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Home My WebLink About11-0590Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Andrew P. Sonin, Esquire ID. Nos. 04267 / 85165 / 204500 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 FILED-OFFICE brti Y ? pplHONOTARY Att e s or amtiff 2011 JAIR 20 PH 2.25 C'UM?ENNSYLVAN ATY CitiMortgage, Inc., PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, V. Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025, DEFENDANT PENNSYLVANIA DOCKET NO: ,<;C<<- S46 (? v i (Ter KA CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND 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 this 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 claimed in the complaint or for any other claim of 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, 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue ?p a1l? Carlisle, PA 17013 ?q Ob 717-249-3166 and 800-990-9108 a pt -9 1 `{ 1 Ce*'aS3avl AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 2 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Andrew P. Sonin, Esquire ID. Nos. 04267 / 85165 / 204500 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc., PLAINTIFF, V. Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, CitiMortgage, Inc., by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 1. Plaintiff, CitiMortgage, Inc., is a corporation with its principal place of business at 1000 Technology Drive, O'Fallon, MO 63368-2240. 2. Defendant, Daniel J. Shank, is the real owner, mortgagor, and grantee in the last Deed of record to the real property located at 2380 Lambs Gap Road, Enola, PA 17025 (hereinafter referred to as "Premises"). Defendant resides at/in the Premises. 3. On 05/16/2003, Defendant made, executed, and delivered a Mortgage for the benefit of CitiFinancial Mortgage Consumer Discount Company (hereinafter referred to as "Originating Lender") as security for Defendant's payment and other obligations under a promissory note executed by Defendant on the same date in consideration of a loan made to Defendant by the Originating Lender. Said Mortgage is recorded in the Office of the 3 Recorder in and for Cumberland County, in Mortgage Book Vol. 1813, Page 4109, and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The Originating Lender assigned the aforesaid Mortgage, promissory note, and indebtedness to Plaintiff by virtue of an Assignment of Mortgage. 5. Plaintiff is, therefore, the present owner of the aforesaid Mortgage and holder of the aforesaid promissory note. 6. The Premises subject to the aforesaid Mortgage is described in Exhibit "A" attached hereto and made a part hereof. The address of the Premises is 2380 Lambs Gap Road, Enola, PA 17025. 7. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid promissory note and Mortgage have not been made from 07/10/2010 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 8. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendant shall be liable for, inter alia, Plaintiffs costs and attorneys' fees. 9. The following amounts are due as of 07-01 - 1 Wanuary 4, 2011: Principal $ 48,392.98 Accrued Interest through November 27, 2010 $ 1,834.54 Late Charges $ 169.60 Corporate Advances $ 77.50 Escrow Advances $ 91.37 Attorneys' Fees (5% of Principal) $ 2,419.65 Total $52,985.64 plus additional pre-judgment and post judgment interest at the rate of $10.30 or at 4 the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage and promissory note. 10. If the Mortgage is reinstated prior to a sheriffs sale, the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5%) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriffs sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. 11. Plaintiff is not seeking a judgment on personal liability (or an in personam judgment) against Defendant(s) in this action but reserves the right to bring a separate action to establish that right, if such right exists. If Defendant(s) received a discharge of personal liability in a bankruptcy proceeding, this action is, in no way, an attempt to re-establish the personal liability that was discharged in bankruptcy, but only to foreclosure the Mortgage and sell the Premises pursuant to Pennsylvania law. 12. Plaintiff has demanded the total amount due from Defendant, but Defendant has failed and/or refused to pay the same. 13. Notice of Intention to Foreclose pursuant to 41 P.S. § 403 and Notice pursuant to the Homeowner's Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et sea. (hereinafter collectively referred to as "Act 91 Notice") was mailed to Defendant via simultaneous regular mail postage prepaid and certified mail return receipt requested on 9/10/2010. A true and correct copy of the Act 91 Notice is attached hereto as Exhibit "B" and made a part hereof. 5 WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendant, Daniel J. Shank, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 9, namely $52,985.64, plus additional pre judgment and post judgment interest at the rate of $10.30 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage and promissory note, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & ASSOCIATES, LLC B y: Ric M. Squire, Esq. (PA I.D.# 04267) ffroyFreedman, Esq. (PA I.D.# 85165) Andrew P. Sonin, Esq. (PA I.D.# 204500) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@sguirelaw.com tfreedman@ squirelaw.com asonin@sguirelaw.com Attorneys for Plaintiff Date: 1 r 11 /!J UNLESS YOU NOTIFY US IN WRITING WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 6 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Andrew P. Sonin, Esquire ID. Nos. 04267 / 85165 / 204500 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc., V. Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025, PLAINTIFF, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION Maishea M. Burrow, hereby states that s/he is an employee, agent, and/or representative of Plaintiff, a corporation unless designated otherwise; that s/he is authorized to make this Verification; that s/he has personal knowledge of the facts averred in the foregoing Complaint; and that the statements made in the foregoing Complaint are true and correct to the best of her/his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1/4/2011 Mais'hea M. Burrow of ii qA Document Control Officer EXHIBIT "A" LEGAL DESCRIPTION Conestoga Title Insurance Company Commitment Number: 2003050074* SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: Hampden Township, Cumberland County ALL THAT CERTAIN lot or tract of land situate along the east side of the Lamb's Gap Road in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin in the center line of the Lamb's Gap Road at the northern line of land now or late of C.W. Emey being 4752 feet in a northerly direction by said center line from the Wertzville Road; thence along the center line of said road North 4 degrees 30 minutes West 100 feet to an Iron pin; thence along land now or late of Robert T. Stoner and Charlotte J. Stoner, his wife, North 89 degrees East 191 feet to a post; thence along land of same South 4 degrees 30 minutes East 100 feet to a post; thence along land now or late of C.W. Emey South 89 degrees West 191 feet to an iron pin in the center line of the Lamb's Gap Road, the place of BEGINNING. CONTAINING .43 acres, more or less, and being improved with a one-story frame dwelling. UNDER AND SUBJECT to rights-of-way of highways, streets and alleyways abutting or adjoining the premises; easements and rights-of-way of record and apparent upon the premises; and restrictions and reservations of prior record. Parcel #10-12-2983-011 I Certify tbis to be recoxded In Cumberland County PA, Gv?rf. Recorder of Deeds ALTA Commitment schedule c (2003050074.PFD12003050074/13) BK 1813PG4125 EXHIBIT "B" /1 CitiMortgage ati www.citimortgage.com 7107 8381 6540 8910 1692 -?' 09/10/10 52431 000978 DANIEL SHANK 2380 LAMBS GAP RD ENOLA PA 17025-1125 RE: CitiMortgage Loan #n: 5000998158 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE N m This is an official notice that default, and the lender intends about the nature of the default The HOMEOWNER'S EMERGENCY MORTG, able to help to save your home. works. the mortgage on your home is in to foreclose. Specific information is provided in the attached pages. NGE ASSISTANCE PROGRAM (HEMAP) may be This Notice explains how the program To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES OE SOMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRAOUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMEftO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Q 02010 CitiMortgage, Inc CliMortgage, Inc. does business as Citicorp Mortgage in NM. CitiMortgage, Inc, is an equal housing lender. Citi. Arc Oesi R and Citi and Arc Design are registered service marks of Citigroup Inc •Ca#s are randomly monitored and tecorded for quality assuratrce. CitlMortgage is a debt collector and any in(omnation obtained wiA be used (or that purpose. CitlMortgage citi www.citimortgage.com Page Two 09/10/10 5000998158 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: Daniel Shank 2380 Lambs Gap Rd Enola,PA 17025-0000 LOAN ACCT. NO.: 5000998158 ORIGINAL LENDER: C1tiflnancial Mort Cons Disc Co CURRENT LENDER/SERVICER: CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM sN l+l m 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 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: s IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, s IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND s 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 THIRTY-THREE (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. l=f ®2010 CitiMortgage, Inc. RiMortgage, Inc. does business as Citicorp Mortgage in NM: CitlMortgage, Inc is an equal housing tender. Cild, Arc Design, and Citi and Arc Design are registered service man marks of Citigroup Inc, 'Calls are randomly monitored and recorded for quality assurance. CitlMortgage is a debt collector and any information obtained will be used for that purpose. CitiMortgage Page Tnree 09/10/10 5000998158 cA$ l l www.citimortgage.com 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 1s located are set forth at the and 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 1s 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 frorh the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling 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 within thirty (30) days of your face-to-face meeting with the counseling agency. w 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 proceeding 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 DEFT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Q 02010 CitiMortgage, Inc CitiMortgage, Inc. does business as Citicorp Mortgage in NM. Cit!Mortga}e, Inc. is an equal housing lender. Citi, Arc Design, and Citi and Arc Design are registered service am marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any information obtained