HomeMy WebLinkAbout11-269771
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Leon P. Haller, Esquire
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
717.234.4178
mtg@pkh.com
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U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY
Plaintiff
VS.
MICHAEL R. ADAMS AND NINA L. KREPS
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action
within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so
the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money
claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA
DE ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE fi`1 rL? 414 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
A V1
CARLISLE, PA 17013
717-249-3166
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
Plaintiff
vs.
MICHAEL R. ADAMS AND NINA L. KREPS,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.C. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorney I.D.# 15700
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
Plaintiff
vs.
MICHAEL R. ADAMS AND NINA L. KREPS,
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, MICHAEL R. ADAMS and NINA L. KREPS, are adult individuals whose last known
address is 357 SHERWOOD DRIVE, CARLISLE, PA 17015.
3. On or about, October 30, 2006, the said Defendants executed and delivered a Mortgage Note in the sum
of $127,492.00 payable to PHILADELPHIA FINANCIAL MORTGAGE a division of LEESPORT
BANK, which Note is attached hereto and marked Exhibit "A"
4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain
real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth on October 31, 2006 in Mortgage Book 1971, Page 551 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 October 31, 2006 in
Book 731, Page 3321. The Mortgage was further assigned to U.S. BANK, NATIONAL
ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, which
Assignment is attached hereto and marked Exhibit "B". The said Mortgage and Assignment are
incorporated herein by reference.
5. The land subject to the Mortgage is: 357 SHERWOOD DRIVE, CARLISLE, PA 17015 and is more
particularly described in Exhibit "C" attached hereto.
6. The said Defendants are the real owners of the property.
7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July
O1, 2010 and all subsequent installments thereon, and the following amounts are due on the Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $21.12 per day
From 06/01/2010 To 04/01/2011
( based on contract rate of 6.2500%)
Accumulated Late Charges
Late Charges $31.40
From 07/01/2010 to 04/01/2011
Escrow Deficit
Attorney's Fee at 5% of Principal Balance
TOTAL
$121,678.69
$6,441.60
$51.60
$282.60
$807.71
$6,083.93
$135,346.13
"Together with interest at the per diem rate noted above after April 01, 2011 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. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendants by letters
dated September 10, 2010 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the
September 10, 2010 Act 6 Notice is attached hereto and marked Exhibit "D".
9. The within Mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
10. 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 Service Members Civil Relief Act, as amended. Copies of
the website reports from the Department of Defense Manpower Data Center, confirming non-active
military duty are attached as Exhibit "E".
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 6.2500% ($21.12 per diem), together with other charges
and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale
of the property within described.
By:
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
I.D. # 15700
Jill M. Wineka
I.D. #58802
Attorneys for Plaintiff
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
?o. Mo F, 3
a Loan Number: 12306354
NOTE
FHA CASE No.
?-
441-7864670
OCTOBER 30, 2006 //
(Dare]
357 SHERWOOD DRIVE, CARLISLE, PENNSYLVANIA 17013
?mPe?tY Addr?u)
I- PARTIES
"Borrower" means each
PHILADELPHIA FINANCIAL person signing at the end of this Note, and the person's successors
PENNSYLVANIA BANKING CORPORATION LEESPORT BANK,' "Lender"means
OF A
Z' BORROWER'S PROMISE TO PAY- IA and its successors and assigns.
