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HomeMy WebLinkAbout10-5764Vii" Ti'?r? Leon 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. LEAH L. GLENN Defendant il- u3 r- _ 3 r,..; C t I 10 - 57&q C'wi-t Term 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, 0 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 S CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET Oa.00 PA A'MJ CARLISLE, PA 17013 0,11(coo o 717-249-3166 & 407272 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 LEAH L. GLENN, 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. LEAH L. GLENN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, 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, LEAH L. GLENN, is an adult individual whose last known address is 402 BEAVER AVENUE ENOLA, PA 17025. 3. On or about, January 14, 2005, the said Defendant executed and delivered a Mortgage Note in the sum of $89,294.00 payable to BROADVIEW MORTGAGE COMPANY, 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 January 19, 2005 in Mortgage Book 1894, Page 3820 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 January 19, 2005 in Book 714, Page 3239. 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: 402 BEAVER AVENUE ENOLA, PA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on February 01, 2010 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $10.19 per day From 01 /01/20 10 To 10/01 /2010 ( based on contract rate of 4.5000%) Accumulated Late Charges Late Charges $18.10 From 02/01/2010 to 10/01 /2010 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $81,545.16 $2,781.87 $314.60 $144.80 $338.32 $4,077.26 $89,203.01 "Together with interest at the per diem rate noted above after October 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 Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated May 24, 2010 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the May 24, 2010 Act 6 Notice is attached hereto and marked Exhibit "C". 10. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 11. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her 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 4.5000% ($10.19 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: PU CELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Multistate NOTE FHA Casa No 441-7608989-703 January 14th, 2005 [Date] 1032717 402 Beaver Avenue Enola, PA 17025 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means EROADVIEW MORTGAGE COMPANY and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of Eighty Nine Thousand Two Hundred Ninety Four and no/100. Dollars (U.S. $ 89,294.00 ) plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of percent( 4.500 ° ?° Four and one half ) 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 Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on March 1st 2005 . Any principal and interest remaining on the first day of February 2035 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 95 E. WILSON BRIDGE ROAD , WORTHINGTON, OH 43085 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U. S. $ 4 52.4 4 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] OGraduated Payment Allonge OGrowing Equity Allonge 00ther [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. -1 R (ssot).oFHA Nfultistate Fixed Rate Note - 10/95 (V VMP MORTGAGE FORMS-(600)527. Init Page 1 of 2 t itials: ? 40 9 VIA 1), I l 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four (B) Default percent( 4.00 %) of the overdue amount of each payment. If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Sea]) (Seal) L ah L Glenn -Borrower -Borrower (Seal) (Seal) .^rl"rI - RECCURSE, PAY TO THE ORDER OF: Borrower -Borrower Penns Ivanta Houtin Finance Agency (Seal) 6ri0Au/JlE /k'v mU, T \G?CO4,hP, -Borrower (Seal) -Borrower BY: ` / r I / (Seal) E (Seal) k4arfha -Borrower -Borrower A-s8!Stant Secretary •1 R (9601)_03 m Page 2 of 2 ALL THAT CERTAIN lot of g County of Cumberland and round situate in the and described as and and State of Pennsylvania, Township more of East ro, follows, o wit: more particularlly y b bounounded BEGINNING at a point on the East one hundred (100) feet measured aside of Beaver wards g the East sidenue, said point being y direction from Shady Lane; thence Eastwardl on Avenue, in a parallel to Shady Lane fifty (50) feet to a a line parallel to Beaver Avenue fifty Y on a line Northwardly Westwards Point; thence alley; on y along said alley fifty (50) feet to an alley; Southwardly along the East side o (50} feet n Beaver Avenue. thence point, the place of BEGINNING of Beaver Avenue, fift thence Y (50) feel- t-„ , BEING the North by A. R. Young, Plan Book No. 1, fifty (50) feet of as recorded in the Page 92. Lot No. 17 in the Plan of Cumberland