will be used for that purpose. CitiMortgage Page Four 09/10/10 5000998158 4 "'? ati www.citimortgage.com 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: 2380 Lambs Gap Rd., Enola, PA 17025-0000 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 07/01/10 thru 09/01/10 3 0 5823.33/month 2 p $33.92/late charge/month $2,537.83 Previous late Charge(s) $0.00 Delinquency Expenses(s) $0.00 TOTAL AMOUNT PAST DUE: $2.537.83 m 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 $2,537.83. PLUS ANY MORTGAGE PAYMENTS, LATE CHARGES AND DELINQUENCY EXPENSES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CitiMortgage, Inc. P.O. Box 689196 Des Moines. IA 50368-9196 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTYA 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 02010 COortgage, Inc ChiMortgage, Inc. dDes business as Citicorp Mortgage in NM. CitiMortgage. Inc is an equal housing lender. Citi, Arc Design, and Citi and Art Design are registered service marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. CitiMortgage is a debt collector and any information obtained will be used for that purpose. ? \ CitiMort9a9e ati www.citimortgage.com Page Five 09/10/10 5000998158 against you, you will have to pay all reasonable attorney's 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 to writing by the N 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. 'O 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 six (6) 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: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Email Address: CitlMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 1-800-723-7906 1-636-261-7716 Adam Saab ryan.olllerlciti.com Q 02010 CitiMortgag% Inc. Citiiklortgage, Inc, does business as Citicorp Mortgage in NM. CitiMortgage, Inc, is an equal housing lender. Citi, Arc Design, and Citi and Arc Design are registered service to- marks of CifigMUP Inc 'Calls are randomly monitored and recorded for quality assurance. CitiMotgage is a debt collector and any information obtained will be used for that purpose. CitiMortgage Page Six 09/10/10 5000998158 /^1 at! www.citimortgage.com 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-Please refer to your original loan documents to determine whether or not 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. You may also call the 1-800 Number above to find out whether your loan 1s assumable. YOU MAY ALSO HAVE THE RIGHT: 0 s_N m * 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. Enclosure: Consumer Credit Counseling Agencies, including those for your county. 100910D0005945 19 @W0 CitiMortgage, Inc CitiMortgage. Inc. does business as Citicorp Mortgage in NM. Citillortgage, Inc is an equal housing lender. Cdi, Arc Design, and Cki and Arc Design are registered smite marks of Citigroup Inc. 'Calls are randomly monitored and recorded for quality assurance. Gtlilortgage is a debt collector and any information obtained wiN be used for that purpose, Action-Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh, PA 15219 800.792.28011412.281.2102 www.actiorhousirig.org 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence - Philadelphia 1628 JFK Blvd-8 Penn Ctr, STE 2210 Philadelphia, PA 19103 215.218.4342 www.afinow.org 'Philadelphia Advocates for Financial Independence - Ridley Park 202 E Hinkley Ave Ridley Park, PA 19078 215.218.4342 www.afinow.org 'Chester, Delaware Alliance for Building Communities 830 Hamilton Mall Allentown, PA 18101 610.439.7007 'Lehigh, Northampton, Schuylkill American Credit Alliance, Inc. 2 S Delmorr Ave; STE 501 Morrisville, PA 19067 800.501.7526/215.295.7195 www.501plan.com 'Bucks, Montgomery Armstrong County Community Action Agency 705 Butler Rd Kittanning, PA 16201 724.548.3408 www.armabwgcap.com 'Armstrong Asociacibn Puertorriquefbs on Marche, Inc. (APM) 600 W Diamond St Philadelphia, PA 19122 7215.235.6070 www.apmphila.orgm 'Delaware, Philadelphia BASE, Incorporated 447 S. Prince St Lancaster, PA 17603 717.392.5467 www.bassinc.org 'Lancaster Bayfront Neighborhood Action Team Organization, Inc. 312 Chestnut St Erie, PA 16507 814.459.2761 'Erie Blair County Community Action Agency 2100 6th Ave; STE 102 Altoona, PA 16602 800.238.97631814.946.3651 'Blair Barks Community Action Program, Inc. 247 N Fifth St Reading, PA 19601 610.375.7866 www.rack.odu/SocialService/bO9O.aspx 'Barks, Schuylkill, Montgomery * Indicates Counties Serviced Bucks County Housing Group CCCS of Delaware Valley - 2324 Second St Pike; STE 17 Philadelphia Wrlghtstown, PA 18940 4400 North Reese St 866.866.0280 / 215.598.3566 Philadelphia, PA 19140 www.bctg.org 800.989.2227 / 215.563.5665 'Bucks www.cocsdv.org 'Bucks, Chester, Delaware, Building United of Southwestern PA Montgomery, Philadelphia 801 N Homewood Ave; STE 201 Pittsburgh, PA 15208 412.281.4422 'Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland Campbell Street Family Youth and Community Association 600 Campbell St Williamsport, PA 17701 570.322.6515 www.campbolistreetcenter.org 'Lycoming Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 'Delaware, Montgomery, Philadelphia Cambria Community Development Corporation 401 Candlelight Dr Ebensburg, PA 15931 814.472.6711 'Blair, Cambria, Delaware, Indiana, Somerset CCCS of Delaware Valley - Bristol 1230 Veterans Hwy; STE F1 Bristol, PA 19007 800.989.2227 / 215.563.5665 'Bucks CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 800.989.2227/215.563.5665 www.cccsdv.org 'Chester, Philadelphia CCCS of Delaware