In return for a loan received from ? CREST
TWENTY-SEVEN THOUSAND gp r' Borrower promises to
(U.S.S 127, 492.00 R HUNDRED NINETY-TWOrlAND SUM of ONE
From the date of disbursement of the )'Plus interest, ro AND 001100 ONE
the order of Lender. Interco! Dollars
Proceeds by Lender, at the rate of will be charged on id
until the full amount of principal has been SIX AND 250/1000 principal,
Paid. percent ( 6-250
3. PROA9ISE TO PAV SECL'R.ED %) per year
Borrower's promise to pay is secured b
date as this Note and called by a mortgage, deed of trust or similar ascots
result if Borrower defaults uheeerSthisrNote.s merit." ty instrument that is dated the mine
Protects the Lender ender from losses Which might
MATINER OF PAYMENT
(A) Time
on BoDECEMBSR alke a Payment of principal and interest to
NOVEMBER 1 , 2 006 Lender on the first
2036 Anyprincipal and interest ye of each month beginning
(B) Piece will be due on that date, which is caled?„on the first day of
Payment shall be "Maturity bete,"
PENNSYLVANIA made at 1767 SENTRY
PARKWAY WESTY PARKWAY WEST, 19422 SUITE 220,
BLUE BELL,
(C) Amount or at such other place as Lender may designate in writing by notice to Borrower
Each monthly payment of principal and interest will be '
This amount will be pert of a larger month) in the amount of U. S. 5 78 4 , 9 9
interest and other items in the y payment required b
order described in the Security Instrument. mall be applied to principal,
(D) Allonge to this Note for Payment Adrustments
'ran allonge providing tad
a11°nge shall be into orfor payment edNsnaenra is executed b
of this Nete. i"tD and shall amend end e y Borrower together with
(Check applicable box.) supplement the covens this Note, th the covenants of e
tsls of this Note an if f the allooge were a part
n
? Growing Equity gllonge
Oradueted Payment Allonge
Other [specify)
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced b
day of any month, Lender shell accept Y this Note,
for cite remainder of the Prepayment on other days to whole or is part, without charge or
month to provided that Borrower penalty. on the first
makes a parries rethe extent required by Lender and pays interest acrcthe amount
P Prepayment, there will be no changes in the due Permitted b prepaid
agrees in writing to those changes, by regulations of the S
date or in the amount of the monthly Payment Unless sa Lender
ML2TSTATB-PrrA FV= RATE N0,, (,..o
De:rmm arneT., fns, faM 645-1362
Page 1 of Z
i' 4
Jan.25. 2011 9:584M US BANK DOCUMENT.CUSTODY
No. 0380 P. 4
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C)
of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of
FOUR AND 000/1000 percent ( 4.000 y?)
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Leader may, except as limited by regulations of
the Secretary in the case of payment defaults, require immediate payment in full of the principal balance retraining due and
all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Leader's rights to require immediate payment
in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations.
As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee,
(C) Payment of Costa and Expenses
If Lender has required immediate payment in full, as described above, Leader may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable
law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. 'Presentment' means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means
the right to require Leader to give notice to other persons that amounts due have not been paid.
S. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given
by delivering it or by mailing It by first class mail to Borrower at the property address above or at a different address if
Borrower has given Lender a notice of Borrower's different address.
Any notice diet must be given to Leader under this Note will be given by first class mail to Lender at rite address stated
in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person sighs 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
vote is also obligated to do these things. Any person who takes over these obligations, including the obligations of a
guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note, Lender may
enforce its rights under this Note against each person individually or against all signatories together. Any one person signing
this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in pages 1 and 2 of this Note.
M/iG/ 1-2- a a,, (Seal)
MICHAEL R ADAMS -Borrower
- (Seal)
-Borrower
_. (Seal)
-Borrower
?,MAAM (Beni)
NINA L K.REPS ?- -Borrower
- (Seal)
-Borrower
- (Seal)
-Borrower
Jan. 25. 2011 9:58AM US BANK DOCUMENT CUSTODY No.0)80 F, 5
ALLONGE
LOAN: 12306354
Borrower(s): MICHAEL R ADAMS, NINA L KREPS
PropertyAddresst 357 SHERWOOD DRIVE, CARLISLE, PENNSYLVANIA 17013
Principal Balance: $127,492.00
Loan Date: OCTOBER 30, 2006
PAY TO THE ORDER OF
- PF?iNSYT VANTp Hf]t]ST it oTnrn?irv nrc,may
Without Recourse
Company Name:
LEESPORT
By: \ it
(Name) FRED CONNOR
Record Prepared by & Return to:
U.S. Bank National Association
c/o PHFA-Accounting & Loan Servicing
211 North Front Street, P.O. Box 15057
Harrisburg, Pennsylvania 17105-5057
717-780-3800 or 1-800-346-3597
PIN / ID Number: 21050431027
Above space is intentionally left blank for recording data.
ASSIGNMENT OF MORTGAGE
For value received, PENNSYLVANIA HOUSING FINANCE AGENCY ("PHFA"), hereby grant, sell, convey,
assign and deliver unto the U.S. BANK NATIONAL ASSOCIATION, (Trustee for the Pennsylvania Housing
Finance Agency, pursuant to a Trust Indenture dated as of April 1, 1982), its successors and assigns, the following
described Mortgage, together with the Note secured thereby:
Name of Original Mortgagor(s): MICHAEL R. ADAMS
NINA L. KREPS
Secured by the real property located at: 357 SHERWOOD DRIVE, CARLISLE, PA 17015
Municipality of. MIDDLESEX
Original Principal Amount: $127,492.00 County Recorded in: CUMBERLAND
Mortgage Recorded: October 31, 2006 Record Book: 1971 Page: 0551
Last Assignment to: PA Housing Finance Agency Record Book: 0731 Page: 3321
IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of
Mortgage to be executed by its duly authorized officer. (Series: 096, PHFA) [GUTSHALE]
DATED: January 28, 2011 By: PENN YLVANIA HO SI G FI ANCE AGENCY
40forz
Anthony J. Jul?
