road Harrisburg, PA 17110 Harrisburg, PA 17102 717.780.3940 888.511.2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 ACT691 LR/dtmdocs/ALSW Pennsylvania Housing Finance Aeencv _ Accounting & Loan servicin 211 North Front Stree4 P.O. Box 15057 Harrisburg, PA 1 71 05-505 7 (800) 346-3597 FAX (717) 780-3804 TTY (717) 780-1869 NOTICE 6/07/2010 CHRISTIE R. THOMPSON MARCUS R. THOMPSON 25 KIM ACRES DR MECHANICSBURG, PA 17055 RE: Account #1591940 TO: CHRISTIE R. THOMPSON MARCUS R. THOMPSON 25 KIM ACRES DR MECHANICSBURG, PA 17055-5588 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. Attachment: Housing Counseling List ACT691 LR/dtmdocs/ALSW HUD-APPh..oVED CREDIT COUNSELING f,GENCIES CCCS OF WESTERN PA-HARRISBURG NACA 2000 LINGLESTOWN RD. 1341 N DELAWARE AVE; SUITE 312 HARRISBURG, PA. 17110 PHILADELPHIA, PA. 19125 Phone:888-599-2227 Phone:888-297-5568 HOUSING ALLIANCE OF YORK 34 S. Duke St. York, PA 17401-1106 Phone: 800-864-4909 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608-1676 Phone: 717-397-5182 PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-930-4663 ACT691 LR/dtmdocs/ALSV/ 7160 3401 9848 9414 3016 TO: CHRISTIE R THOMPSON 25 KIM ACRES DR MECHANICSBURG,PA 17055 SENDER: THOMPSOT REFERENCE:1591940 RETURN RECEIPT CerWed FN SERVICE Rolm RooW Fee Totm Posteps a Fa US Pb" SWvla Receipt for Certified Mail No Nam= Cowmps Provided Do Not Use for hM W I AMY ---------- - - -- ...._.._.._..1.._ _. _. .. . w Lnn hd fD m a to T 1-3 to ?4 k C (n? d n a f< i F+? ? > ro Q J 0 7 ? Sego PQ% z ¢ r.? "affim? PITNEY BOW" 02 !A $ 01.15° 0C 43991 oq ?-407 20'Q MAILED FROM ZIP CODE x`710 7160 3901 9848 9414 3023 TO: MARCUS R THOMPSON 25 KIM ACRES DR MECHANICSBURG,PA 17055 SENDER: THOMPSOT REFERENCE:1591940 RETURN I POMP RECEIPT CertYled Fes SERVICE Return Rw&W Fss TOW Po"ps a Fess 5.1 us Postal SWAN PoSTMAAK QA, DATE Receipt. for CertMed Mail No NMUmnos Covemps P?ovided Do Not ties for Ifft"" al AMY 0 ?P Q to to N Q ° 00 ?d v o v (° P-? 71 PT, . PITNEY now" 02 1A $ 01.15° 413931 34 ;'JN 0 7 11,310 t.AA1LFD FROM ZIP(,()r)F ? 71i 1 --- --------------- i o I L .i o 1 tM ?ro ? c o z 0 n L p H IH Ir p W M ICY a r on it r o 4A smm? o - 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. a 4*? Anthony J. tJuli Director of Accounting and Loan Servicing Y /? !l PENNSYLVANIA HOUSING FINANCE AGENCY Date: lY I v SERVICING AGENT FOR U.S. BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,~ F~L~D-~~`~=1C~ r;~-~ RY US Bank National Association vs. Marcus R. Thompson (et al.) _. ~; ~: ., 4~~ .,,, ~~ S~ ~ ! S ~~~ 8~ S ~ ~~~~v~~s r~.urtraia 'v Case Number 2010-5278 SHERIFF'S RETURN OF SERVICE 09/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christine R. Thompson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Christine R. Thompson. Request for service at 25 Kim Acres Drive, Mechanicsburg, PA 17055 is vacant. However, The Mechanicsburg Postmaster is delivering Christine R. Thompson's mail to 25 Kim Acres Drive, Mechanicsburg, PA 17055. 09/03/2010 Ronny R. Anderson, 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 of 25 Kim Acres Drive, Mechanicsburg, PA 17055, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. Request for service at 25 Kim Acres Drive, Mechanicsburg, PA 17055 is vacant. 09/08/2010 03:13 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 8, 2010 at 1513 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Marcus R. Thompson, by making known unto himself personally, at 1209 Indian Peg Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~ NOAH CLINE, DEPUTY SHERIFF COST: $88.00 September 10, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW vs. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD Defendant(s) PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: September 30, 2010 ACTION OF MORTGAGE FORECLOSURE PURCELL, KRUG, & HALLER BY _ Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15100 No. 10-5278 C~ / ~ ~~g~ I~ ~ Pa7~ c3 ~~ ~ r ~= ~~ c-a ~~ r%~ ~; ~ ~ ° w .~~ v ~ .._,. ~ -~;. .~,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~1~titr 4f ~uirtg,~~,~~~~ ~r -~ ,~`r~; t~FF~G~ QF Fr+E 5~::.RiFF ~~ r `~d ~°y~~}^~~, Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank National Association vs. Marcus R. Thompson (et al.) ~~~~ ~~ ~ -~ ~a~~~~ 4~= 'L Case Number 2010-5278 SHERIFF'S RETURN OF SERVICE 10/04/2010 06:49 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 4 2010 at 1849 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christie R. Thompson, by making known unto herself personally, at 13 Pinetree Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 05, 2010 ROB BITNER, DEP TY SO ANSWERS, RON R ANDERSON, SHERIFF (ci CountySuite Shenfi. Teleosoft: Inc. 1 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA-, , CIVIL ACTION LAW NO. 10-5278 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) MARCUS R. THOMPSON and CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest Per diem of $22.31 From 03/01/2010 To 09/01/2010 Accumulated Late Charges Late Charges ($42.74 per month to 09/01/2010) Escrow Credit 5% Attorney's Commission TOTAL $143,393.74 $4,105.04 $170.96 $213.70 -$165.05 $7,169.69 $154,888.08 "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. A#Y 1414 111 PURCELL, KRUG & HALLE By Leon P. ler PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 l?r (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW Vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) NO. 10-5278 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on October 28, 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 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-5278 VS. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: October 28, 2010 TO: CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 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 ZPURCELL, KRUG & HALLE LEON P. HA LL R, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-41 '8 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-5278 VS. MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: October 28, 2010 TO: MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 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 & HALLE By / LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 r . , U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. MARCUS R. THOMPSON CHRISTIE R. THOMPSON FWA CHRISTIE R. HECKARD, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5278 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed, before me this day of & 20/0 L '1q P. HALLER, ESQUIRE C MVIONWE8 2E 1§Njj NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower PaAon Twp., Dauphin County My Commissim Expires Aug. 8, 2014 u WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5278 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 MARCUS R. THOMPSON, CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD (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 $154,888.08 L.L.$.50 Interest $4,060.42-- PER DIEM OF $20.89 TO SALE DATE 3/2/2011 Atty's Comm % Atty Paid $267.50 Due Prothy $2.00 Other Costs LATE CHARGES $42.74 PER MONTH TO SALE DATE 3/2/2011 -- $213.70 ----- ESCROW DEFICIT-- Plaintiff Paid $2,410.00 ----- *PLUS ADDITIONAL INTEREST, LATE CHARGES AND OTHER COSTS TO DATE OF SHERIFF'S SALE -- SALE DATE 3/2/2011 Date: 11/22/10 David D. Buell, Prothonotary (Seal} By: Deputy I*EQL.IBSTING PARTY: Name: LEON P. HALLER, ESQ Address: 1719'N FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 10-5278 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) Total Judgment Amount $154,888.08 Interest $4,060.42 Per diem of $22.31 to sale date 3/2/2011 Late Charges $213.70 $42.74 per month to sale date 3/2/2011 Escrow Deficit $2,410.00 TOTAL WRIT $161,572.20 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, March 02, 2011 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: November 18, 2010 Attorney for Plaintiff / 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 SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: 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 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 Date: ?r ALL THAT CERTAIN tract of land lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described according to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one-hundredths (120.32) feet East of the Center line of Berkshire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 1 I on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07 minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. HAVING THEREON ERECTED A DWELLING KNOWN AS 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TAX PARCEL NO.: 42-28-2421-292. BEING THE SAME PREMISES WHICH John H. Rudick by deed dated 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all conditions, restrictions and easements of record. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDGMENT NO. 10-5278 1 t t I r `i b '?. Its t' 0 N2111 2 2 PM I : PENNSYLVANIA Iii - G v a. sd pcl A?l 4 do Z, 9 pd. Ab? ?a.06 dtrt o pies ?issrt? r U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) NO. 10-5278 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 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 - _ r- MARCUS R. THOMPSON CD Cr 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 ` = Fa ' CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 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: r PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 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 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 (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. FJaWfrPA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 18, 2010 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON FWA CHRISTIE R. HECKARD, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5278 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 02, 2011 ` rA - n CD ?. TIME: 10:00 O'clock A.M. ` LOCATION: Cumberland County Courthouse ..x 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: 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 10-5278 JUDGMENT AMOUNT $154,888.08 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MARCUS R. THOMPSON and CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 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 Sheriff s 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 lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described according to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one-hundredths (120.32) feet East of the Center line of Berkshire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 11 on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07 minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. HAVING THEREON ERECTED A DWELLING KNOWN AS 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TAX PARCEL NO.: 42-28-2421-292. BEING THE SAME PREMISES WHICH John H. Rudick by deed dated 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all conditions, restrictions and easements of record. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDGMENT NO. 10-5278 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) IN THE COURT OF COMMON PLEAS t CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5278 ?' '? s r 7 IN MORTGAGE FORECLOSURE << RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on l oa l,19LCW) , 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: MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 MARCUS R. THOMPSON 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 By PURCELLt4CRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 .i Ilk LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINKA NICHOLE M. STALEY O'GORMAN LISA RYNARD MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 MARCUS R. THOMPSON 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 2344178 FAX (717) 234-1206 HERSHEY (717)533-3836 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 ivested by the sale and that you have an opportunity to protect your interest, if any, by being notified of Ile iffs ale. Leon P er PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5278 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 02, 2011 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: 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 10-5278 JUDGMENT AMOUNT $154,888.08 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MARCUS R. THOMPSON and CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 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 lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described according to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one-hundredths (120.32) feet East of the Center line of Berkshire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 11 on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07 minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. HAVING THEREON ERECTED A DWELLING KNOWN AS 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TAX PARCEL NO.: 42-28-2421-292. BEING THE SAME PREMISES WHICH John H. Rudick by deed dated 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all conditions, restrictions and easements of record. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDGMENT NO. 10-5278 ____ -_r.--__-.A--- 2. Article''Nurrjbw A. tisoNv?A ly ew C>e p C. Siynan, a o• 7160 3901 9849 1136 4637 -? D. Is del rent item 1 If YES, r; 3. Service Type CERTIFIED MAIL\ T 4. Restricted Delivery? (Extra Fee) 4-1yes 1. Article Addressed to: MARCUS R. THOMPSON Reference Information 25 KIM ACRES DRIVE MECHANICSBURG, PA 1705?nI?N??G NOS 03/02/11 ??? pM /76 ? PHFA/THOMPSON rEIN PS Form 3511, Jury 2005 Dontwft Return 2. Article Number oil A. F C. IC 7160 3901 9649 1138 41 3. Service TYPO CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) 1. Article Addressed to: MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 taO It Y tar t-nit as be Reference I nfoms t n NOS 03/02/ 1 1 PHFA/THOMPSON edms1T c.u p ? AgeM ? ? Addressee ? Yes ? No Delivery ? Addressee ? Ybs ? ? No 7160 3901 9849 1136 4644 TO: MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 SENDER: PHFA/THOMPSON REFERENCEINOS 03/02/11 7160 3901 9849 1138 4613 TO: CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 SENDER: PHFA/THOMPSON REFERENCENOS 03/02/11 RETURN Postage 0.61 -- RETURN Postage 0 61 RECEIPT SERVICE Certified Fee 2.80 RE?'C Certified Fee - 180 Return Receipt Fee 2.30 E Return Receipt Fee 10 Restricted Delivery 4.50 t Restricted Delivery Total Postage & Fees 10.21 Total Postage & Fees 10 ?1 US Postal Service K US Postal Service POS B Receipt for F`' c Receipt for G Certified Mail a Certified Mail a s ? v Do Not Use for International MW ? Do Not U f l t ti l .S` r se map or rt er ona 7160 3901 9849 1138 4620 7160 3901 9849 1138 4637 TO: CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TO: MARCUS R. THOMPSON 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 SENDER: PHFA/THOMPSON REFERENCEe4OS 03/02/11 RETURN Postage Q i RECEIPT Certified Fee S 2 ERVICE Return Receipt Fee 2 Restricted Delivery Total Postage & Fees ; US Postal Service OR Receipt for Certified Mail U No kmmnm Coverage Provided oe Not Use for In*mationW Mail SENDER: PHF'A/THOMPSON REFERENCONOS 03/02/11 RETURN Postage RECEIPT Certified Fee SERVICE Retum Receipt Fee Total Postage & Fees US Postal Service Receipt-for Certified Mail No Wounum Coverage PmvWW Do Not Use for In*-*-"al tail w C? 4 f 21 PENNSYLVANIA HOUSING FINANCE AGENCY v. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD Cumberland County Sale 3/2/2011 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: MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 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: CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: MARCUS R. THOMPSON 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 Postage: Postmark: ID O ?PNes POST F PYINEY ROWL5 0 2 1VI $ 01.150 0004284324 DEC03 2010 MAILED FROM ZIP CODE 1 7102 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: TENANT/OCCUPANT 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 Postmark: o?d ?F 4'17 NIFY 66WF5 02VO ` $ 01.150 0004284324 DEG03 2010 MAILED FROM ZIPGODE 1 7? 02 PIES P©gT ? ? r 'L7 d. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY va titt?, of Climb,1*14G OFD 'E -_ . _ FlED-OFFIC? 2C II APR I I AM I0= 37 CUMBERLAND COUNTY PENNSYLVANIA US Bank National Association vs. Christie R. Thompson (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2010-5278 01/0612011 12:24 PM - Deputy Sheldon Marshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 25 Kim Acres Drive, Mechanicsburg, PA 17055, Cumberland County. 01/14/2011 05:42 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Christie R. Thompson at 13 Pinetree Drive, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 01/21/2011 11:35 AM - Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be TIM THOMPON, FATHER, who accepted as "Adult Person in Charge" for Marcus R. Thompson at 1209 Indian Peg Road, Mechanicsburg, PA 17055, Cumberland County. 03/02/2011 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, Carlisle, Cumberland County, PA, on March 2, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Leon Haller, on behalf of US Bank National Association, Trustee for the Pennsylvania Housing Finance Agency, 211 North Front Street, Harrisburg, PA 17101, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,104.68 April 08, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ple.oa?r? a.oo So I?c? L.1L eA4 8«ss R-T c2S "9,S (Cl Countysulte Shen f. I elaosoft _ InC r . U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. MARCUS R. THOMPSON CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD, DEFENDANT(S) COPY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5278 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 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): MARCUS R. THOMPSON 1209 INDIAN PEG ROAD MECHANICSBURG, PA 17055 MARCUS R. THOMPSON 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD 13 PINETREE DRIVE MECHANICSBURG, PA 17055 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 pwperty 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): 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 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 (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. r PA I.D. 415700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 18, 2010 ALL THAT CERTAIN tract of land lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described according to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one-hundredths (120.32) feet East of the Center line of Berkshire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 11 on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07 minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. HAVING THEREON ERECTED A D)XTLLING KNOWN AS 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TAX PARCEL NO.: 42-28-2421-292. BEING THE SAME PREMISES WHICH John H. Rudick by deed dated 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all conditions, restrictions and easements of record. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDGMENT NO. 10-5278 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5278 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 MARCUS R. THOMPSON, CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD (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?ny-debt-Io?r ` _?Q, L h? a?L?,E?the-defendant-(s}snot-€rem-d efenda?r?------ (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 $154,888.08 L.L.$.50 Interest $4,060.42-- PER DIEM OF $20.89 TO SALE DATE 3/2/2011 Arty's Comm % Arty Paid $267.50 Plaintiff Paid Date: 11/22/10 Due Prothy $2.00 Other Costs LATE CHARGES $42.74 PER MONTH TO SALE DATE 3/2/2011 -- $213.70 ----- ESCROW DEFICIT-- $2,410.00 ----- *PLUS ADDITIONAL INTEREST, LATE CHARGES AND OTHER COSTS TO DATE OF S SALE -71S,4LE DATE 3/2/2011 (Seal) REQUESTING PARTY: Name: LEON P. HALLER, ESQ Address: 1719 N FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF David D. Buell, By: Deputy TRUE CORY FROM RECORD In Tesiimany Whereof, I here und and the seal of saia to W my I1A1 This r 6 Miele, Ps.Z4? i On December 2, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 25 Kim Acres, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 2, 2010 By: eal Estate Coordinator b t :Z cJ h Z AON NZ i .. f r __ •1 r1 J ? ? 