Valley - Chinatown 901-A Wood St Philadelphia, PA 19107 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - Coatesville 1001 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 800.989.2227/215.563.5665 www.o=sdv.org 'Chester, Delaware CCCS of Delaware Valley - Jenkintown 261 Old York Rd; The Pavillion #401 Jenkintown, PA 19046 800.989.2227/215.563.5665 www.ccmdv.org 'Montgomery CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 800.989.2227/215.563.5665 www.cocsdv.org 'Delaware CCCS of Delaware Valley - Philadelphia 7340 Jackson St Philadelphia, PA 19136 800.989.2227/215.563.5665 www.cccsdv.org 'Philadelphia CCCS of Delaware Valley - West Chester 770 E Market St; STE 190 West Chester, PA 19382 800.989.2227/215.563.5665 www.cocsdv.org 'Chester. Delaware CCCS of Lehigh Valley - Pottstown 1954 E High St Pottstown, PA 19464 866.889.9347 www.cDnsurriercredittv.org 'Chester, Montgomery CCCS of Lehigh Valley - Quakertown 127 S. 5th St; STE 155 Quakertown, PA 18951 866.889.9347 www.cDnsumarcrediUv.org 'Bucks CCCS of Lehigh Valley - Whitehall 3671 Crescent Court E Whitehall, PA 18052 866.889.9347 www.consuniercredigv.org 'Carbon, Lancaster, Lehigh, Schuylkill CCCS of Lehigh Valley - Wyomissing 833 N Park Rd, M; STE 103 Wyomissing, PA 18072 866.889.9347 www.consumercredifv.org 'Barks, Northampton CCCS of Northeastern PA - By Appt Only 214 W. Walnut St Hazleton, PA 18201 800.922.9537 www.ccesnepa.org 'Carbon CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537/570.602.2227 www.oocsnepe.org 'Bradford, Carbon, Centre, Clearfield, Luzeme, Clinton, Columbia, Elk, Juniata, Lackawanna Lycoming, Mifflin,Monroe,Montour,Northumberle Pike, Potter, Schuylkil, Snyder, Sullivan Susquehanna,Tioga,Union,Wayne, Wyoming CCCS of Northeastern PA - State College 202 W Hamilton Ave State College, PA 16801 800.922.9537/814.238.3688 www.c=nepa.org 'Blair CCCS of Northeastern PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537/570.602.2227 www.cccsnepa.org 'Monroe CCCS of Western PA - Altoona 917A Logan Blvd; Royal Remax Plaza Altoona. PA 16602 888.511.2227/888.511.2227 www.cccspa.org 'Bedford, Blair, Cambria, Centre, Clearfield, Fulton, Huntingdon, Juniata, Somerset CCCS of Western PA - Butler 112 Hollywood Dr, STE 101 Butler, PA 16001 888.511.2227/888.511.2227 www.mcspa.org 'Armstrong, Beaver, Butler, Clarion, Jefferson, Lawrence CCCS of Western PA - Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227 / 888.5112227 www.cccspo.org 'Crawford, Elk, Erie, McKean, Mercer, Union, Vanango, Warren CCCS of Western PA - Greensburg 1 N Gate Sq Greensburg, PA 15601 888.511.2227/888.511.2227 www.cocspo.org 'Indiana, Westmoreland CCCS of Western PA - Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg, PA 17110 888.511.2227/888.511.2227 www.cccspa.org 'Dauphin, Juniata, Lebanon, Mifflin, Northumberland, Perry, Union CCCS of Western PA - Pittsburgh 2403 Sidney St; STE 400; River Park Commons Pittsburgh, PA 15203 888.511.22271888.511.2227 www.occspa.org 'Allegheny, Cameron CCCS of Western PA - York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 / 888.511.2227 www.=Spa.org 'Adams, Cumberland. Franklin, Lancaster, Lebanon, York Center for Family Services, Inc. 213 W Center St Meadville, PA 16335 814.337.8450 www.thecenter-nwpa.org 'Crawford, Mercer, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.849.5100 www.conterinthepark.org 'Philadelphia Chester Community Improvement Project nd 412 Ave of the States Chester, PA 19013 610.876.8663 'Chester, Delaware, Montoomerv. Philadelohia Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.232.9757 www.cactricounty.org 'Cumberland, Dauphin, Perry Community Action Partnership of Mercer County 75 S Dock St Sharon, PA 16146 724.342.3532 www.capmercer.org 'Mercer " Indicates Counties Serviced Community Action Southwest - Washington County 150 W Beau St; STE 304 Washington, PA 15301 877.814.0788/724.852.2893 www.caswg.org 'Washington Community Action Southwest - Waynesburg/Greene 58 E Greene St Waynesburg, PA 15370 877.814.0788 1724.225.9550 www.coswg.org 'Fayette, Greene, Huntingdon, Westmoreland Commission on Economic Opportunity - Wilkes-Barre 165 Amber Lane Wilkes-Barre, PA 18702 800.822.0359/570.826.0510 www.coopeopishelpingpeople.org 'Carbon, Columbia, Luzeme, Monroe Fair Housing Partnership of Greater Pittsburgh, Ina 2840 Liberty Ave; STE 205 Pittsburgh, PA 15222 412.391.2535 www.pifburghfairtiousing.org 'Allegheny Fayette Co. Community Action Agency, Inc. 108 N Beeson Blvd Uniontown, PA 15401 800.427.46361724.437.6050 www.fecoa.org 'Fayette, Somerset, Westmoreland Garfield Jubilee Association 5138 Penn Ave Pittsburgh, PA 15224 412.665.5204 'Allegheny Genesis Housing Corporation 208 DeKalb St; #212 Norristown, PA 19401 Community Action Committee of the Lehigh Valley 610.275.4357 1337 E Fifth St www.genesishousing.org Bethlehem, PA 18015 'Bucks, Chester, Delaware, 610.691.5620 www cadv Montgomery, Philadelphia org 'Barks, Carbon, Lehigh, Monroe, Northampton CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 www.corvgreso.net 'Philadelphia Council of Spanish Speaking Organization (CONCILIO) 70509 N Franklin St Philadelphia, PA 19123 215.627.3100 elconcilianet 'Philadelphia Credit Counseling Center 832 2nd St Pike Richboro, PA 18954 877.900.4222/215.396.1880 www.occ-credit.com 'Bucks, Delaware, Montgomery, Philadelphia Credit Counseling Center 408 Mill St Bristol, PA 19007 www.cco-credd.com 'Bucks, Delaware, Montgomery, Philadelphia Da-Network Housing Ministries, Inc. 