Count Lots laid out y Recorder's Office in Cxh;bI , }"R" 'ennsyfvania Holising Finance A I cenuntinu Ar 1 ann ..Q%Prvirin 211 North Front .Street, P.O. Box 151157 Ilurrisburg, PA 17105-5057 (800) 346-3597 FAX (717) 780-3899 TTY (717) 780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 5/24/2010 RE: Account No. 1248632 LEAH L. GLENN 402 BEAVER AVE ENOLA, PA 17025-2307 RE: 402 BEAVER AVE ENOLA, PA 17025-2307 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter We, Us or Ours) on your property located at 402 BEAVER AVE, ENOLA, PA 17025-2307, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $624.00 for 2/2010 through 5/2010 for a total of $2,496.00. Late charges and NSF charges that have accrued to this date in the amounts of $235.30 and $25.00 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 $2,884.30. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $2,884.30, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash in our office, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This means 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 mortgageed property. 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 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. FHAACT/dtmdocs/ALSV/ 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 Ps foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's 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 in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's 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 LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE 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. Sincerely, -1 "" Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 TLG/ FHAACT/dtmdocs/ALSV/ ennsyPvania Mij sing F inance A NOTICE 5/24/2010 LEAH L. GLENN 402 BEAVER AVE ENOLA, PA 17025-2307 RE: Account #1248632 TO: LEAH L. GLENN 402 BEAVER AVE ENOLA, PA 17025-2307 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY ccounting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05-5 05 7 (800) 346-3597 FAX ("717) 780-3899 TTY (717) 780-1869 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. 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. Attachment: Housing Counseling List FHAACT/dtmdocs/ALSW *** PLEASE BE SURE THE AG CCCS OF WESTERN PA-HARRISBURG 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 HOUSING ALLIANCE OF YORK DEVELOPMENT 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 OF YOUR CHOICE SERVICES YOUR COUNTY *** NACA 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 Phone:888-297-5568 PHILADELPHIA COUNCIL OF COMMINITY ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-930-4663 FH AACT/dtmdocs/ALS V/ PENNSAVANIA HOUSING FINANCEAGENCY Single Family Programs Division 211 North Front Street POB 15057 Harrisburg, PA 17105-5057 (717) 780-3870 / (717) 780-1869 TDD # for the Hearing Impaired April 6, 2010 Leah Glenn 402 Beaver Ave. Enola, PA 17025-2307 Re: PHFA Mortgage Loan: # 1248632 Dear Ms. Glenn: Please know that as of today your account is being considered for foreclosure. PHFA would welcome the opportunity to discuss your account and financial situation with you. Please contact PHFA at 800-822-7375. Financial forms have been included if you would like to pursue loss mitigation efforts to save your home. Your account will be held until April 20, 2010, in my office. After that time your account will be forwarded to our attorney, and legal fees will begin to accrue. Sincerely, Richelle Strawser Senior Loan Officer PHFA I 7160 3901 9848 9414 5706 TO: LEAH L GLENN 402 BEAVER AVE ENOLA,PA 17025 SENDER: GOOD REFERENCE: 1248632 -0 RETURN Postage RECEIPT Ce tifi 44 r ed Fee SERVICE 2 , 8 0 Return Receipt Fee 2 Restricted Delivery Total Postage & Fees 9-54 US Postal Service POStMARK OR DATE Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail -- v 7 r0 N N w w V .-1 • 1 Q F- of M r: w w 7 H w ro m -, +J a a 0 w z z N In o c r F- > > w w c c a LL Y w W J J i ? 0 t` 0 x a a- O a O c c O O M N M N ° C E M iJ > > n. u1 N 0 ul N 0 D w a AA am ad 41 ao do J a a a o a (D N z rL a. > ?! w ?aN vi X z Y co -a .. w (L z w J.+ y C 4k ik J r, >rn L Ln C 0 d4 trE J N 0 00 0 W Q w o w N X U N+) w Q CA: .. c o H e z > co `O w v w > a w > a •,4 ++ a > Q• N G 2 W co W W Q m a ...I L T W to o N H o Cl J N o O N z 0 -j O z U N w •o vl w O .•? ... N IT W S W A r- H 0 * 1.9 111 A C 1 L r1 •H" L '-1 "4 O. L -i L r1 m ro•• oa LaroLGmO' oeeoeeLV .ia MV co w JU cc Wwca wwaa Ea J 1 r or z tit N i i'I ? Ao >C M r ?