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HomeMy WebLinkAbout10-6192i tl K,a-?? r KCr 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 VS. Plaintiff LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED Defendants in In 1? 'rp ^ P t,Ml l-0: 35 tU v ?i C. , r;:1 riix,-7RLAND [3 ivJ_`s'f?i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 14- 60?- THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR. CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET s q a 6? a CARLISLE, PA 17013 / 1 717-249-3166 C k * LI) . 1 ,+ U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, 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, LINDA L. MORGAN and DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, are adult individuals whose last known address is 10 ANNETTE DRIVE ENOLA, PA 17025. 3. On or about, July 23, 2007, Robin A. Gerhold executed and delivered a Mortgage Note in the sum of $107,200.00 payable to FIRST HORIZON HOME LOANS a division of FIRST TENNESSEE BANK N.A., 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, Robin A. Gerhold made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on July 25, 2007 in Mortgage Book 2000, Page 4622 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on July 25, 2007 in Book 738, Page 4232. 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: 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. Robin A. Gerhold died Intestate on May 8, 2010. On May 19, 2010, Letters of Administration were granted to her parents, Linda L. Morgan and Donald W. Morgan under Cumberland County File Number 21-10-0527. The heirs of Robin A. Gerhold are the real owners of the property and their interests are represented by the Co-Administrators. 7. The Mortgage is in default due to the fact that the Defendants have failed to pay the installment due on May 01, 2010 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $16.05 per day From 04/01/2010 To '10/01/2010 ( based on contract rate of 5.6000°/x) Late Charges $30.77 From 05/01/2010 to 10/01/2010 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $103,201.36 $2,937.15 $153.85 $843.27 $5,160.07 $112,295.70 **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. 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. seg.) by sending to each Defendant, by certified and regular mail, a copy of the Combined Act 6/91 Notice. True and correct copies of the Combined Act 6/91 Notices dated July 27, 2010 are 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% ($16.05 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: Ai&111- PUACELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 0061207833 NOTE July 23rd, 2007 cAMp HILL, [Date] [City] 204 SOUTH ENOLA DRIVE, ENOLA, PA 17025 [Property Address] PENNSYLVANIA [State] 1. BORROWER'S PROMISE TO PAY 107,200-00 (this amount is called "Principal"), In return for a loan that I have received, I promise to pay U.S. $ plus interest, to the order of the Lender. The Lender is FIRST HORIZON HOME LOANS, A DIVISION OF FIRST TENNESSEE BANK N.A. 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. 1st, 2007 • I will I will make my monthly payment on the 1st day of each month beginning on September 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 August 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." po BOX 8 0 9 I will make my monthly payments at MEMPHIS, TN 38101 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments 615.42 My monthly payment will be in the amount of U.S. $ 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 3200 1/01 Wolters Kluwer Financial Services VMP®-5N 102071.01 ! ( f Page 1 of 3 Initials: ISgs9aj /7n-% ,1 5. LOAN CHARGES est or other If a law, which applies to this loan and o necuon with this loan loan e exceed the permitted lin??tsetheno(a) any1esuchrloan charge loan charges collected or to be collected in already collected from me shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums which exceeded permitted limits will be refund to de w ? mNote e. a refund reduces Principal, the reduction will be treated as principal I owe under this Note or by making a direct payment Y a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments days If the Note Holder has not received the full amount of any monthly payment by the end of 15 15 0 calendar % of after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.0 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 the certain date, the Note Holder may require ?stpay be at least 30 days after the date on which the notice is mailed to me orndelivered interest that I owe on that amount. That date 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. given to me under this Note will 7. GIVING OF NOTICES ven Unless applicable law requires a different method, any notice that or at a different address if I giv a the Note delivering it or by mailing it by first class mail to me at the Property Address 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 3200 1/01 0061207833 