Director of Accounting and Loan Servicing
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On this, the day of 2011, before me, the undersigned officer, personally appeared
Anthony J. Julian, Director of Acc unting and oan Servicing, an authorized officer of the Pennsylvania Housing
Finance Agency, and acknowledged that he, being authorized to do so, executed the foregoing instrument for the
purposes therein contained.
In witness whereof, I have hereunto set my hand and official seal.. w12C&i
Notary Publi
MMON01MO 16F FNNMVANIA
Noartal seal
KlmballOy A. Ayala, Notary Public
City d thni ury, Dauphin County
MY 0XV111"M
S ten' 15, 2015
CERTIFICATE OF RESIDENCE OF ASSIGNEE
MEM9ER, PLtiNSY1.YANIA A$OUATIOM OF NOTARIES
I certify that the principal business and mailing address for this assignment and assignee is:
U.S. Bank National Association, c/o PHFA-Accounting & Loan Servicing
211 North Front Street, P.O. Box 15057, Harrisburg, Pennsylvania 17 OS-5057
W
Au o zed Officer
G?-' I ?' P
ALL that certain tract of land situate in Middlesex Township, Cumberland County,
Pennsylvania, bounded and described in accordance with survey made by Noel B. Smith,
registered Surveyor, on March 29, 1973, as follows:
BEGMING at a point in the center line of Thirty-three (33) feet wide Township Road T-
503 known as Sherwood Drive at the corner of land now or formerly of Harry Donnley;
thence along the center line of said Township Road T-503, South 65 degrees 15 minutes 24
seconds East, a distance of Ninety-six and Ninety Hundredths (96.90) feet to a point; thence
along line of land now or formerly of Lynell W. Wolf and wife, and through a partition wall
of a frame shed, South 27 degrees 40 minutes 13 seconds West, a distance of Two Hundred
Twenty-four and Eighty Hundredths (224.80) feet to a point; thence still along line of land
now or formerly of Lynell W. Wolf and wife, South 32 degrees 12 minutes 32 seconds West,
a distance of One Hundred Seventy-three and Ninety-eight Hundredths (173.98) feet to a
post; thence South 84 degrees 32 minutes 33 seconds West, a distance of One Hundred
Sixty-five and Thirty-nine Hundredths (165.39) feet to a point; thence along a fence, North
21 degrees 02 minutes 45 seconds East, a distance of One Hundred Thirty-eight and Eighty
Hundredths (138.80) feet to a post, thence along a fence, South 64 degrees 28 minutes 15
seconds East, a distance of Ninety-nine atui Nineteen Hundredths (99.19) feet to a post;
thence still along a fence, North 20 degrees 17 minutes 23 seconds East, a distance of One
Hundred Forty-eight and Thirty-one Hundredths (148.31) feet to an iron pin; thence still
along a fence, North 25 degrees 11 minutes 27 seconds East, a distance of One Hundred
Ninety-five and Twenty-six Hundredths (195.26) feet to a point in the centerline of Thirty-
three (33) feet wide Township Road T-503 known as Sherwood Drive at the plan of
BEGINNING.
The above described tract of land contains an area of one acre, more or less, and has the
mailing address of 357 Sherwood Drive, Carlisle, PA 17013.