•.i `rd C?J i W J O C i N , ji) z (1 F.l v n F ? C ;U d MCC at = rz;1 _-- -? InOz AD-4 M OHO 'Im114 = 0 00m ;a z D M ;a x O O S4 F+ x :0 ? O A r6 ?. O C ? nq ? aro r 0 x k•? T G W d tt?? A ON i X lT' 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. Julian Director of Accounting and Loan Servicing PENNSYLVANIA HOUSING FINANCE AGENCY Date: _ ql3o- SERVICING AGENT' FOR U.S. BANK, NATIONAL ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCI AQFNCY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank National Association vs. Leah L. Glenn l^tfF7 E 'r- . `? RWF a?^ +i. I'. ._. 3i Jc' J Case Number 2010-5764 SHERIFF'S RETURN OF SERVICE 09/20/2010 06:00 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2010 at 1800 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Leah L. Glenn, by making known unto herself personally, at 402 Beaver Avenue, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHE14 BENDER, DEPUTY 09/23/2010 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 402 Beaver Avenue, Enola, PA 17025, 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 402 Beaver Avenue, Enola, PA 17025 is only occupied by Leah L. Glenn. SHERIFF COST: $62.94 September 23, 2010 SO ANSWERS, 2wj?`?~? RON R ANDERSON, SHERIFF ;c GountySuite Sherft. Tteieosott. ini:. Leon 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. LEAH L. GLENN Defendant TRUE COPY FROM RECORD In Tealmony whereof, t hero unto set my hind and the seal of said at Carlisle. Pa. day pf 20.(,Q- This -fi ?/ , Pnotlwrwtaey to - 5q&y 0,M L Tenn 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 RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y 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 ....,. i.}!. .,„.v._,.. ............ ?4P {??hi?x .......,... ........ ,.-1 ?iul Q.? r i?.' j? .9 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. LEAH L. GLENN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, . Plaintiff vs. LEAH L. GLENN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, 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, LEAH L. GLENN, is an adult individual whose last known address is 402 BEAVER AVENUE ENOLA, PA 17025. 3. On or about, January 14, 2005, the said Defendant executed and delivered a Mortgage Note in the sum of $89,294.00 payable to BROADVIEW MORTGAGE COMPANY, 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 January 19, 2005 in Mortgage Book 1894, Page 3820 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 January 19, 2005 in Book 714, Page 3239. 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: 402 BEAVER AVENUE ENOLA, PA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on February 01, 2010 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $10.19 per day From 01/01/2010 To 10/01/2010 (based on contract rate of 4.5000%) Accumulated Late Charges Late Charges $18.10 From 02/01/20 10 to 10/01 /2010 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $81,545.16 $2,781.87 $314.60 $144.80 $338.32 $4,077.26 $89,203.01 **Together with interest at the per diem rate noted above after October 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 letter dated May 24, 2010 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the May 24, 2010 Act 6 Notice is attached hereto and marked Exhibit "C". 10. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 11. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her 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 4.5000% ($10.19 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: At? PU CELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 1 (F? NOTE HA Casa No. Multistate 441-7508989-703 January 14th, 2005 [Date] 402 Beaver Avenue F,nola, FA 17025 [Property Address) 1032717 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means BROADVIEW MORTGAGE COMPANY and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of Eighty Nine Thousand Two Hundred Ninety Four and no/100. Dollars (U.S. $ 89,294.00 plus interest, to the order of Lender, Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Four and one half percent( 4 .500 %) per year until the full amount of principal has been paid. 3. PRONUSE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on March 1st , 2005 . Any principal and interest remaining on the first day of February ; 2035 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 95 E. WILSON BRIDGE ROAD , WORTHINGTON, OH 43085 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U. S. $ 4 52 .4 4 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ?Graduated Payment Allonge ?Growing Equity Allonge ?Other (specify) 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due daze or in the amount of the monthly payment unless Lender agrees in writing to those changes. FHA Ni lultistate Fixed Rate Note - 10/95 -1 R (9601).03 m VMP MORTGAGE FORMS •(600)527.729 Page f of 2 Initials: 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent( 4.00 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. L /?/?