HomeMy WebLinkAbout11-3799
Leon P. Haller, Esquire
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
717.234.4178
mtg@pkh.com
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY
Plaintiff
vs.
BRIAN SWEENEY AND SHANNON WATSON
NWA SHANNON SWEENEY
Defendants
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C+..rMLB RLAN) Ci 1.=° i l
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
I ? - Slot 9 e(V? k
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action
within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so
the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money
claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU "
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA
DE ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
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U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
Plaintiff
vs.
BRIAN SWEENEY AND SHANNON WATSON
N/K/A SHANNON SWEENEY,
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.
BRIAN SWEENEY AND SHANNON WATSON
N/K/A SHANNON SWEENEY,
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, BRIAN SWEENEY and SHANNON WATSON N/K/A SHANNON SWEENEY, are adult
individuals whose last known address is 101 APRIL DRIVE, CAMP HILL, PA 17011.
3. On or about, August 31, 2006, the said Defendants executed and delivered a Mortgage Note in the sum
of $147,829.00 payable to SLM FINANCIAL CORPORATION d/b/a SALLIE MAE MORTGAGE,
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 September 7, 2006 in Mortgage Book 1965, Page 1081 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 December 11, 2006 in
Book 732, Page 3303. 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: 101 APRIL DRIVE, CAMP HILL, PA 17011 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
September 01, 2010 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $23.34 per day
From 08/01/2010 To 05/01/2011
( based on contract rate of 6.0000%)
Late Charges $35.45
From 09/01/2010 to 05/01/2011
Escrow Deficit
Attorney's Fee at 5% of Principal Balance
TOTAL
$140,020.66
$6,371.82
$283.60
$491.52
$7,001.03
$154,168.63
"Together with interest at the per diem rate noted above after May 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 December 10, 2010 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the
December 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 6.0000% ($23.34 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: r I . V
PU CELL, KRUG & HALLER
Le 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)
ORIGINAL WATSON
NOTE Loan#:8570607034
MN: 100091085706070345
Case #:441-7840589-703
/
AUGUST 31, 2006
(Date] CAMP HILL
[City] PENNSYLVANIA
[State] j
1. r
101 APRIL DR, CAMP HILL, PA 17011
[Property Address]
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender"
means SLM FINANCIAL CORPORATION DBA SALLIE MAE MORTGAGE and its successors and assigns.
2. BORROWER'S PROMISE TO PAY, INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED FORTY-
SEVEN THOUSAND EIGHT HUNDRED TWENTY-NINE AND 00/100 Dollars (U.S. $147,829.00), plus interest, to
the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender,
at the rate of SIX percent (6.000%) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same
date as this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which might
result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Thne
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
OCTOBER 1, 2006. Any principal and interest remaining on the first day Of SEPTEMBER, 2036, will be due on that date,
which is call?titlie "Maturity Date."
(B) Place
Payment shall be made at 6000 COMMERCE PARKWAY SUITE A, MT LAUREL, NJ 08054 or at such place
as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $886.31. This amount will be part of a
larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the
order described in the Security Instrument.
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the
allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of
this Note. [Check applicable box.]
? Graduated Payment Allonge ? Growing Equity Allonge ? Other [Specify]
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount
prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If
Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless
Lender agrees in writing to those changes.
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
''=" " 36.69 Page 1 aft FHA Multistate Fined Rate Note -12/07
8570607034
4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount
of FOUR percent (4.000%) ofthe overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and
all accrued interest Lender may choose not to exercise this option without waiving its rights in the event of any subsequent
default In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in
full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As
used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable
law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the
right to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if
Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address
stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made
in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note
is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor,
surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights
under this Note against each person individually or against all signatories together. Any one person signing this Note may be
required to pay all ofthe amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
r.
k ?v A— -13
- OWER - SHANNON WATSON - DATE -
- B RROWER - BRIAN SWE - DATE
[Sign Original Only]
no.oy Page 2 of 2 FHA Multistate Fixed Rate Note -12101
ALLONGE TO NOTE
Loan Number: ,75Z0 6c/-?7D3
Borrower Name (s):
T-"
Property Address: /O/ .9 lel
?.9inv h/ P 1?oii
Note Date:
Loan Amount: /y7
Pay to the order of: 1-2E/c1/L?SU?dityJ/ ?f_ ?g? p????yy
Without recourse on this day of x,5'7` ??