I
rennsyivanja
Housing Finance Agent,
A- ntin aXc Loan Servicin
211 North Pront .Street, 11. 0. Box 15057
Harrisburg, 1'A 17105-5057
(800) 346-3597 FAX (717) 780-3899
TTY (717) 780-1869
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
9/10/2010
MICHAEL R. ADAMS
NINA L. KREPS
357 SHERWOOD DR
CARLISLE, PA 17015-9013
RE: Account No. 1461011
RE: 357 SHERWOOD DR
CARLISLE, PA 17015-9013
Dear Occupant(s):
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter We, Us
or Ours) on your property located at 357 SHERWOOD DR, CARLISLE, PA 17015-9013, IS IN
SERIOUS DEFAULT because you have not made the monthly payments of $994.00 for 7/2010 through
9/2010 for a total of $2,982.00. Late charges and NSF charges that have accrued to this date in the
amounts of $114.40 and $.00 respectively, are also due. The total listed below includes all fees
(including inspections and securing that needed to be completed) less any funds we are holding in
suspense. The total amount now required to cure this default, or in other words, get caught up in your
payments, as of the date of this letter is $3,096.40.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the
total amount of $3,096.40, plus any additional monthly payments, expenses and late charges which may
fall due during this period. Such payment must be made either by cash in our office, cashier's check,
certified check or money order and made at:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 NORTH FRONT STREET/P.O. BOX 15057
HARRISBURG, PA 17105-5057
1-800-822-7375 or TTY (800) 346-3597
If you do not cure the default within THIRTY (30) DAYS,
We intend to exercise our right to
accelerate the mortgage payments. This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY
(30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your M2ggaaeed
rP operty. -
If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the
mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal
proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay the reasonable
attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us,
which may also include our reasonable costs. If you cure the default within the thirty-day period, you will
not be required to pay attorney fees.
G(k-, bl- P1 I I FHAACT/dtmdocs/ALSV/
We may also sue you pcisonally for the unpaid principal balance anu al other sums due under
the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings
have begun, you still have the right to cure the default and prevent the sale at any time up to one hour
before the sheriff Ps foreclosure sale. You may do so by paying the total amount of the unpaid monthly
payments and any late or other charges then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale and perform any other requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff's sale could be held would be approximately five
months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment will be by calling us at the following number:
1-800-822-7375. This payment must be made payable in cash in our office, cashier's check, certified
check or money order and made payable to us at the address stated above.
You should realize that a Sheriff's sale will end your ownership of the mortgaged property and
your right to remain in lt. If you continue to live in the property after the Sheriff's sale, a lawsuit could be
started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY
HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A
BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID
PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE
ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had
occurred. However, you are not entitled to this right to cure your default more than three times in any
calendar year.
You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under
the mortgage documents, the nonexistence of a default or any other defense you believe you may have
to any such action.
If you maintain credit, life or disability insurance in connection with your mortgage loan, your
failure to pay premiums with your payments may have already resulted or may result in the future in the
lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is
cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the
insurance company and qualify for replacement insurance it you wish to retain it.
If you make partial payments on account of the delinquencies, we may accept them and apply
them to the delinquencies. However, such partial payments will not cure your default or reinstate your
loan. The loan will not be reinstated unless we receive the entire amount required to cure the default.
Sincerely,
Mr. Thomas L. Gouker
Manager of Collections
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street/ P.O. Box 15057
Harrisburg, PA 17105-5057
TLG/
FHAACT/dtmdocs/ALSW
. rennsylivania
Housing Finance AgenL A yjunting & Loan Servicing
?11 North Front Street, P. 0. Box 15057
Harrisburg, PA 1 71 05-505 7
(800) 346-3597 FAX (717) 780-3899
TTY (717) 780-1869
NOTICE
9/10/2010
MICHAEL R. ADAMS
NINA L. KREPS
357 SHERWOOD DR
CARLISLE, PA 17015-9013
RE: Account #1461011
TO: MICHAEL R. ADAMS
NINA L. KREPS
357 SHERWOOD DR
CARLISLE, PA 17015-9013
FROM: PENNSYLVANIA HOUSING FINANCE AGENCY
The Federal Housing and Development Act of 1987 (as amended) directs creditors
to notify homeowners who are delinquent in their mortgage obligation of the availability of
homeownership counseling provided by nonprofit organizations approved by the Secretary
of the Department of Housing and Urban Development ("HUD") and experienced in the
provision of homeownership counseling.
Attached is a current list of HUD-approved counseling agencies for Pennsylvania.
If these agencies are not near you, you can call HUD's toll free number (800)
569-4287 for financially distressed mortgagors for information concerning HUD-approved
housing counseling agencies.