--- (Seal) (Seal) L ah L Glenn -Borrower -Borrower (Seal) (Seal) ^r;HJUT RECOURSE, PAYTOTHEORDEROF: -Borrower -Borrower Panns fvania Hot*in Finance Agency (seal) (Seal) Y l`t,U?T G2GOP?P, SR0.ADVf ,1 , Borrower Borrower T (Seal) (Seal) aY. ' v v ( -Borrower Borrower k4artha Barnhart A.8sistant Secr tar -1 R (9so i p3 Page t of 2 O ALL THAT CERTAIN lot of ground situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Beaver Avenue, said point being one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardly direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty (50) feet to a point; thence Northwardly on a line parallel to Beaver Avenue fifty (50) feet to an alley; thence Westwardly along said alley fifty (50) feet to Beaver Avenue; thence Southwardly along the East side of Beaver Avenue, fifty (50) feet to a point, the place of BEGINNING. BEING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A. R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. Pennsyl-;ania Ho' sin F Finance A fry "accounting & Loan Servicing 311 North Front .Street, P.O. Box 15057 Ilurrisburg, PA 1 71 05-505 7 (800) 346-3597 FAX (717) 780-3899 TTY('717) 780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 5/24/2010 RE: Account No. 1248632 _EAI- L. GLENN 102 BEAVER AVE E7NOLA, PA 17025-2307 RE: 402 BEAVER AVE ENOLA, PA 17025-2307 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter We, Us or Ours) on your property located at 402 BEAVER AVE, ENOLA, PA 17025-2307, IS IN SERIOUS C EFAULT because you have not made the monthly payments of $624.00 for 2/2010 through 5/2010 for a total of $2,496.00. Late charges and NSF charges that have accrued to this date in the amounts of $235.30 and $25.00 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 tctal arnount now required to cure this default, or in other words, get caught up in your payments, as of the data of this letter is $2,884.30. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $2,884.30, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash in our office, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borroweJ 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 mortgageed property If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the moilgage 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 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 he required to pay attorney fees. `i i I FHAACT/dtmdocs/ALSV/ 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 sheriffPs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's 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 in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's 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 LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYS FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE 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. Sincerely, -j-V" Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 TLG/ FH AACT/dtmdocs/ALSV/ • peI2I?Sy1``va'.nla. Musin l? hance Age y ccauntin & Loan Servicing -- 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05-5 05 7 (800) 346-3597 FAX ('717) 780-3899 TTY (717) 780-1869 NOTICE 5/24/2010 LEAH L. GLENN 402 HEAVER AVE ENCLA, PA 17025-2307 IRE: Account #1248632 TO: LEAH L. GLENN 4C2 BEAVER AVE ENOLA, PA 17025-2307 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 1omeownership 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. Attachment: Housing Counseling List FH AACT/dtmdoc s/ALS V/ y. *** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY *** CCCS OF WESTERN PA-HARRISBURG 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 NACA 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 Phone:888-297-5568 HOUSING ALLIANCE OF YORK DEVELOPMENT 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 ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-9304663 FH AA CT/dtmdocs/ALSV/ PENNS AVANIA HOUSING FINANCEAGENCY Single Family Programs Division 211 North Front Street POB 15057 Harrisburg, PA 17105-5057 (717) 780-3870 / (717) 780-1869 TDD # for the Hearing Impaired April 6, 2010 Leah Glenn 402 Beaver Ave. Enola, PA 17025-2307 Re: PHFA Mortgage Loan: # 1248632 Dear Ms. Glenn: Please know that as of today your account is being considered for foreclosure. PHFA would welcome the opportunity to discuss your account and financial situation with you. Please contact PHFA at 800-822-7375. Financial forms have been included if you would like to pursue loss mitigation efforts to save your home. Your account will be held until April 20, 2010, in my office. After that time your account will be forwarded to our attorney, and legal fees will begin to accrue. Sincerely, Richelle Strawser Senior Loan Officer PHFA 7160 3901 9&46 9414 5706 TO: LEAR BEAVER AVE ENOI.A, pA. 1_'7025 SENDER GOOD REFERENCE: 1248632 RETURN V--.