initials:- VMP®-5N (0207).01 Page 2 of s 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 UNDERSIGNED. (Seal) ROBIN A. GERHOLD -Borrower _ (Seal) -Borrower _ (Seal) -Borrower -(Seal) -Borrower - (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower [Sign Original Only] 0061207833 VMP®-SN (0207).01 Page 3 of 3 Form 3200 1/01 to -he.oaier of • Housrig Fkmnm Agency Without reoourse First Horizon Home Loans, a division of First Tennessee Bank N.A.. by - - IV j Sri. 1 i i?II T ED VICE PRESIDENT ALL THAT CERTAIN lot or piece of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point fifty-four (54) feet from the southeast comer of Manor Avenue and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R. Rupley, one hundred ffrty (150) feet to First Alley; thence extending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (150) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty-five (25) feet to the place of BEGINNING. FRONTING twenty-five (25) feet on said State Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" according to a Plan of Lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "O", Volume 6, Page 600. UNDER AND SUBJECT to Restrictions and Conditions as now appear of record. C1,11 kA\1911 Date: 7/27/2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE rhis is an official notice that the m t foreclose. Specific e on your home is in default and iformation about the nature of th 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 AFECTA SU DERECHO ADJUNTO ES DE SUMA IMPORTANCIA, PUES 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/ALSV/ I ?X fr1 lent t , ? ,1 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NO.: ROBIN A. GERHOLD 204 S ENOLA DR ENOLA, PA 17025-2807 1595925 CURRENT LENDERISERVICER: Pennsylvania North Front Street Finance Agency 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 NO[ICE UP TO DA O CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE 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 designated Consumer Credit Counseling Agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one race to face rnet;ti??y 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/ , sylvania ' Agencies listed at the end oft this Only submitting ar o' y Counseling on Ito the v Pennsylvania for the Program and they will assist you 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. TMARK DATE OF THIS NOTICE WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE PO AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF STARTING AHFORECLOSURE AGAINST LENDER WILL BE TEMPORARILY PREVENTED FROM START YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN FROM STOARTINGSA FOREC OSURE A LATE APPLICATION WILL NOT PREVENT THE LENDER R 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: 204 S ENOLA DR, ENOLA, PA 17025-2807, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months May, 2010 thru the first pahave accrued in the amount yments, fees and expenses fdue,3 July, 2010 in the amount of $2,409.00 This includes t all that T less THE TOTAL TAL AMOUNT DUE S $2,546.08. 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 WHICH IS $2,546.08 this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b 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/ALSV/ iF YOU DO NOT CURE THE DEFAULT-- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the 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 AYSothellenderlalsonintendsutopnstructtitsfathe total amount ttorneys to start legal due is not made within THIRTY (30) 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 which they exceed $5 Any attorney' costs. If fees will be added to the amount u owe DAYr, a iod mou cure the default within the lende also include other er reasonable 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 sob a in the total amount then past due lus an late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and an other costs connected with the Sheriff's Sale ass ecif ie? defaultlin the manner set forth in this notice will requirements under the mortgage to mortgage. Curing your 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 Sheriff's 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 Sheriff's 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/ALSV/ YOU MAY ALSO HAVE THE RIGHT: OR TO * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE PY DOFF GAS DEBT. BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO * TO HAVE THIS DEFAULT CURED BY ANY THIRD SAME POSITION YAOSUR NBEHALF. O DEFAULT HAD * TO HAVE THE MORTGAGE RESTORED TO HE 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 CI PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 5ELING AGENCIES SERVING YOUR COUNTY CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 ACT691 LR/dtmdocs/ALSV/ Pennsylvania Housing Finance A n NOTICE 7/27/2010 ROBIN A. GERHOLD 10 ANNETTE DR ENOLA, PA 17025 RE: Account #1595925 TO: ROBIN A. GERHOLD 204 S ENOLA DR ENOLA, PA 17025-2807 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY Accounting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 780-3804 (800) 346-3597 FX717) 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. Attachment: Housing Counseling List ACT691 LR/dtmdocs/ALSV/ HUD-APPROVED CREDIT COUNSELING AGENCIES CCCS OF WESTERN PA-HARRISBURG NACA ELAWARE AVE• SUITE 312 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 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 1341 N D PHILADELPHIA, PA. 19125 Phone:888-297-5568 PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-9304663 ACT691 LR/dtmdocs/ALSV/ Date: 7/27/2010 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. S ecific 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 A encies 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/ALSV/ 1401MEOWNER'S NAME(S): PROPERTY ADDRESS LOAN ACCOUNT NO.: TO THE ESTATE OF ROBIN A. GERHOLD 204 S ENOLA DR ENOLA, PA 17025-2807 1595925 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 designated Consumer Credit Counseling Agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). 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 this Notice. Only Consumer Credit Counseling Agencies have applications for the Program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. 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: 204 S ENOLA DR, ENOLA, PA 17025-2807, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months May, 2010 thru the first of July, 2010 in the amount of $2,409.00 plus late charges that have accrued in the amount of $123.08. THE TOTAL AMOUNT DUE IS $2,546.08. 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 $2,546.08 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/ALSV/ IV YOU DO NOT CURE THE DEFAULT-- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the 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 wntmg 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 Sheriff's 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/ALSV/ YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY PHFA CCCS of Western PA 211 North Front Street 2000 Linglestown Road Harrisburg, PA 17110 Harrisburg, PA 17102 717.780.3940 Community Action Commission of Capital Region Maranatha 1514 Deny Street 43 Philadelphia Avenue Harrisburg, PA 17104 Waynesboro, PA 17268 717.232.9757 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 ACT691 LR/dtmdocs/ALSV/ Pennsylvania + Housing Finance Age NOTICE 7/27/2010 TO THE ESTATE OF ROBIN A. GERHOLD 10 ANNETTE DRIVE 204 S. ENOLA DRIVE ENOLA, PA 17025 RE: Account #1595925 TO: TO THE ESTATE OF ROBIN A. GERHOLD 204 S ENOLA DR ENOLA, PA 17025-2807 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY & Loan 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (800) 346-3597 FAX (717) 780-3804 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. Attachment: Housing Counseling List ACT691 LR/dtmdocs/ALSV/ .r HUD-APPROVED CREDIT COUNSELING AGENCIES r('r.S nF WESTERN PA-HARRISBURG NACA 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 HOUSING ALLIANCE OF YORK 34 S. Duke St. York, PA 17401-1106 Phone: 800-8644909 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608-1676 Phone: 717-397-5182 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 Phone:888-297-5568 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/ ' 7360 3-9113 98?F8 9678 S%2 TO: ESTATE OF ROBIN A. GMMLD 204 S_ENOLA DRIVE- ENOLA,PA 17025 i ' SEDER: CONDE ' REFERENCE: 1595925 7?bpi 9bV8 96I-6 S900- TO: ROBIN A GEMoLD 204 _S_. ENOLA DR ENOLA,PA 17025 SENDER: CONDE REFERENCE:1595925 PE7ufw ProcWr SERVICE _ ITam?.aF... Us Paw BNYIm Receipt for Certified Ma11 0000 NU. b,In w Ww 7108 J ?` dd H N ca Lvl ON b4 o 0 o?Hz 0 )O a? ?,w"-mss •, of ?v o m? o r It m "e w c RETURN PAGRPT OFN SGRVICE ?oI FN I Tow Posaw a F..s us Paw s.rvb, Receipt for mil obat 001 *W OR a ?\ _ -- 1-6 w ;a 0.?&m ?o?A %0 m e Nix ? ? r00 G 0 L" ,v ??+ 6 f7 til 0 b In ,T 0 m ? CD ?L O m e a m pq p d y ?"i t•f ILI 02 1A pp d1• 0004399184 JUL27 10 -021A MAH p 2CE V004388184 JUL 27 2010 AIMED FRAM 21PCOf 17101 a 7.71 { 10. tj t4 ? O ? t w y, 7260 3903 qm ?„+ S9 7160 3903 98il8 %7&5n? TO: ESTATE- OF ROBIN A. GERHOLD .10- A+E DRIVE TAO: ROBIN A GERHOLD ENOLA, PA 17025 10 AITTE DR ENOLA,PA 17025 I SENDER: CONDE REFERENCE:1595925 • SENDER: CONDE REFERENCE: 1595925 POTUIN ?t? sEmnm crwMd F.. --? ? 0.._ ?Arn R.o,p F" Rw4l owd Us flew Sww" Nos1 a , ... RemIpt for x. to a O y n O '? c o a N ? ' 3 cn ? 1A ? ? a tj o n? j m I j ?m Ln HH 5 L'F1 x ? K c In C?1 h? 1+ ? C1 L yr D f ( Rap'. *aowew K 02 1A y _ 0004399184 JUL 27 2010 UAKED FROM ZPCOM 17101 t_.. i S F+ N po ?0°m ? H tp .Z Ov+?G i !7 02 1A $ 0'1.150 =. , s 0004399184 JUL 27 2010 DFJIOiMZIPGOM 17101 lE r`.. 2 CCC=CCC s y a g .ti rl ?o !a •o ti z 0 „?a r 0 I I ry ? ?4 . AY y :r; 1 F. _ o? 0 F i- ? r r r m I N OAN C r- 00 zE Oo0 c c u c c u c L t 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 A11LL1) PENNSYLVANIA HOUSINGS ?, NATIONAL -q- Date: SERVICING AGENT 0 ASSOCIATION AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCi AGENCY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank National Association vs. Donald W. Morgan (et al.) :~ .., ~ ~, . , ~~\A1LL1i c~l ~. dla ,r.r~~~ .. ! ~ _ ..1 ~ e'~ *- !D v i1- ..