1529 N. 7th St Philadelphia, PA 19122 215.927.3227 www.deriehvmkhousing.org 'Philadelphia Diversified Community Services Q Dixon House 1920 S 20th St Philadelphia, PA 19145 215.336.3511 www.dcsphila.org 'Bucks, Delaware, Philadelphia Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 www.gerrnantam.org 'Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philadelphia, PA 19124 215.535.3885 'Philadelphia Greater Erie Community Action Committee 18 W 9th St Erie, PA 16501 814.459.4581 www.gecoc.org 'Erie, Md(ean, Venango, Warren Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717238.9540 'Cumberland, Dauphin, Perry Hispanic Association of Contractors and Enterprise (RACE) Philadelphia 167 W Allegheny Ave; STE 200 Philadelphia, PA 19140 215.426.1151 'Philadelphia Housing Alliance of York 35 S Duke St York PA 17401 717.854.1541 www.housingaillanosofyork.com 'Adams, York Housing and Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 866.683.5907/717.249.0789 www.aiva.com 'Cumberland Housing Development Corporation of Northeastern PA 163 Amber Ln Wilkes Barre, PA 18702 570.824.4803 'Luzeme, Wyoming Housing Opportunities of Beaver County 282 East End Ave Beaver, PA 15009 724.728.7511 www.hobcirrfo.org 'Beaver, Butler, Lawrence Housing Authority of the County of Butler 114 Woody Or Butler, PA 16001 800.433.6327 / 724.287.6797 www. housingauthority .com/Homeownership_Program.himl 'Allegheny, Armstrong, Beaver, Butler, Clarion, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 www.housingpartnershipco.com 'Chester, Delaware, Montgomery Indiana County Community Action Program, Inc. 827 Water St Indiana, PA 15701 724.465.2657 www.iocap.net 'Armelrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercultural Family Servtoss, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 www.dsinc.org 'Delaware, Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 www.koreancenter.org 'Delaware, Philadelphia Lancaster Housing Opportunities Partnership 44 N Christian St; STE 300 Lancaster, PA 17602 717.291.9945 www.lhop.org 'Lancaster Housing Association of Delaware Valley (HADV) Lawrence Housing Association Information Program (HAIP) County Community Action N Watts St 241 ; rant (LCCAP) 658 Philadelphia, PA 19123 241 W Grant 215.978.0224 New Castle, PA 16101 A 888.252.5104 / 724.658.7258 www.hadv.org 24 'Delaware, Philadelphia ?'wence a9/h•PhP *Lawrence Lebanon County Housing and Redevelopment Authority 303 Chestnut St Lebanon, PA 17042 717.273.9326 www.lobanonoountyhousing.com 'Lebanon Liberty Resources, Inc, (Serving Allentown and Philadelphia) 714 Market St; STE 100 Philadelphia, PA 19106 888.634.2155/215.634.2000 www.libedyresotirces.org "Bucks, Chester, Delaware, Montgomery, Philadelphia Loveship,Inc. 2320 N 5th St Harrisburg, PA 17110 717.232.2207 'Cumbedand, Dauphin, Perry Media Fellowship House, Inc. 4302 S Jackson St Media, PA 19063 610.565.0434 www.ffm&afeilDwshiphouse.org 'Chester, Delaware, Montgomery Mon Valley Initiative 305 E Eighth Ave Homestead, PA 15120 412.464.4000 www.monvalloyinitlative.com 'Allegheny, Armstrong, Beaver, Butler, Fayette, Greene, Indiana, Washington, Westmoreland Mt. Airy USA 6703 Germantown Ave; STE 200 Philadelphia, PA 19119 215.844.6021 www.mtairyusa.org 'Philadelphia Nazareth Housing Services (HE and C) 320 Brownsville Rd Pittsburgh, PA 15210 412.381.6925 www.mtnazarethoonter.org/nazareth-housing.htN 'Allegheny Neighborhood Housing Services of Lackawanna County 709 E Market St Scranton, PA 18509 570.558.2490 www.nhslackawannapa.org 'Lackawanna, Pike, Wayne Neighborhood Housing Services of Philadelphia 121 N Broad St; #5 Philadelphia, PA 19107 215.476.4205 www.phillynhs.org 'Philadelphia Neighborhood Housing SoMose Greater Barks 213 N 5th St; STE 10030 Reading, PA 19601 610.372.8433 www.nhsreading.org 'Barks Neighbonvorks Western PA 710 Fifth Ave; STE 1000 Pittsburgh, PA 15219 412281.9773 www.nwwpa.org *Allegheny, Armstrong. Beaver, Sugar, Cambria, Fayette, Greene, Washington, Westmoreland New Kensington Community Development Corp.(NKCDC) 2515 Frankford Ave Philadelphia, PA 19125 215.427.0350 www.r*cdc.org *Philadelphia NID-Housing Counseling-Philadelphis 3212 W. Cheltenham Ave Philadelphia, PA 19150 267.385.7624 *Delaware, Montgomery, Philadelphia Northern Cambria Community Development Corp. (NORCAM Group) 4200 Crawford Avenue Suite 200 Northern Cambria, PA 15714 888.676.8781/814.948.4444 'Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Elk, Erie, Huntingdon, Jefferson, Somerse Northern Tiar Community Action Corp. 135 West 4th Street Emporium, PA 15834 814.486.1161 *Cameron, Elk, McKean, Potter Northwest Counseling Service, Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 'Bucks, Chester, Delaware, Montgomery, Philadelphia The Partnership CDC 4020 Market St; STE 100 Philadelphia, PA 19104 215.662.1612 www.thapartnersHpodc.org *Philadelphia * Indicates Counties Serviced Pittsburgh Community Reinvestment Group SL Martin Center, Inc. (PCRG) 1701 Parade St 1901 Centre Avenue; STE 200 Erie, PA 16503 Pittsburgh, PA 15219 814.452.6113 412.391.6732 www.stmar0neenter.org www•pcr9•crfl *Centre, Crawford, Erie, McKean, *Allegheny Mercer, Venango, Warren Schuylkill Community Action Step, Inc. (a.k.a. LycorningClinton Counties 225 N Center St Commission for Community Action) Pottsville, PA 17901 2138 Lincoln St 570.622.1995 Williamsport, PA 17701 www.schuylkilkv=uNtyacbon.com 800.346.3020 / 570.326.0587 'Barks, Carbon, Lebanon, Lehigh, Luzeme, www.stepoorp.org Northumberland, Schuylkill 'Centre, Clinton, Lycoming, Union Shsnango Valley Urban League 601 Indiana Ave Farrell, PA 19121 724.981.5310 www.svul.org *BUtier, Crawford, Lawrence , Venango South of South Neighborhood Association, Inc. (SOSNA) 1901 Christian St Philadelphia, PA 19146 215.732.8446 www.southofsmth.org *Philadelphia South Philadelphia HOMES, Inc. (SPHINC) 1444 Point Breeze Ave Philadelphia, PA 19146 800.349.5904/215.334.4430 www.sphinc.com 'Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 www.southwastodc.org 'Delaware, Philadelphia Southwestern PA Legal Services - Fayette County. 