- RECEIPT Certified Feb SERVICE Retum Receipt Fee Restricted Delivery postage & Fees ¢I I Iota postMARK OR DATE US Postal Service t #or Receip fert! fie d mail nsurance Coverage pnarovided tiol meld Do Not Use fir intema N N r .0 A on a u 4 az > cam. ° d c F O ? c "? ? N J - o ul w 4rn °A 0 40 J 4 n. a Lea N o O ,r V+ N Z y Y 00 .+ w J L4 C ?k > H J 1 L in H 2 N n , rA ' ? v u N .4 .11 w > N m `t 0 N ? o a cn n. L o b ? VI ,- ° us ° .. on- -4 U N 0 r- 4 CL. r- 0 rn N m N r- 4 a a w w 0 4 W a 4 w W 4 La J J L U LU J N O c Z w Z IT w n ° IT r-1 L M L '? A 0'a .'1 b y O is p O w t= U, E 4 w 4 J ww o F• ?w O N is `t y? ) •? C U't O Z ? C1 t ? wl += .t -t d tACC ?` - wl '? r a AD-A OHO is flo 0 OOM _ O O O O O v. 4a O O c c ? C ?o vt ul M a a - Mao, ??- 000 a L O a, 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. Julian Director of Accounting and Loan Servicing PENNSYLVANIA HOUSING FINANCE AGENCY 5Z 3h-0 SERVICING AGENT FOR U.S, BANK, NATIONAL Date: ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5764 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 LEAH L. GLENN (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 $89,202.01 L.L.$.50 Interest PER DIEM OF $10.19 TO SALE DATE 6/1/2011 -- $2,455.00 LATE CHARGES $18.10 PER MONTH TO SALE DATE 6/1/2011 -- $126.70 ESCROW DEFICIT $1,990.45 Atty's Comm % Due Prothy $2.00 Atty Paid $195.44 Other Costs Plaintiff Paid Date: 1/10/11 vid D. Bu ill, Prothonotary iSel,) By: Deputy RFQUESTING PARTY: Name: LEON P. HALLER, ESQUIRE Address: 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. LEAH L. GLENN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM DEFENDANT(S) I MORTGAGE FORECLOSURE C ' PRAE CIPE ? TO THE PROTHONOTARY OF THE WITHIN COUNTY: ? ,- Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant =w> LEAH L. GLENN for failure to plead to the above action within twenty (20) days from date ofserV to of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance $81,545.16 Interest $2,781.87 Per diem of $10.19 From 01/0 1 /2010 To 10/01/2010 Accumulated Late Charges $314.60 Late Charges $144.80 ($18.10 per month to 10/01/2010) Escrow Deficit $338.32 5% Attorney's Commission $4,077.26 TOTAL $89,202.01 "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 Y Leon P. Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 ???L? ?? (717) 234-4178 -t 103 9sl 4q7od53 7yb t 101c( mach .lk U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LEAH L. GLENN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM IN MORTGAGE FORECLOSURE RELIEF FROM STAY . W. UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: LEAH LYNN GLENN BANKRUPTCY NO. 1-10-bk-07804-MDF Debtor CHAPTER 7 U.S. BANK, NATIONAL ASSOCIATION TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Movant VS. LEAH LYNN GLENN and MARDIAN R. SLOBODIAN, Trustee Respondents O R D E R Upon consideration of the Motion of U.S. Bank, National Association Trustee for Pennsylvania Housing Finance Agency to Obtain Relief from Stay, the parties having consented thereto, the Motion is hereby granted and the automatic stay is terminated as to the Movant relative to property situate at 402 Beaver Avenue, Enola, Pennsylvania 17025. By the Court, A4 & IW Chief Bw"" Judge pat Dated: November 4, 2010 Case 1:10-bk-07804-MDF Doc 19 Filed 11/04/10 Entered 11/04/10 15:10:02 Desc Main Document Page 1 of 1 l? U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. LEAH L. GLENN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on December 1, 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. LEAH L. GLENN Defendant DATE OF THIS NOTICE: December 1, 2010 TO: LEAH L. GLENN 402 BEAVER AVENUE ENOLA, PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-5764 CIVIL TERM CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALLER By LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 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. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LEAH L. GLENN, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed LEON P. HALL ??; QUIRE BaMM0N!jj,? 