-~ Case Number 2010-6192 SHERIFF'S RETURN OF SERVICE 10/05/2010 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: Donald W. Morgan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Donald W. Morgan. Request for service at 204 S. Enola Drive, Enola, PA 17025 is vacant. The Enola Postmaster has advised, Donald W. Morgan's mail is still being delivered to 204 S. Enola Drive Enola, PA 17025. 10/05/2010 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: Linda L. Morgan, 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 Linda L. Morgan. Request for service at 204 S. Enola Drive, Enola, PA 17025 is vacant. The Enola Postmaster has advised, Linda L. Morgan's mail is still being delivered to 204 S. Enola Drive, Enola. PA 17025. 10/05/2010 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 204 S. Enola Drive, 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 204 S. Enola Drive, Enola PA 17025 is vacant. SHERIFF COST: $88.50 October 05, 2010 SO ANSWERS, RONP15' R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~IL~f~-OF~'I~~ Sheriff "~' T'~#~ P~OTNC'~~T,~R~' ~p~~~t~ ilk ~Itnii~Crr~~b Jody S Smith G :~ ~~ ~ Q ~~~ ~ ~ ~~'~* Chief Deputy . ~ - x `~ Richard W Stewart ~" ''` ~alJP~f3~»ERLAI~D C~UPd~"` SOiICItOr #~F~iWHOFTHE~!+ERiPt^-~' Et~t~S~'~VA~~Ir4 US Bank National Association Case Number vs. 2010-6192 Donald W. Morgan (et al.) SHERIFF'S RETURW OF SERVICE AMENDED 10/05/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 204 S. Enola Drive, 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 204 S. Enola Drive, Enola PA 17025 is vacant. 10!11!2010 06:51 PM -Amanda Cobaugh, Deputy Sheriff, who being duly swom according to law, states that on October 11, 2010 at 1851 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Linda L. Morgan, by making known unto Donald Morgan, Husband of defendant at 175 N. Enola Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true a d correct copy of the same. A ANDA COBAUGH, DEPUTY 10/11/2010 06:51 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2010 at 1851 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donald W. Morgan, by making known unto himself personally, at 10 Annette Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. AMANDA COBAUGH, DEPUTY SHERIFF COST: $88.50 October 12, 2010 SO ANSWERS, r RON R ANDERSON, SHERIFF (c) GountySulte Shenff, Teleosoft, Inc. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: ?D i - 7 : - c. .?.» x.43 ....... C'3 J ? u? Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED 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 $16.05 From 04/01/2010 To 10/01/2010 $103,201.36 $2,937.15 Late Charges ($30.77 per month to 10/01/2010) Escrow Deficit 5% Attorney's Commission TOTAL $153.85 $843.27 $5,160.07 $112,295.70 "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. PG/ PURCELL, KRUG & HAL I/ By Leon P. Haller PA I.D. # 15700 1719 North Front Street a'S?7S? Harrisburg, PA 17102 (717) 234-4178 1. U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on January 13, 20111 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 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. LINDA L. MORGAN and DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN GERHOLD, DECEASED Defendants DATE OF THIS NOTICE: January 13, 2011 TO: LINDA L. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 DONALD W. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6192 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 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 & HAL By LEON P. HALLE , Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before m hisd3day of 20& f;ftinA6rdW?AL?kI ®? eS NONIA TA PJIARYLr?N.?, !I- F6FIRETTI, Lowe; NGtaPy Pubilc ? ?? -,„ - Dauphin 00unty a-- y ^ m Puxian misstp'n Expires Aug 8, 2014 LEON P. ALLER, ESQUIRE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-6192 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 LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED (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 $112,295.70 L.L.$.50 Interest PER DIEM OF $16.05 TO SALE DATE 6/1/11 -- $3,852.00 Atty's Comm % Due Prothy $2.00 Atty Paid $ 3 c 11..3''0 Other Costs LATE CHARGES $30.77 PER MONTH TO SALE DATE 6/1/11 --$215.39 ESCROW DEFICIT $2,010.00 Plaintiff Paid Date: 2/25/11 David D. Bu 11, Prothonotary (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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW AT NO. 10-6192 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, DEFENDANT(S) Total Judgment Amount $112,295.70 Interest $3,852.00 Per diem of $16.05 to sale date 6/1/2011 Late Charges $215.39 $30.77 per month to sale date 6/1/2011 Escrow Deficit $2,010.00 TOTAL WRIT $118,373.09 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, June 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. - = -+ co - Date: February 23, 2011 ) ^ co -3 -r, r 1. Attorney for Plaintiff 1719 North Front Street Leon ?!