48 E Mein St Uniontown, PA 15401 888.855.3873 / 724.439.3591 Pathstone Corporation Pennsylvania www.splas.org 1625 North Second St 'Fayette Harrisburg, 17102 Southwestern PA Legal Services - 717.234.8616 6 Greene County www.rurelisc.org/pattretone?na.htm * 63 S Washington St Adams, Barks, Cambria, Cheater, Clearfield, Waynesburg, PA 15370 Cumberland, Dauphin, Franklin, Somerset 888 855.3873 / 724.627.3127 Pennsylvania Interfaith Community Programs, Inc. www.splas.org Adam's County Housing Authority (ACHA) 'Greene 40 E High St Southwestern PA Legal Services - Gettysburg, PA 17325 Somerset County 717.334.1518 132 E. Catherine St www.adamscha.org Somerset, PA 15501 'Adams, Franklin, 800.855.3873 / 814.443.4615 Cumberland, Lackawanna, York www.spies.org Philadelphia Council for Community *Somerset Advancement (PCCA) Southwestern PA Legal Services - 1617 JFK Blvd; STE 1550 Washington County Philadelphia, PA 19103 10 W Cherry Ave 215.567.7803 Washington, PA 15301 www.pocahotising.org 888.855.3873 / 724.225.6170 'Bucks, Chester, Delaware, www.splas.org Montgomery, Philadelphia 'Washington Tableland Services Ino./Community Action Partnership for Somerset Cnty 535 E Main St Somerset, PA 15501 800.452.0148 / 814.445.9628 www.capfsr.org *Bedford, Cambria, Fayette, Somerset, Westmoreland TABOR Community Services, Inc. 308 E King St Lancaster, PA 17608 800.788.5062 /717.397.5182 www.tabomet.org 'Chester, Lancaster, Lebanon United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 TREHAB Center, Inc. 703 S Elmer Ave; STE 104 Sayre, PA 18840 800.982.40451570.888.0412 www.trehab.org *Bradford www.ucsep.org 'Philadelphia TREHAB Center, Inc. 10 Public Ave Montrose, PA 18801 800.982.4045 / 570278.3338 www.trehab.org `Susquehanna United Neighborhood Centers of Northeastern PA 410 Olive St Scranton, PA 18505 570.343.8835 'Lackawanna TREHAB Center, Inc. - Toga County 52 Plaza Ln Welisboro, PA 16901 866.656.7788/570.724.5252 www.trehab.org *Tioga Universal Companies - Universal Community Homes 800 S 15th St Philadelphia, P?. 19146 215.732.6518 *Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia, PA 19107 215.985.3220 www.urbanleaguephila.org *Bucks, Chester, Delaware, Montgomery, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4163 www.ulpgh.org 'Allegheny Voices for independence 1107 Payne Ave Erie, PA 16503 866.407.0064/814.874.0064 www.voicesforindoWdence.org * Clarion, Elk, Erie, McKean, Mercer, Venango Warren-Forest Counties Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, W Warren, PA 16365 800.231.1797/814.726.2400 www.wfcaa.org *Crawford, Forest, McKean, Warren West Oak Lane Community Development Corporation (CDC) 6259 Limekiln Pike Philadelphia, PA 19141 215.224.0880 *Montgomery, Philadelphia Westmoreland Community Action 226 S Maple Ave Greensburg, PA 15601 800.816.0022 /724.834.1260 www.west,mrsiandca.org 'Westmoreland Women's Opportunity Resource Center (WORC) 2010 Chestnut St Philadelphia, PA 19103 215.664.5500 WW W.worc-pe.com 'Philadelphia Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'IF FILED-0, Ali, tR`1(fT " FEB _9 4M Q ': 0131 UNBE8L °,, Citimortgage Inc vs. Daniel J. Shank Case Number 2011-590 SHERIFF'S RETURN OF SERVICE 02/02/2011 04:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 2, 2011 at 1625 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Daniel J. Shank, by making known unto Sandra Heninger, adult in charge at 2380 Lambs Gap Road, 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. SHERIFF COST: $41.50 February 03, 2011 R4RT BITNER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 Attorneys for Plaintiff PLAINTIFF, CitiMortgage, Inc. V. Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025, DEFENDANT. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-00590 CIVIL ACTION c M --t >C--) cn PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: C) 7. C- C) .J ....d C. C? n Kindly enter judgment in favor of the Plaintiff and against Daniel J. Shank, Defendant for their failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: Figures Good Through311912011 Principal Balance: $48,392.98 Late Charges at time of foreclosure referral to counsel: $169.60 Total Interest Amount: $3,005.49 Paid Out School Taxes: $91.37 Foreclosure Attorney Fees: $1,542.00 AppraisalBPO: $84.00 Inspections: $81.00 Total: $53,366.44 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Rich Squire, Esq. (PA I.D.# 04267) arnf $ )y oofi a? M. oy Freedman, Esq. (PA I.D.# 85165) (aU&a? TMB JL?