211 CjNNjt1&NIA NOTARIAL SEAL MARYLAND K. FERREITI, Notary Public Lower PmW De In County My CoE Ip, on -rp ,-r es pug. 8, 2014 before me this L day of 20/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 10-5764 CIVIL TERM U.S. BANK NATIONAL ASSOCIATION TRUSTEE Total Judgment Amount $89,202.01 FOR THE PENNSYLVANIA HOUSING FINANCE Interest $2,455.00 AGENCY, Per diem of $10.19 to sale PLAINTIFF date 6/1/2011 Late Charges $126.70 VS. $18.10 per month to sale date 6/l/201 1 LEAH L. GLENN, Escrow Deficit $1,990.45 DEFENDANT(S) TOTAL WRIT $93,774.16 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, Jun e 01, 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. D m ate: January 11, 2011 A-- M <> co Attorne for Plaintiff Y - n1 1719 North Front Street Leon P. Hall c-: Harrisburg, PA 17102 PA I.D. #15700 w `F (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 402 BEAVER AVENUE ENOLA, PA 17025 Date: J //"/ PROTH NO ARY/C RK CIVIL DIVISION ?'Gl Irdtf l/D, HW9 ?V P tb 6o rr R/ ( rr 11 -? "sO fe 'i ) q11 f-?J 141 ow / t6 t QoA4i BY DEPUTY ALL THAT CERTAIN lot of ground situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Beaver Avenue, said point being one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardly direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty (50) feet to a point; thence Northwardly on a line parallel to Beaver Avenue fifty (50) feet to an alley; thence Westwardly along said alley fifty (50) feet to Beaver Avenue; thence Southwardly along the East side of Beaver Avenue, fifty (50) feet to a point, (erroneously omitted from previous deed), the place of BEGINNING. BEING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A.R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. HAVING THEREON ERECTED A DWELLING KNOWN AS 402 BEAVER AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH Elwood Long and Phyllis Long, husband and wife, by deed dated 1/14/05 and recorded 1/19/05 in Cumberland County Record Book 267 Page 970, granted and conveyed unto Leah L. Glenn. TO BE SOLD AS THE PROPERTY OF LEAH L. GLENN ON JUDGMENT NO. 10-5764 CIVIL TERM. ASSESSMENT NO. 09-13-1002-161. UNDER AND SUBJECT, NEVERTHELESS, to conditions, easements, restrictions and matters of prior record and any matter which a physical inspection or survey of the property would disclose. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LEAH L. GLENN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM 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 th ealEjropelty located at 402 BEAVER AVENUE ENOLA, PA 17025: - K - :-,"2 - I-rim c. - Y *! I...,i 1. Name and address of the Owner(s) or Reputed Owner(s): r -- LEAH L. GLENN 402 BEAVER AVENUE - ENOLA, PA 17025 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 402 BEAVER AVENUE ENOLA, PA 17025 Dorothy L. Mott, Esquire 125 State Street Harrisburg, PA 17101 (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 ubject 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: January 11, 2011 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LEAH L. GLENN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: r° That the Sheriffs Sale of Real Property (real estate) will be held: r-q CO DATE: Wednesday, June 01, 2011 > CD TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse '- CD f.- 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: 402 BEAVER AVENUE ENOLA, PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 10-5764 CIVIL TERM JUDGMENT AMOUNT $89,202.01 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: LEAH L. GLENN I',; 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 lot of ground situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Beaver Avenue, said point being one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardty direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty (50) feet to a point; thence Northwardly on a line parallel to Beaver Avenue fifty (50) feet to an alley; thence Westwardly along said alley fifty (50) feet to Beaver Avenue; thence Southwardly along the East side of Beaver Avenue, fifty (50) feet to a point, (erroneously omitted from previous deed), the place of BEGINNING. BEING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A.R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. HAVING THEREON ERECTED A DWELLING KNOWN AS 402 BEAVER AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH Elwood Long and Phyllis Long, husband and wife, by deed dated 1/14/05 and recorded 1/19/05 in Cumberland County Record Book 267 Page 970, granted and conveyed unto Leah L. Glenn. TO BE SOLD AS THE PROPERTY OF LEAH L. GLENN ON JUDGMENT NO. 10-5764 CIVIL TERM. ASSESSMENT NO. 09-13-1002-161. UNDER AND SUBJECT, NEVERTHELESS, to conditions, easements, restrictions and matters of prior record and any matter which a physical inspection or survey of the property would disclose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson TH- i ?? ,r PP 0 Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor «?I I jul -$ Pry I4: CUMBEPTAhi; C t ' 1 ' PEN1gSYLVAt lr. US Bank Trust National Association Case Number vs. Leah L. Glenn 2010-5764 SHERIFF'S RETURN OF SERVICE 03/14/2011 05:29 PM - Deputy Ryan Burgett, 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 402 Beaver Avenue, Enola, PA 17025, Cumberland County. 