_Haller Harrisburg, PA 17102 PA I.D. #15700 ca c ' :, (717) 234-4178 , m 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 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Date: Pd-111tl 6 41?11 ?r A?8 - sc; CBS ¢,9d GU ri l tl a a,5c q'I ?3 cl 9'.. SiT mom- 1 PROT ONO4RY/ ERK CI VIL DIVISION BY DEPUTY 4 a - ( lUSi??ES?, so ?? LC ALL THAT CERTAIN lot or piece of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point fifty-four (54) feet from the southeast corner of Manor Avenue and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R. Rupley, one hundred fifty (150) feet to First Alley; thence extending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (150) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty-five (25) feet to the place of BEGINNING. FRONTING twenty-five (25) feet on said State Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" according to Plan of Lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "O", Volume 6, Page 600. HAVING THEREON ERECTED A DWELLING KNOWN AS 204 SOUTH ENOLA DRIVE, ENOLA, PA 17025 PARCEL NO. 09-15-1297-218. UNDER AND SUBJECT to Restrictions and Conditions as now appear of record. BEING THE SAME PREMISES WHICH Trevor S. Solt and Jody M. Leggore-Solt by deed dated 7/23/07 and recorded 7/25/07 in Cumberland County Record Book 281, Page 612, granted and conveyed unto Robin A. Gerhold. The said Robin A. Gerhold died intestate on 5/8/2010. Letters of Administration were granted to her parents, Linda L. Morgan and Donald W. Morgan under Cumberland County File No. 21-10- 0527. The heirs of Robin A. Gerhold are the real owners of the property and their interests are represented by the Administrators. TO BE SOLD AS THE PROPERTY OF LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED ON JUDGMENT NO. 10-6192 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 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 204 SOUTH ENOLA DRIVE ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): LINDA L. MORGAN -- ' 10 ANNETTE DRIVE ENOLA, PA 17025 1 -u cn rz DONALD W. MORGAN 10 ANNETTE DRIVE C7 ENOLA, PA 17025 -'p ESTATE OF ROBIN A. GERHOLD 204 SOUTH ENOLA DRIVE 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 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 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 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Murrel R. Walters, III, Esquire 54 East Main Street 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 ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. a ler PA 1. D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 23, 2011 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, P AINTIFF . VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL.ACTION LAW NO. 10-6192 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: 7: That the Sheriffs Sale of Real Property (real estate) will be held: :-' r' DATE: Wednesday, June 01, 2011 v i f t`; 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: 204 SOUTH ENOLA DRIVE 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. 10-6192 JUDGMENT AMOUNT $112,295.70 THE NAMES OF THE aWNERS OR REPUTED OWNERS of this property is: LINDA L. MORGAN and DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED 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 WOULD 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 w 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 or piece of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point fifty-four (54) feet from the southeast corner of Manor Avenue and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R. Rupley, one hundred fifty (150) feet to First Alley; thence extending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (150) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty-five (25) feet to the place of BEGINNING. FRONTING twenty-five (25) feet on said State Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" according to Plan of Lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "O", Volume 6, Page 600. HAVING THEREON ERECTED A DWELLING KNOWN AS 204 SOUTH ENOLA DRIVE, ENOLA, PA 17025 PARCEL NO. 09-15-1297-218. UNDER AND SUBJECT to Restrictions and Conditions as now appear of record. BEING THE SAME PREMISES WHICH Trevor S. Solt and Jody M. Leggore-Solt by deed dated 7/23/07 and recorded 7/25/07 in Cumberland County Record Book 281, Page 612, granted and conveyed unto Robin A. Gerhold. The said Robin A. Gerhold died intestate on 5/8/2010. Letters of Administration were granted to her parents, Linda L. Morgan and Donald W. Morgan under Cumberland County File No. 21-10- 0527. The heirs of Robin A. Gerhold are the real owners of the property and their interests are represented by the Administrators. TO BE SOLD AS THE PROPERTY OF LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED ON JUDGMENT NO. 10-6192 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A GERHOLD, DECEASED, DEFENDANT(S) . "' -M ... > ;. j f..