--S-' C-1
?s?} S.eGGiE /l,?E
By:
Joanne M. ks
Vice Pre* ent
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: 01210275085
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): SHANNON SWEENEY
BRIAN SWEENEY
Secured by the real property located at: 101 APRIL DRIVE, CAMP HILL, PA 17011
Municipality of. CAMP HILL (PC RR NAME LEMOYNE-CAMP HILL)
Original Principal Amount: $147,829.00 County Recorded in: CUMBERLAND
Mortgage Recorded: September 7, 2006 Record Book: 1965 Page: 1081
Last Assignment to: PA Housing Finance Agency Record Book: 732 Page: 3303
IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of
Mortgage to be executed by its duly authorized officer. (Series: 095, PHFA) [BASSETT]
DATED: March 4, 2011 By: PENNS V IA HOUS G FIVANC AGENCY
Anthony J. Ju
Director of Accoun g a d L n Servicing
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On this, the?TM - day of 2011, before me, the undersigned officer, personally appeared
Anthony J. Julian, Director of Accounting and Loan 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.
Notary Public
CQMM OF FENNMVANIA
Notarial Seal
Kimberley A. Ayala, Notary Public
City of NaMstiurp, Dauphin County
MY Commission Expires )an. 15, 2015
CERTIFICATE OF RESIDENCE OF ASSIGNEE MEM PENNSnVANU ASSO(7g7ION 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, Pennsy nia 7105-5 57
t o ' ed Officer
C4- k ?i ? \\ 6(,
'ill that certain piece or parcel of land, eilaale •
Township) Cutnborland Count in the Borough of Camp Hill (formerly H
as follows, to wit: ys Pennsylvania, more particularly bounded and'descrlbed
BEGINNING at a'poifit on-the Eastern side of
hundred ten and fif April Drive which point is.one
Trindle Road ands-five hundredths (110.55)`f
of ..
eet South of the Southeast corner
on the hereinafter mentioned plan ofglots;'th North Nos.
*10 line of Lots s 3L mi and I2 .
along said division line one hundred thin six 65 degrees ed minutes East
feet to a point; thence South 20 degrees thirty-two and ixty.,one hundredth (132. b1) •
hundredths (78.13) feet to a point atthe2divisi nslinetofeLotsNeight and thirteen .12
and thence South 71 de irteen
grees i5. minutes west along said division line one hundredlthirty_
three and eighty-four hundredths (133.84) feet to a point on the
APz'i1 Drive; thence North 18 degrees 45 minutes West point
side of
April Drive sixty-five g . .s
the aforem
(65) feet to a point, the PLACE OF BEGINNING, ntioned
IT BEING.Lot No, 12, Block "Cn
3, recorded in and for the County of Cum
On Plan berland Lots a° Booknl?e Village Section:
56. Pages 54,55 and
UNDM AND SUBJECT to a seven and a half (7z) foot sewage easement alon .
the Northern line. Of said lot,
8
?.va_ '
HAVING SON erected a single dwelling known and numbered as.101 April
s
Pennsylvania
Housing Finance Agency Accounting & Loan Servicin
211 North Front Street, P.O. Box 15057
Harrisburg, PA 1 71 05-505 7
(800) 346-3.597 FAX (717) 780-3899
TTY (717) 780-1869
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
12/10/2010
RE: Account No. 1449040
SHANNON WATSON
BRIAN SWEENEY
101 APRIL DR
CAMP HILL, PA 17011-4904
RE: 101 APRIL DR
CAMP HILL, PA 17011-4904
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 101 APRIL DR, CAMP HILL, PA 17011-4904, IS IN SERIOUS
DEFAULT because you have not made the monthly payments of $1,158.00 for 9/2010 through 12/2010
for a total of $4,634.00. Late charges and NSF charges that have accrued to this date in the amounts of
$106.35 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 $3,840.35.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the
total amount of $3,840.35, plus any additional monthly payments, expenses and late charges which may
fall due during this period. Such payment must be made either by cash in our office, cashier's check,
certified check or money order and made at:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 NORTH FRONT STREET/P.O. BOX 15057
HARRISBURG, PA 17105-5057
1-800-822-7375 or TTY (800) 346-3597
If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to
accelerate the mortgage payments. This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the chance to pay off the original
mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY
(30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgageed
property.