03/14/2011 05:29 PM - Deputy Ryan Burgett, 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: Leah L. Glenn at 402 Beaver Avenue, East Pennsboro Township, Enola, PA 17025, Cumberland County. 06/01/2011 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, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to U.S. Bank National Association, et. al., 211 North Front Street, Harrisburg, PA 17101, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $864.27 July 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 3 i c` 1r GS .r f 1) S BitT?K NA 1 ;?:N;'.L ASSOCIA'i'iON 'IRUS7EE h F P k- 11F\ '•.NI A I?OUSINC; FINANCE PLAIN F IFF i_t=AH L. GL1NN" DEFENDANT(S) COPY !N THE CO1 RT OF COMMON N(-.AS Ci;MBERLAND C"_'N"I Y. P A`N`> "LVANIA CIVIL ACTON LAW NO. 10-5764 CIVIL TERM 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 402 BEAVER AVENUE ENOLA, PA 17025: Name and address of the Owner(s) or Reputed Owner(s): LEAH L. GLENN 402 BEAVER AVENUE ENOLA. PA 17025 ?. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 5. 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 2''.1 North Front Street P. O. Box 8029 Harrisburg, PA 17105-8029 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 ?. 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: 1) 0MF: 1`i4- .Ll'LAi 10NS umber?and t,- f?ourthouse Norf,l Hanover Street Carlisle. PA 17013 IINI ANIVOCCI_!PANT 402 BEAUR A`'FNMTF FNOLA. PA 17025 Dorothy L. Mott. Esquire State Street Harrisbura. P.4 17101 (In the preceding information, where addresses could not be reasonably- ascertained, the same is i 9dicated.) 1 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. 91 X700 Purcell, Krug & faller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: January 11. 2011 BANK NXIIONAL. ASSOCIATION TRUSTEE LCR THE PENNSYLVANIA HOUSING FINANCE PLAINTIFF VS. L1?AH L. GLENN. DEFENDANT(S) IN THE COURT OF COl,,I G'tt !111 .S CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION LAW NO. 10-5764 CIVIL TERM 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 01, 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: 402 BEAVER AVENUE ENOLA, PA 17025 THE, JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 10-5764 CIVIL TERM JUDGMENT AMOUNT $89,202.01 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: LEAH L. GLENN 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 b% 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 P14OPF.RTV 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 'Vou 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. 'SOU SHOIALD TAKE THIS PAPER TO FOUR LAWYER AT ONCE. GO TO OR . LEPHONE TIDE OFFICE SET FORTH BELOW TO FIND OiIT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle. Pennsylvania 17013 717-249-3166 Legal Services, Inc 3 Irvine RoNv 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 iudgment 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 fora 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 IIarrisburg, PA 17102 (717) 234-4173 AUIt 1]IAT (`ERTAIN lot of ground situate in the Township of East Pennsboro, County of Cumberland and Commomvealth of Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on the East side of Beaver Avenue, said point being one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardly direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty (50) feet to a point; thence Northwardly on a line parallel to Beaver Avenue fifty (50) feet to an alley; thence Westwardly along said alley fifty (50) feet to Beaver Avenue; thence Southwardly along the East side of Beaver Avenue, fifty (50) feet to a point, (erroneously omitted from previous deed), the place of BEGINNING. BRING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A.R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. HAVING THEREON ERECTED A DWELLING KNOVNrN AS 402 BEAVER AVENUE, ENOLA. PA 17025 BEING THE S.-VME PREMISES WHICH Elwood Long and Phyllis Long, husband and Nvife., by deed dated 114/05 and recorded 1/19/05 in Cumberland Count-," Record Book 267 Page 970, granted and conveyed unto Leah L. Glenn. TO BE SOLD AS THE PROPERTY OF LEAH L, GLENN ON JUDGMENT NO. 10-5764 CIVIL TERM. ASSESSM N'T NO. 09-13-1002-161. UNDER AND SUBJECT, NEVERTHELESS, to conditions, easements, restrictions and matters of prior record and any matter which a physical inspection or survey of the property would disclose. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5764 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 LEAH L. GLENN (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 $89,202.01 L.L.