-.?. IN THE COURT OF COMMON PL ? CUMBERLAND COUNTY, PENN AID CIVIL ACTION LAW NO. 10-6192 T? - - g CO IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on '5)11 l as 1 1 , 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: LINDA L. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 DONALD W. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 ESTATE OF ROBIN A. GERHOLD 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Murrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, PA 17055 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINKA LISA RYNARD LINDA L. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 DONALD W. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 y 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 2344178 FAX (717) 234-1206 ESTATE OF ROBIN A. GERHOLD 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Murrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, PA 17055 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 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 be divested by the sale and that you have an opportunity to protect your interest, if any, by being no ' ed of said Sheriffs Sale. By: v faller PA I.D.15700 for Plaintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 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: 204 SOUTH ENOLA DRIVE 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. 10-6192 JUDGMENT AMOUNT $112,295.70 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: LINDA L. MORGAN and DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED 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 7160 3901 4644 3035 S6S6 7160 3901 9644 3035 5644 TO: ESTATE OF ROBIN A. GERHOLD TO: DONALD W. MORGAN 204 SOUTH ENOLA DRIVE j 10 ANNETTE DRIVE ENOLA, PA 17025 ENOLA, PA 17025 SENDER;:,HFA/GERHOLD SENDERpHFA/GERHOLD REFERENCEkOS 06/01/11 REFERENCEIUOs 06/01/11 PS Form 3800 January 2005 P3 F_qrm 3800 January 2005 RETURN Postage RECEIPT RETURN Poste 98 SERVICE Certified Fee Return Receipt Fee RECEIPT Certified Fee SERVICE Restricted Delive Return Receipt Fee 230 Total Postage & Fees 4.50 Restricted Delivery a ISO i 0-24-- Total Postage & Fees i US Postal Service POSTMARK OR DATE ]a US Postal Service POSTMARK OR DATE Receipt for Receipt for Certified Mail t. Certified Mail Duo InsuUse for r Provided a No Insurance Coverage Provided w ` Do Not Use for Irv- grnatlonN Wary -- •_._? --- ---------•--•-- --•- 7160 3901 9649 3035 S632 - Y .... TO: LINDA L. MORGAN 10 ANNETTE DRIVE i ENOLA, PA 17025 SENDERpHFA/GERHOLD REFEREWC§40S 06/01/11 PS Form 3800 Janua 2005 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service POSTMARK OR DATE Receipt for Certified Mail No' I..noo Covarapa Provided Do Not Lin for InlarrWiorral MW PENNSYLVANIA HOUSING FINANCE AGENCY v. ROBIN A. GERHOLD, DECEASED Cumberland County Sale 6/1/2011 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: LINDA L. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 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: DONALD W. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 Postage: 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 One piece of ordinary mail addressed to: ESTATE OF ROBIN A. GERHOLD 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Postage: Postmark: 'e o WTNEY BOV17F5 02 1M $ 01.15° 0004284324 W R11 2011 MAILED FROM ZIP CODE 1 710 2 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: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Postage: 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 One piece of ordinary mail addressed to: Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Postage: 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 One piece of ordinary mail addressed to: Murrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, PA 17055 Postage: Postmark: PAS P%' mNEY BOWES 02 11V $ 01.150 0004284324 MAR11 2011 MAILED FROM ZIP CODE 17102 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 ?P"es Po3T? 3 , W ® . waWWWW PITNEY 605M:S 02 I NI $ 02.30° i 000,4284324 MAR11 2011 MAILED FROM ZIP CODE 1 710 2 ti ? l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ai!(a?,r?FRj? ?F ?U ?y. r! iltit.) dr7iNoT?p f1;; Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank Trust National Association vs. Donald W. Morgan (et al.) 12 ?DER± Al ,.,''i;,`di r. kt %1 Case Number 2010-6192 SHERIFF'S RETURN OF SERVICE 03/15/2011 04:41 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 204 South Enola Drive, Enola, PA 17025, Cumberland County. 03/21/2011 07:31 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 DONALD MORGAN JR. (SON), who accepted as "Adult Person in Charge" for Linda L. Morgan at 10 Annette Drive. East Pennsboro Township, Enola, PA 17025, Cumberland County. 