Attachment: Housing Counseling List
FHAACT/dtmdocs/ALSW
*** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY ***
CCCS OF WESTERN PA-HARRISBURG
2000 LINGLESTOWN RD.
HARRISBURG, PA. 17110
Phone:888-599-2227
NACA
1341 N DELAWARE AVE; SUITE 312
PHILADELPHIA, PA. 19125
Phone:888-297-5568
HOUSING ALLIANCE OF YORK
DEVELOPMENT
34 S. Duke St.
York, PA 17401-1106
Phone: 800-8644909
TABOR COMMUNITY SERVICES
208 E King St.
Lancaster, PA 17608-1676
Phone: 717-397-5182
PHILADELPHIA COUNCIL OF COMMINITY
ONE PENN CENTER;1617 JFK BLVD; SUITE 1550
PHILADELPHIA, PA. 19103-1828
Phone:800-930-4663
FHAACT/dtmdocs/ALSW
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Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Feb-01-2011 06:39:22
< Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
KREPS NINA L 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).
y6t f 01
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/f4q/pis/PC09SLDR.htnll. 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/popr o . 0
C 2/1/2011
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 SCR,4 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:P43ONSHOUC
https://www.dmdc.osd.mil/appj/scra/popreport.do 2/1/2011
Request for Mil, itary Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Feb-01-2011 06:35:06
< Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
ADAMS MICHAEL Based on the information you have furnished, the DMDC does not possess
R 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).
IA_
y6t /'I
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 htip://www.defenselink.mil/faq/pis/PC09SLDR.html. 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 2/1/2011
:,Zequest for Vi;itary Status
Page 2 of 2
j61ore 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:IKA001 SR3M
https://www.dmde.osd.mil/appj/scra/popreport.do
2/1/2011
COMPANY NAME: PENNSYLVANIA HOUSING FINANCE AGENCY AS SERVICING
AGENT FOR U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE
PENNSYLVANIA HOUSING FINANCE AGENCY
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated 52125)1)
By AO?Q
Title Director of Accounting & Loan Servicing
ADAMS 1461011
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
d
n
04/'(
Lit p
41, ri
ist4 rd t ;
a??r-??:?Ar
US Bank National Association
vs.
Michael R. Adams (et al.)
Case Number
2011-2697
SHERIFF'S RETURN OF SERVICE
03/25/2011 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 357 Sherwood Drive, Carlisle,
Pennsylvania 17015, 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
357 Sherwood Drive, Carlisle, Pennsylvania 17015 is vacant.
03/25/2011 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: Michael R. Adams, 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 Michael R. Adams. Request for service at 357 Sherwood Drive, Carlisle, Pennsylvania 17015
is vacant. The Carlisle Postmaster has confirmed, Michael R. Adam's new address is P.O. BOX 483,
New Bloomfield, Pennsylvania 17068.
03/25/2011 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: Nina L. Kreps, 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 Nina L. Kreps. Request for service at 357 Sherwood Drive, Carlisle, Pennsylvania 17015 is
vacant. The Carlisle Postmaster has confirmed, Nina L. Kreps's new address is 123 W. McClure Street,
New Bloomfield, Pennsylvania 17068.
SHERIFF COST: $81.00
March 25, 2011
SO ANSWERS,
---
_zZ
RON R ANDERSON, SHERIFF
Ceurt*ys;jitn SNe,rff, 1es:iec,5a'i Inc
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY
Plaintiff
VS.
MICHAEL R. ADAMS AND NINA L. KREPS
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 11-2697-CIVIL
PRAECIPE TO REINSTATE
-<> Q +
r-)
TO THE PROTHONOTARY: a
?
Kindly reinstate the complaint on the above captioned matters o
DATE: March 31, 2011
PURCELL, KRUG, & HALLER
BY (I'll. U 1 I lAkli,, j L
Jill M ineka
ID #54'802
Leon P. Haller
ID # 15700
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, Pa. 17102
717-234-4178
0,M} % 1b -00 T)d 61
"?-
mt IW14(p,
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
???titr of uanbep?V 440
FILED-OFFICE
'Fi' THE PROTHONGTARY
2011 APR I I PM 12= 58
Richard W Stewart
Solicitor
US Bank National Association
vs.
Michael R. Adams (et al.)
OFF t:E - -F _-ER1rF
CUMBERLANDVA COUNTY
Case Number
2011-2697
SHERIFF'S RETURN OF SERVICE
04/04/2011 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: Michael R. Adams, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
In Mortgage Foreclosure according to law.
04/04/2011 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: Nina L. Kreps, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
In Mortgage Foreclosure according to law.