$.50 Interest PER DIEM OF $10.19 TO SALE DATE 6/1/2011 -- $2,455.00 LATE CHARGES $18.10 PER MONTH TO SALE DATE 6/1/2011 -- $126.70 ESCROW DEFICIT $1,990.45 Atty's Comm % Due Prothy $2.00 Arty Paid $195.44 Other Costs Plaintiff Paid Date: 1/10/11 vid D. Buell, . rothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 rRt,,F COFYFROM REf%0R0 I" TesU^non and t i 'vhereof, I here unto set mY hand This ?i said CAttn 3t Carlisle, Pa 20 Prothonotary .l On March 3, 12 o 1 i lip Shen l i levied upon the defendant's interest in the real property situated in Last Pennsboro I ownship, Cumberland County. PA, Known and numbered as, 402 Beaver Avenue, Enota, more 1-ulty described on Exhibit -A" filed with this writ and by this reference incorporated herew . Date: March 3 ?( s 1.3 1- . Real estate Coordinator- CUMBERLAND LAW JOURNAL Writ No. 2010-5764 Civil ord and any matter which a physical inspection or survey of the property US Bank National Association would disclose. vs. Leah L. Glenn Atty.: Leon P. Haller ALL THAT CERTAIN lot of ground situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylva- nia, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Beaver Avenue, said point be- ing one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardly° direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty (50) feet to a point; thence Northwardly on a line parallel to Beaver Avenue fifty (50) feet to an alley; thence Westwardly along said alley fifty (50) feet to Beaver Avenue; thence South- wardly along the East side of Beaver Avenue, fifty (50) feet to a point, (erroneously omitted from previous deed), the place of BEGINNING. BEING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A.R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. HAVING THEREON ERECTED A DWELLING KNOWN AS 402 BEAVER AVENUE, ENOLA, PA 17025. BEING THE SAME PREMISES WHICH Elwood Long and Phyllis Long, husband and wife, by deed dat- ed 1/14/05 and recorded 1/19/05 in Cumberland County Record Book 267 Page 970, granted and conveyed unto Leah L. Glenn. TO BE SOLD AS THE PROPERTY OF LEAH L. GLENN ON JUDGMENT NO. 10-5764 CIVIL TERM. ASSESSMENT NO. 09-13-1002- 161. UNDER AND SUBJECT, NEVER- THELESS, to conditions, easements, restrictions and matters of prior rec- 28 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 22, April 29, and May 6, 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. r U Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 6 da of May, 2011 X Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 ? The Patriot-News Co. 2020 Technology Pkwy Suite 3U4 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Patr1*0t'WX(W5 Now you know 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 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: 04/22/11 04/29/11 05/06/11 Sworn to and sub"6/Cribed be ore me this 23 day of May, 2011 A. D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Klsner, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 2010-5764 Chdl Term US So* 1 al Assoclatlon Vs Leah L. Glenn Atty Leon R Haller ALL THAT CERTAIN lot of ground situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania,, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Beaver Avenue, said, point being one hundred (100) feet measured along the East side of Beaver Avenue, in a northwardly direction from Shady Lane; thence Eastwardly on a line parallel to Shady Lane fifty 50) feet to a point; thence Northwardly on a line parallel to Beaver Ate; le fifty (50) feet to an alley; thence We.tw ardly along said alley fifty (50) feet to Beaver Avenue; thence Southwark along the East side of Beaver Avenue, fifty (50) feet to a point, (erroneously omitted from previous deed), the place of BEGINNING. BEING the North fifty (50) feet of Lot No. 17 in the Plan of Lots laid out by A.R. Young, as recorded in the Cumberland County Recorder's Office in Plan Book No. 1, Page 92. HAVING THEREON ERECTED A DWELLING KNOWN AS 402 BEAVER AVENUE, ENOLA, PA 17025 BEING THE SAME . PREMISES WHICH Elwood Long and Phyllis Long, husband and wife, by deed dated 1/14/05 and recorded 1/19/05 in Cumberland County Record Book 267 Page 970, granted and conveyed unto Leah L. Glenn. TO BE SOLD AS THE PROPERTY OF LEAH L. GLENN ON JUDGMENT NO. 10- 5764 CIVIL TERM. ASSESSMENT NO. 09-13-1002-161 UNDER AND SUBJECT, NEVERTHELESS, to conditions, easements, restrictions and matters of prior record and any matter which a physical inspection or survey of the property would disclose. 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 Finance A eg ridgy is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 18 day of January, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 5764, at the suit of Finance Agency against Leah L. Glenn is duly recorded as Instrument Number 201119106. IN TESTIMONY WHEREOF, I have hereunto set my hand an eal of said office thisy day of A.D. Ricord r of Deeds d Om be W Cmmj. Oeift Ply My Gomm Bg0XM the Fk9 Mm q d JUL 2044