03/21/2011 07:31 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 DONALD MORGAN JR. (SON), who accepted as "Adult Person in Charge" for Donald W. Morgan at 10 Annette Drive, 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: $1,066.74 SO ANSWERS, July 11 2011 RONW R ANDERSON, SHERIFF i COPY 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 `J S. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A GERHOLD, DECEASED, DEFENDANT(S) NO. 10-6192 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 204 SOUTH ENOLA DRIVE ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): LINDA L. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 DONALD W. MORGAN 10 ANNETTE DRIVE ENOLA, PA 17025 ESTATE OF ROBIN A. GERHOLD 204 SOUTH ENOLA DRIVE 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 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg. PA 17105-8486 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 204 SOUTH ENOLA DRIVE ENOLA, PA 17025 Murrel R. Walters. III, Esquire 54 East Main Street 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 ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haler PA I.D. 415700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:February 23. 2011 U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF vs. LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A GERHOLD, DECEASED, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 10-6192 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 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) ?'HE LOCATION of your property to be sold is: 204 SOUTH ENOLA DRIVE 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. 10-6192 JUDGMENT AMOUNT $112,295.70 THE, NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: LINDA L. MORGAN and DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED 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 Countv 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 s 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 or piece of land situate in East Pennsboro Township, Cumberland County; Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point fifty-four (54) feet from the southeast cornea- of Manor Avenue and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R. Rupley, one hundred fifty (150) feet to First Alley; thence extending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (150) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty-five (25) feet to the place of BEGFN-N1 NG. FRONTING twenty-five (25) feet on said State Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" according to Plan of Lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "O", Volume 6, Page 600. HAVING THEREON ERECTED A DWELLING KNOWN AS 204 SOUTH ENOLA DRIVE, ENOLA, PA 17025 PARCEL NO. 09-15-1297-218. UNDER. AND SUBJECT to Restrictions and Conditions as now appear of record. BEING THE SAME PREMISES WHICH Trevor S. Solt and Jody M. Leggore-Solt by deed dated 7/23/07 and recorded 7/25/07 in Cumberland County Record Book 281, Page 612, granted and conveyed unto Robin A. Gerhold. The said Robin A. Gerhold died intestate on 5/8/2010. Letters of Administration were granted to her parents, Linda L. Morgan and Donald W. Morgan under Cumberland County File No. 21-10- 0527. The heirs of Robin A. Gerhold are the real owners of the property and their interests are represented by the Administrators. TO BE SOLD AS THE PROPERTY OF LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED ON JUDGMENT NO. 10-6192 SHERIFF: I am submitting documentation necessary to schedule a Sheriffs sale of real estate. If you require anything further or have any questions as to content or format, please contact the undersigned. Thank you. Maryland Ferretti Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 PHONE: (717) 234-4178 Inquiries relating to service should be directed to Mindy Horley. Inquiries relating to the actual sale should be directed to Sharon Dunn. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-6192 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 LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERHOLD, DECEASED (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 5112,295.70 L.L.$.50 Interest PER DIEM OF $16.05 TO SALE DATE 6/1/11 -- $3,852.00 Atty's Comm % Atty Paid S 3c9`? Due Prothy $2.00 Other Costs LATE CHARGES $30.77 PER MONTH TO SALE DATE 6A/11 --S215.39 ESCROW DEFICIT $2,010.00 Plaintiff Paid Date: 2/25/11 (Seal) Buell, Prothonotary By: I 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 TRUE COPY FROM RECORD In Testirr-tony whereof, I here unto set my hand and the of ss Carlisle, Pa.. This ?„nIde?? 030t ; d ?L Prothono inn N/larch 3, )()1 i the Sheriff levied upon the defendant's interest in the real property situated iri East Penns boro to wnsliip, Cumberland County, PA, Known and numbered as, 204 South Enola Drive. Enola, more hilly described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: March ;'. 