04/05/2011 01:55 PM - Perry County Return: And now April 5, 2011 at 1355 hours I, Carl E. Nace, Sheriff of Perry
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Nina L. Kreps by making known unto
herself personally, at 123 W. McClure Street, New Bloomfield, Pennsylvania 17068 its contents and at the
same time handing to her personally the said true and correct copy of the same.
04/05/2011 01:55 PM - Perry County Return: And now April 5, 2011 at 1355 hours 1, Carl E. Nace, Sheriff of Perry
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Michael R. Adams by making known
unto Nina L. Kreps, Wife of Defendant at 123 W. McClure Street, New Bloomfield, Pennsylvania 17068 its
contents and at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $53.00
April 08, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
{0j COW tySuite Snenff_ releosoft, Inc
US Bank NA IN THE COURT OF COMMON PLEAS OF
THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA,
PERRY COUNTY BRANCH
Versus
Michael R. Adams and
No. 2011-2697
Nina L. Kreps
SHERIFF'S RETURN
And now April 5 , 2011 : Served the within name Nina L. Kreps
the defendant(s) named herin, personally at her place of residence in New Bloomfield Boro-
123 W McClure St,
Perry County, PA, on April 5, 2011 at 1:55 o'clock PM
by handing to Nina Adams (Kreps), defendant 1 true and attested
copy(ies) of the within Complaint in Mortgage Foreclosure
and made known to her the contents thereof
Sworn and subscribed to before me this
!L
So answers
day of ; , v2 Q
CO'WONWEALTH OF PEAR919 tary
N A IA amt. ??
MARGARET I', NICKINGER, Notary Public
Bloomfield Boro. Parry County
My Commission Expires Feb.16.2012
Sheriff of Perry County
US Bank NA IN THE COURT OF COMMON PLEAS OF
THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA,
PERRY COUNTY BRANCH
Versus
Michael R. Adams and
Nina L. Kreps No. 2011-2697
SHERIFF'S RETURN
And now April 5 , 2011 : Served the within name Michael R. Adams
the defendant(s) named herin, personally at his place of residence in New Bloomfield Boro-
123 W McClure St,
Perry County, PA, on April 5 , 2011 at 1:55 o'clock PM
by handing to Nina Adams (Kreps), defendant's wife 1 true and attested
copy(ies) of the within Complaint in Mortgage Foreclosure
and made known to her the contents thereof
Sworn and subscribed to before me this 64 h
day of
Prothonotary
So answers
Deputy Sheriff of Perry County
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL.
MARGARET F. FUCKINGER, Notary PubUc
Bloomfield Boro. Perry county
My Gommiscion Expires Fah 16,2012
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
PLAINTIFF
VS.
MICHAEL R. ADAMS
NINA L. KREPS,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVAN IA
t7 ra
CIVIL ACTION LAW;
CO
rrf ?+.
NO. 11-2697-CIVIL
?D
IN MORTGAGE FORECLOSURE
C:)
RETURN OF SERVICE
C:)
-'Urn
;0=
CD ,
-tca
r;
I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on
141a% J ao I,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:
MICHAEL R. ADAMS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
MICHAEL R. ADAMS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
NINA L. KREPS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
NINA L. KREPS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
357 SHERWOOD DRIVE
CARLISLE, PA 17015
Redevelopment Authority of
County of Cumberland
114 North Hanover Street
Suite 104 - ?'G--
Carlisle, PA 17013 By
PURC , RUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
HOWARD B. KRUG
LEON P. HALLER
JOHN W.PURCELLJR.
JILL M. WINKA
LISA RYNARD
MICHAEL R. ADAMS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
MICHAEL R. ADAMS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
NINA L. KREPS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
NINA L. KREPS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
357 SHERWOOD DRIVE
CARLISLE, PA 17015
Redevelopment Authority of
County of Cumberland
114 North Hanover Street
Suite 104
Carlisle, PA 17013
gD%?C'PGGI
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FAX (717) 234-1206
HERSHEY
(717)533-3836
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court
of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate
will be exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said re slate will be
divested by the sale and that you have an opportunity to protect your interest, if ein notified of
said Sheriffs Sale.
By:
i P. Haller PA I.D.15700
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
PLAINTIFF
VS.