6J A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 28, February 4, and February 11, 2011 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. v Li Marie Coyne, E ior SWORN TO AND SUBSCRIBED before me this 11 da of Februar 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-5278 Civil US Bank National Association vs. Christie R. Thompson Marcus R. Thompson Atty.: Leon P. Haller ALL THAT CERTAIN tract of land lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described ac- cording to survey of Robert E. Stiffler, Registered Surveyor, dated August 27, 1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line di- viding Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also referenced as a distance of one hundred twenty and thirty-two one-hundredths (120.32) feet East of the Center line of Berk- shire Road; thence extending along the Southern line of Kim Acres Drive, North 84 degrees 53 minutes East, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 and 11 on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of one hundred thirty two (132) feet to a point; thence along the Northern line of Lots Nos. 27 and 28 on said Plan, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line divid- ing Lots Nos. 12 and 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07 minutes West, a dis- tance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan be- ing recorded in Cumberland County Recorder's Office in Plan Book 10, Page 32. HAVING THEREON ERECTED A DWELLING KNOWN AS 25 KIM ACRES DRIVE, MECHANICSBURG, PA 17055. TAX PARCEL NO.: 42-28-2421- 292. BEING THE SAME PREMISES WHICH John H. Rudick by deed dat- ed 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all con- ditions, restrictions and easements ofrecord. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDG- MENT NO. 10-5278. 59 ,j he Patriot-News Co. +'920 Technology Pkwy suite 306 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ?latriotNews 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 Holly Blain.. 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly 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: 1128/11 214/11 2111/11 _ ..:.?. . Sworn to?nd"subscribed befor this,2 d* of-February, 2011 A.D. f r Notary Public t Nln(1ktV 4LTh OF PENNSYLVANIA 'i rye L Kisner, Nobary Public :oY:er Pax-4-") T1vp, Dauphin County Y, Lr1mmis lon Expires Nov. 26, 2011 "n 1"aura -ociation of Notaries 2010-5278 Chra Term U81Wel(fil n%M AssedWon Vs Chrlstt R. Thompson Marcus R. Thompson Mr. Leon P. Honer ALL THAT CERTAIN tract of land lying and being in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, being more particularly described according to survey of Robert E. Stiffier, Registered Surveyor, dated August 27,1968, as follows, to wit: BEGINNING at a point in the Southern line of Kim Acres Drive, which said point is in the line dividing Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots, said point being also reference as a distance of one hundred twenty and thirty- two one-hurAredths (120.32) het Eat of the tenter line of Berkshire Road: thence eiftndmg along the Souther ffm of Kim Arses Drive, North 94 de 53 minutes Fast; a distance of eighty ( to a point in the line dividing Lots Nos. 12 and I i on said Plan; thence along the line dividing Lots Nos. 12 and 11, South 05 degrees 07 minutes East, a distance of`one hundred thirty two (132) feet toapoint; 'thence along the Northern line of Lots Nos. 27 and 28 on said Platt, South 84 degrees 53 minutes West, a distance of eighty (80) feet to a point in the line dividing Lots Nos. 12 ad 13 on said Plan aforementioned; thence along the line dividing Lots Nos. 12 and 13, North 05 degrees 07-minutes West, a distance of one hundred thirty-two (132) feet to a point in the Southern line of Kim Acres Drive, aforementioned at the point and place of BEGINNING. BEING Lot No. 12, Plan of Section 1, Mt. Allen Heights, said Plan being recorded in Cumberland County Recorder's office in Plan Book 10, Page 32. HAVING THEREON ERECTED A DWELLING KNOWN AS 25 KIM ACRES DRIVE MECHANICSBURG, PA 17055 TAX PARCEL NO.: 42-28-2421-292. BEING THE SAME PREMISES WHICH John H. Rudiek by deed dated 6/19/07 and recorded 6/29/07 in Cumberland County Record Book 280 Page 3607 granted and conveyed unto Christie R. Heckard and Marcus R. Thompson. The said Christie R. Heckard is now known as Christie R. Thompson. UNDER AND SUBJECT to the building and use restrictions and rights of public utilities created by instruments of prior record. UNDER AND SUBJECT to all conditions, restrictions and easements of record. TO BE SOLD AS THE PROPERTY OF MARCUS R. THOMPSON AND CHRISTIE R. THOMPSON F/K/A CHRISTIE R. HECKARD ON JUDGMENT No. 10-5278 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 Sheriffs Deed in which Pennsylvania Housing Finance Agency Tr is the grantee the same having been sold to said grantee on the 2nd day of March A.D., 2011, under and by virtue of a writ Execution issued on the 22nd day of November, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 5278, at the suit of Pennsylvania Housing Finance Agency, Tr against Marcus R & Christie R Thompson aka Christie R Heckard is duly recorded as Instrument Number 201110694. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. of Deeds taeomW of De#, CutbwWW County, Carlisle, PA bly Owalseor? Dom the Rat Monday of Jan. 2014