+' ??7 y Christina C. Viola, Esq. (PA I.D. #308909) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire esquirelaw.com tfreedmannsquirelaw.com cviolanasquirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: 3•aS -) L / R ONOTARY TMB Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc. PLAINTIFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025, DEFENDANT. DOCKET NO: 2011-00590 CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE M. Troy Freedman, hereby verifies that he is attorney for the Plaintiff in the above- captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the Defendant not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that Defendant Daniel J. Shank is over 18 years of age and reside at 2380 Lambs Gap Road, Enola, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RICHARD M. SQUIRE & ASSOCIATES, LLC By: - Richard quire, Esq. (PA I.D.# 04267) M. T y Freedman, Esq. (PA I M. 85165) Christina C. Viola, Esq. (PA I.D. #308909) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rs uirennsquirelaw com tfreedmann squirelaw com cviolansauirelaw.com Attorneys for Plaintiff TMB Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025 DEFENDANT. TO: Daniel J. Shank 2380 Lambs Gap Rd. Enola PA 17025 DATE OF NOTICE: March 09.2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2011-00590 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. FAClients\Citi Mortgage\Shank - 244F\10 day notice.wpd\TMB IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAChents\Citi Mortgage\shm* - 244F\10 day notice.wpd\TMB .Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Mar-18-2011 07:59:07 "4° Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency SHANK DANIEL Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 14. 4WJ._ ' AMY, - q A?M- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htrnl. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 3/18/2011 .Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:GCSQAKA83D https://www.dmdc.osd.mil/appj/scra/popreport.do 3/18/2011 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011-00590 C 7 4'" -?? Daniel J. Shank ? 2380 Lambs Gap Road, CIVIL ACTION te c 'r Enola, PA 17025 cnr - DEFENDANT. € MORTGAGE FORECLOSURE C) PRAECIPE FOR WRIT OF EXECUTION ? s (Mortgage Foreclosure) =- r-- A_ To the Prothonotary: Issue Writ of Execution in the above matter. Amount Due $ 53,366.44 Interest From 03/20/2011 to 09/07/2011 1,771.60 @ $10.30 per diem $ 55,138.04 * plus fees and costs Dated: May 31, 2011 By' - *&4.w P,D ATTNf d M. Squire, Esq. (PA I.D.# 04267) N I.5o 038F M. Troy Freedman, Esq. (PA I.D.# 85165) ga,00 so Christina C. Viola, Esq. (PA I.D. #308909) 14.00 " 115 West Avenue Suite 104 a.5o to , Jenkintown, PA 19046 1711. oo PD ATtY 215-886-8790 215-886-8791 (fax) rsquire&squirelaw.com tfreedman&squirelaw com cviola&squirelaw.com Attorneys for Plaintiff 4a.oo,oue a . so u. C1+at 511 e4&00'71 QE LO-it 4%%u,4 0 rn O O N O i U 0 Q w O d W W a z O U w O x H 4 I ? N [-4 w "oz Ua Ac) ?Q W 00 M N z 0 E-' U W O O w a U U ,a O oo 00 O 00 cr 1-1 En ,-y U h fn v N O W W o? N ?cn t? 00 y 00 `/ U 0 W) a w a O w Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire I.D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011-00590 C: C-5 Daniel J. Shank 2380 Lambs Gap Road, CIVIL ACTION Enola, PA 17025 DEFENDANT. MORTGAGE FORECLOSURE c} AFFIDAVIT PURSUANT TO RULE 31291 •" CitiMortgage, Inc., Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 2380 Lambs Gap Road, Enola, PA 17025, Tax Parcel No. 10-12-2983- 011: 1. 2. 3 4 Name and last known address of Owner(s) or Reputed Owner(s): Daniel J. Shank 2380 Lambs Gap Road, Enola, PA 17025 Name and last known address of Defendant(s) in the judgment: Daniel J. Shank 2380 Lambs Gap Road, Enola, PA 17025 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. 1000 Technology Drive, O'Fallon, MO 63368 Name and address of last recorded holder of every mortgage of record: CitiMortgage, Inc. PLAINTIFF, E-D r T1 1000 Technology Drive, O'Fallon, MO 63368 --t F:\Clients\Citi Mortgage\Shank - 244F\Writ Package.fnn CitiFinancial Mortgage Consumer 9000 Brooktree Road, Ste 202 Discount Wexford, PA 15090 5. Name and address of every other person who has any record lien on the property: None other. 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: PA Department of Revenue P.O. Box 281230 Bureau of Compliance Harrisburg, PA 17128-1230 Department of Public Welfare Health & Welfare Building Attn : Legal Department P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Domestic Relations Cumberland County Tax Claim Bureau Cumberland County Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 FAC(ients\Citi Mongage\Shank - 244F\Writ PackageIrm 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: Tenant/Occupant 2380 Lambs Gap Road, Enola, PA 17025 Sandra Heniger 2380 Lambs Gap Road, Enola, PA 17025 VERIFICATION I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Richard M. Squire & Associates, LLC By: Vintown, eedman, Esquire 1Avenue, Suite 104 J PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: May 31, 2011 FAClients\Citi Mortgage\Shank - 244F\Writ Package.frm F Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire I.D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. PLAINTIFF, V. Daniel J. Shank 2380 Lambs Gap Road, Enola, PA 17025 DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYQA=k rn C- C= rn n NO. 2011-00590 :0M ? ,.. CIVIL ACTION } -? MORTGAGE FORECLOSURE -"-` -- ' ' NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Daniel J. Shank 2380 Lambs Gap Rd. Enola, PA 17025 Your house (real estate) at 2380 Lambs Gap Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesdav September 7 2011 at 10 00 a m at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the courtjudgment of $53,366.44 plus interest to the sale date obtained by CitiMortgage, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay back to CitiMortgage, Inc., the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire or M. Troy Freedman, Esquire at (215) 886-8790. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriff s Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6195. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the owner of the properly as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Lawyer Reference Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-590 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC., Plaintiff (s) From DANIEL J. SHANK (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 $53,366.44 L.L. $.50 Interest from 3/20/11 to 9/7/11 @ $10.30 per diem -- $1,771.60 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Other Costs Plaintiff Paid Date: 6/3/11 David D. Buell, Prothonotary (Seal) g Deputy REQUESTING PARTY: Name: M. TROY FREEDMAN, ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 85165 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , Sheriff I I Jody S Smith ?l?o?tr ai ?a,i,i?r(p«4 Chief Deputy ? Richard W Stewart Solicitor Contimortgage Inc vs. Daniel J. Shank Case Number 2011-590 SHERIFF'S RETURN OF SERVICE 06/24/2011 08:03 PM - Deputy Michelle Gutshall, being duly sworn according to law, states seniice 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 2380 Lambs Gap Road, Enola, PA 17025, Cumberland County. 06/24/2011 08:03 PM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Daniel J. Shank at 2380 Lambs Gap Road, Hampden Township, Enola, PA 17025, Cumberland County. 09/06/2011 As directed by M Troy Freedman, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/7/2011 09/29/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,068.85 SO ANSWERS, September 29, 2011 RON R ANDERSON, SHERIFF L. C?. _?? s 1174 On June 7, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 2380 Lambs Gap Road, Enola, more fully described on Exhibit "A" filed with. this writ and by this reference incorporated herein. Date: June 7, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-590 Civil Contimortgage Inc. vs. Daniel J. Shank Atty.: M. Troy Freedman The land referred to in this Com- mitment is described as follows: Hampden Township, Cumberland County ALL THAT CERTAIN lot or tract of land situate along the east side of the Lamb's Gap Road In the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin in the center line of the Lamb's Gap Road at the northern line of land now or late of C.W. Erney being 4752 feet in a northerly direction by said center line from the Wertzville Road; thence along the center line of said road North 4 degrees 30 minutes West 100 feet to an iron pin; thence along land now or late of Robert T. Stoner and Charlotte J. Stoner, his wife, North 89 degrees East 191 feet to a post; thence along land of same South 4 degrees 30 minutes Fast 100 feet to a post; thence along land now or late of C.W. Erney South 89 degrees West 191 feet to an iron pin in the center line of the Lamb's Gap Road, the place of BEGINNING, CONTAINING .43 acres, more or less, and being improved with a one- story frame dwelling. UNDER AND SUBJECT to rights- of-way of highways, streets and alleyways abutting or adjoining the premises; easements and rights-of- way of record and apparent upon the premises; and restrictions and reservations of prior record. Parcel #10-12-2983-011. 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: July 15, July 22 and July 29, 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. U Lisa Marie C (Pe, Editor. SWORN TO AND SUBSCRIBED before me this 9 da of Jul 2011 1 Notary / NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 26, 2014 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 Patr1*otwXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden.. County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising.. and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behaif 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: 07/15/11 07/22111 07129/11 s ? f Sworn to and subS.oribed before me-Ks '18 day of August, 2011 A D. Notary Public t:C)f PMONV E.Al.:°r O PENNSYLVANIA Notarlai Scat hr rt° L.'(Isnei, NoUiry Pubix er pa don rwp., Gauohin C:ounly My Corn;rossor Expires Nov. 26, 2011 TTL_; h, " ,!f 3., cm? ')° "lotan- 20114190 CWN Ten °' CaMiw9e Inc Ys Dan kA j. $bank' AtW M I" freedman The land referred to in this Commitment is described as follows: Cumberland County Hampden Township lot or tract of land ALL THAT CERTAIN situate along the east side of the Iamb's Gap Road In the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin in the centerline of the Iamb's Gap Road at the northern line of land now or late of C.W Erney being 4752 feet in a northerly direction by said center be from the Werwitle Road, thence along the center line of said road North '4 degrees 30 minutes west 100 feet to an iron pin, thence along land -now or late of Robert T. Stoner and Charlotte J. Stoner, t t? Est North 89 degrees ast 191 thence along land of same South 4 degrees 30 minutes East 100 feet to a post; thence along land now or late of C W. trnCY South 89 degrees West 191 feet to an iron pin in the centerline of the Lamb's Gap Road, the place of BEGINNING, CONTAINING .43 acres, more or less, and being improved with a one-story frame dwelling. UNDER AND SUBJECr to rights-of-way of highways, streets and alleyways abutting or adjoining the premises; easements and tights-oflway of record and apps nt upon the premises; and reservations of prior record. Parcel #10.12-2983-011