MICHAEL R. ADAMS AND
NINA L. KREPS,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 11-2697-CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, September 07, 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:
357 SHERWOOD DRIVE
CARLISLE, PA 17015
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 11-2697-CIVIL JUDGMENT AMOUNT $135,346.13
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
MICHAEL R. ADAMS AND NINA L. KREPS
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 3401 4644 3036 2463
TO: MICHAEL R. ADAMS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
SENDER:
REFERENCE: NOS 09/07/11
RETURN Postage
RECEIPT Certified Fee
SERVICE
Retum Receipt Fee
Total Postage & Fees /Q
US Postal SeMce POSTMA '? F?poT q?
Receipt for
Certified Mail W? ??
No Insurance CoveryQe Provided w ?J2
Do Not Use for Intemefionel AASN b
------------ --- ----
71160 3401 '164®1
3ti3L 2449
TO: NINA L. KREpS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
SENDER:
REFERENCE: NOS 09/07/11
RETURN Postage --
RECEIPT
SERVICE Certfied Fee
Retum Receipt Fee
Total Postage & Fees ,-4-
US Postal i
``+eMce POSTM ^OR
Receipt for
Certified Mail
No Insuranos ?^atle Prprldb j
Do Not Use for borwl AW
v
--- --..._
7160 3401 9644 3036 2470
TO: MICHAEL R. ADAMS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
SENDER:
REFERENCE: NOS 09/07/11
RETURN Postag-
RECEIPT
SERVICE Certified Fee
Retum Receipt Fee
- Total Postage & pe
T
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US Postal senirce s
G1
Recei
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POSTMARK OR DATE
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7160
3903 964 q-
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3036 24 S6
TO: NINA L. KREPS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
SENDER:
REFERENCE: NOS 09/07/11
RETURN ffCerhfed RECEIPT
SERVICE ee
ceipt Fee
Tota l Postage & Fees
USPostal,?-
,ervloe
POSTMA4seR l
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-- - ---- ---------------------- ----
f
. . l
PENNSYLVANIA HOUSING FINANCE AGENCY v. MICHAEL R. ADAMS NINA L. KREPS
Cumberland County Sale 9/7/2011
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:
MICHAEL R. ADAMS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
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:
NINA L. KREPS
123 WEST McCLURE STREET
NEW BLOOMFIELD, PA 17068
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
y-ols PflsT TA
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MAILED FROM ZIP t,O 01
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PENNSYLVANIA HOUSING FINANCE AGENCY v. MICHAEL R. ADAMS NINA L. KREPS
Cumberland County Sale 9/7/2011
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:
TENANT/OCCUPANT
357 SHERWOOD DRIVE
CARLISLE, PA 17015
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:
MICHAEL R. ADAMS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
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:
NINA L. KREPS
357 SHERWOOD DRIVE
CARLISLE, PA 17015
f;51
??B?fDii
gPCfS POST y
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vnrirv aowEs
` 00204284324 $ 01$15°
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 Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Redevelopment Authority of
County of Cumberland
114 North Hanover Street
Suite 104
Carlisle, PA 17013
TA
Posr'94?
?s
.7 PI7NFY 11 WJES
02 1M $ 01.150
0004284324 uUf\i28 2011
MAILED FROM ZIP CODE 1 710 2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson t ` r
Sheriff
Jody S Smith i'; 2 h i°
Chief Deputy
Richard W Stewart
Solicitor
U it
US Bank Trust National Association Case Number
vs. 2011-2697
Michael R. Adams (et al.)
SHERIFF'S RETURN OF SERVICE
06/17/2011 03:30 PM - Deputy Noah Cline, 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 357 Sherwood Drive, Carlisle, PA 17015, Cumberland County.
07/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Michael R. Adams, but was unable to locate the Defendant
in his bailiwick. He therefore deputized the Sheriff of Perry County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
07/05/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of
Perry County upon Nina L. Adams (Kreps), who accepted for Michael R. Adams, at 123 W. McClure
Street, New Bloomfield, PA, on 6/17/11 at 1:20 p.m. So Answers: Derek Bates, Deputy, Sheriff.
07/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Nina L. Kreps, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of Perry County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
07/05/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of
Perry County uponNina L. Adams (Kreps), personally, at 123 West McClure Stret, New Bloomfield, PA on
6/17/11 at 1:20 p.m. So Answers: Derek Bates, Deputy Sheriff.
09/07/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m..