2011 s Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-6192 Civil US Bank National Association vs. Donald W. Morgan, Administrator of the Estate of Robin A. Gerhold, Deceased Linda L. Morgan, Administrator of the Estate of Robin A. Gerhold, Deceased Atty.: Leon P. Haller ALL THAT CERTAIN lot or piece of land situate in East Pennsboro Town- ship, Cumberland County, Penn- sylvania, being more particularly bounded and described as follows: BEGINNING at a point fifty-four (54) feet from the southeast corner of Manor Avenue and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R. Rupley, one hundred fifty (150) feet to First Alley; thence extending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (150) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty-five (25) feet to the place of BEGINNING. FRONTING twenty-five (25) feet on said State Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" ac- cording to Plan of Lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "O", Volume 6, Page 600. HAVING THEREON ERECTED A DWELLING KNOWN AS 204 SOUTH ENOLA DRIVE, ENOLA, PA 17025. PARCEL NO. 09-15-1297-218. UNDER AND SUBJECT to Restric- tions and Conditions as now appear of record. BEING THE SAME PREMISES WHICH Trevor S. Solt and Jody M. Leggore-Solt by deed dated 7/23/07 and recorded 7/25/07 in Cumber- land County Record Book 281, Page 612, granted and conveyed unto Robin A. Gerhold. The said Robin A. Gerhold died intestate on 5/8/2010. Letters of Administration were grant- ed to her parents, Linda L. Morgan and Donald W. Morgan under Cum- berland County File No. 21-10-0527. The heirs of Robin A. Gerhold are the real owners of the property and their interests are represented by the Administrators. TO BE SOLD AS THE PROPERTY OF LINDA L. MORGAN AND DONALD W. MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GER- HOLD, DECEASED ON JUDGMENT NO. 10-6192. 56 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. -LJ'sa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this da of Ma 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE: BOROUGH, CUMBERLAND COUNTY ",yTCommission Expires l+ar?S, L0?4 The Patriot-News Co. 2020 Technology Pkwy Suite 300 ' Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ?NOH' 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: 04122/11 04/29/11 05/06/11 Sworn to and subscribed ore me this 23 d?y",of May, 2011 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial 501 Sherrie L. Klsner, Notary Public tower Paxton Twp., Dauphin County My commission cxplret Nov. 76 201 t _ Member, Pennsvtvania A§Wd ?r Pies 2010.6192 civil Term us Bank National Association Vs Donald W. Morgan, Administrator of the Estate of Robin A. Gerhold, Deceased Linda L. Morgan, Administrator of the Estate of Robin A. Gerhold, Deceased AtW Leon R, Bailer ALL, THAT CERTAIN lot or piece of land situate in East Pennsbom 'Township, Cumberland County, Pennsylvania, being more particularly bounded and'` described as follows: BEGINNING at a point fifty-four (54) fee'. from the southeast comer of Manor AVenU and the State Road; thence extending eastwardly along Lot No. 10 on Connected Plan of Lots of Arthur R Rupley, one hundred fifty (150) feetto First Alley; thence ertending in a southerly direction along the western side line of First Alley, twenty-five (25) feet to Lot No. 8 on said Plan; thence extending in a westerly direction along line of Lot No. 8, one hundred fifty (. ) feet to the State Road; thence extending in a northerly direction along the eastern side line of said State Road, twenty five (25) feet to the place of BEGINNING. FRONTING twenty-five (25) feet on said state Road and extending in depth of even width one hundred fifty (150) feet to First Alley. BEING Lot No. 9, Block "B" according to Plan of lots laid out and adopted by Arthur R. Rupley, said Plan being recorded in Cumberland County in Record Book "0" Volume 6, Page 600. HAVING THEREON ERECTED A. DWELLING KNOWN AS 204 SOUTH ENOLA DRIVE, ENO LA, 15?A 172025 PARCEL NO. UNDER AND SUBJECT to Restrictions and Conditions as now appear of record. BEING THE SAME PREMISES WHICH Trevor S. Solt and Jody M. Leggore- Solt by deed dated 7123107 and recorded 7125107 in Cumberland County Record Book 281, Page 612, granted and conveved unto Robin A. Gerhold. The said Robin A. Gerhold died intestate on 51812010. Letters of Administration were granted to her parents, Linda L. Morgan and Donald W. Morgan under Cumberland County File No. 21-10-0527. The heirs of Robin A. Gerhold are and their the i real eOwnrs of the property ol represented by the Administrators TO BE SOLD AS THE PROPERTY Ol LINDA L. MORGAN AND DONALD W MORGAN, ADMINISTRATORS OF THE ESTATE OF ROBIN A. GERIIOLD DECEASED ON JUDGMENT NO. 10 6192 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 ncy 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 25 day of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6192, at the suit of Pennsylvania Housing Finance Agency against Estate of Robin A. Gerhold is duly recorded as Instrument Number 201119323. IN TESTIMONY WHEREOF, I have hereunto set my hand aneal of said office this _ day of A.D. r/ ,9y 6;"r- i Expires me Fit Mbndepi of Jen. 2014