He sold the same for the sum of $1.00 to Attorney Leon Haller, on behalf of, U.S. Bank National
Association, et. al., of, 211 North Front Street, Harrisburg, PA 17101 being the buyer in this execution,
paid to the Sheriff the sum of $
SHERIFF COST: $1,104.19 SO ANSWERS,
October 21, 2011 RON ~ R ANDERSON, SHERIFF
co (r,i Gowltysuite sher.'f, le'...eos oft. 6`i }.. 6 t N/l
On June 9, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
Middlesex Township, Cumberland; County, PA,
Known and numbered as, 357 Sherwood Drive,
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: June 9, 2011
By:
aj-? 8e-oe-?
Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2011-2697 Civil
US Bank National Association
VS.
Michael R. Adams
Nina L. Kreps
Atty.: Leon P. Haller
ALL THAT CERTAIN tract of land
situate in Middlesex Township,
Cumberland County, Pennsylvania,
bounded and described in accor-
dance with a survey made by Noel
B. Smith, Registered Surveyor, on
March 29, 1973, as follows, to wit:
BEGINNING at a point in the
center line of thirty three (33) feet
wide Township Road T-503 known
as Sherwood. Drive at the corner of
land now or formerly of Harry Donn-
ley; thence along the center line of
said Township Road T-503, south 65
degrees 15 minutes 24 seconds east
a distance of ninety six and ninety
hundredths (96.90) feet to a point;
thence along line of land now or for-
merly of Lynell W.Wolf and wife, and
through a partition wall of a frame
shed, south 27 degrees 40 minutes
13 seconds west, a distance of two
hundred twenty four and eighty
hundredths (224.80) feet to a point;
thence still along line of land now
or formerly of Lynell W. Wolf and
wife, south 32 degrees 12 minutes
32 seconds west, a distance of one
hundred seventy three and ninety
eight hundredths (173.98) feet to a
post; thence south 84 degrees 32
minutes 33 seconds west, a distance
of one hundred sixty five and thirty
nine hundredths (165.39) feet to a
point; thence along a fence, north 21
degrees 02 minutes 45 seconds east,
a distance of one hundred thirty eight
and eighty hundredths (138.80) feet
to a post; thence along a fence, south
64 degrees 28 minutes 15 seconds
east, a distance of ninety nine and
nineteen hundredths (99.19) feet
to a post; thence still along a fence,
north 20 degrees 17 minutes 23 sec-
onds east, a distance of one hundred
forty eight and thirty one hundredths
(148.31) feet to an iron pin; thence
still along a fence, north 25 degrees
11 minutes 27 seconds east, a dis-
tance of one hundred ninety five and
twenty six hundredths (195.26) feet
to a point in the center line of thirty
three (33) feet wide Township Road
T-503, known as Sherwood Drive, at
the place of BEGINNING.
The above described tract of land
contains an area of one acre, more
or less.
HAVING THEREON ERECTED A
DWELLING KNOWN AS 357 SHER-
WOOD DRIVE, CARLISLE, PA 17015.
TAX PARCEL NO. 21-05-0431-
027.
BEING THE SAME PREMISES
WHICH Melissa A. Baranishyn by
deed dated 10/30/06 and recorded
10/31/06 in Cumberland County
Record Book 277 Page 1729, granted
and conveyed unto Michael R. Adams
and Nina L. Kreps.
TO BE SOLD AS THE PROPERTY
OF MICHAEL R. ADAMS AND NINA
L. KREPS ON JUDGMENT NO.
11-2697-CIVIL.
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.
L sa Marie Coyne, P ditor
SWORN TO AND SUBSCRIBED before me this
29 da of Jul 2011
Notary
NOTARIAL SE
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot-News Co.
2020 TAr:finology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
i4ePatriot News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
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:
07/15/11
Sworn to
. J 7....... ......
me the 1 §A61/ gf-August, 2011 A. D.
Public
COMMONWEAL Tip OF PENNSYLVANIA
=S.hmerrie otarial Seal E
Kisner, Notary public
Twp., Dauphin County
n Expires Nov. 26, 2011 1
Member, Pennsvlvania Association of Notaries
07/22/11
07/29/11
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
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 Agency (Tr) is the grantee the same having
been sold to said grantee on the 7 day of Se tep mber A.D., 2011, under and by virtue of a writ Execution
issued on the 1 day of June, A.D., 2011, out of the Court of Common Pleas of said County as of Civil
Term, 2011 Number 2697, at the suit of Pennsylvania Housing Finance Agency (Tr) against Michael R.
Adams & Nina L. Kreps is duly recorded as Instrument Number 201129271.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A -A
,A.D.
of Deeds
* Co m"On Expires ft FIM Ilmk C(Jsn 2014