If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the
mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal
proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay the reasonable
attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us,
which may also include our reasonable costs. If you cure the default within the thirty-day period, you will
not be required to pay attorney fees.
\I ?\ FHAACT/dtmdocs/ALSW
1
We may also sue you personally for the unpaid principal balance and all other sums due under
the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings
have begun, you still have the right to cure the default and prevent the sale at any time up to one hour
before the sheriffps foreclosure sale. You may do so by paying the total amount of the unpaid monthly
payments and any late or other charges then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale and perform any other requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff's sale could be held would be approximately five
months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment will be by calling us at the following number:
1-800-822-7375. This payment must be made payable in cash in our office, cashier's check, certified
check or money order and made payable to us at the address stated above.
You should realize that a Sheriff's sale will end your ownership of the mortgaged property and
your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be
started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY
HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A
BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID
PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE
ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had
occurred. However, you are not entitled to this right to cure your default more than three times in any
calendar year.
You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under
the mortgage documents, the nonexistence of a default or any other defense you believe you may have
to any such action.
If you maintain credit, life or disability insurance in connection with your mortgage loan, your
failure to pay premiums with your payments may have already resulted or may result in the future in the
lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is
cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the
insurance company and qualify for replacement insurance if you wish to retain it.
If you make partial payments on account of the delinquencies, we may accept them and apply
them to the delinquencies. However, such partial payments will not cure your default or reinstate your
loan. The loan will not be reinstated unless we receive the entire amount required to cure the default.
Sincerely,
-le", L
Mr. Thomas L. Gouker
Manager of Collections
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street/ P.O. Box 15057
Harrisburg, PA 17105-5057
TLG/
FH AACT/dtmdocs/ALS V/
Pennsylvania
Hiousin2 Finance Agency Accounting & Loan Servicin
211 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
12/10/2010
SHANNON WATSON
BRIAN SWEENEY
101 APRIL DR
CAMP HILL, PA 17011-4904
RE: Account #1449040
TO: SHANNON WATSON
BRIAN SWEENEY
101 APRIL DR
CAMP HILL, PA 17011-4904
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 NACA
2000 LINGLESTOWN RD. 1341 N DELAWARE AVE; SUITE 312
HARRISBURG, PA. 17110 PHILADELPHIA, PA. 19125
Phone:888-599-2227 Phone:888-297-5568
HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY
DEVELOPMENT
34 S. Duke St. ONE PENN CENTER;1617 JFK BLVD; SUITE 1550
York, PA 17401-1106 PHILADELPHIA, PA. 19103-1828
Phone: 800-864-4909 Phone:800-930-4663
TABOR COMMUNITY SERVICES
208 E King St.
Lancaster, PA 17608-1676
Phone: 717-397-5182
FHAACT/dtmdocs/ALSW
7160 3901 9849 1497 5054
TO: BRIAN SWEENEY
101 APRIL DR
CAMP HILL,PA 17011
i SENDER: BASSETT
REFERENCE: 1449040
PS Form 3800 Jammy 2005
RETURN Postw .44
RECEIPT Certified Fee 2.80
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Request for Military Status
Department of Defense Manpower Data Center
IF Military Status Report
j9ftk Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Apr-01-2011 13:29:23
Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
SWEENEY BRIAN 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).
A 14
flm? In . 1- A??_
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/l)is/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 4/1/2011
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 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:642LQOATU3
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/1/2011
Request for Military Status
Department of Defense Manpower Data Center
10 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Apr-19-2011 10:16:06
Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
WATSON SHANNON 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 t
Afty, IM. A??
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 htti)://www.defenselink.mil/fag/r)is/PC09SLDR.htmi. 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 4/19/2011
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:GB761OV071
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/19/2011
Request for Mi'itary Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Apr-01-2011 13:28:16
4.. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
SWEENEY SHANNON 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).
A 14
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 htt-p://www.defenselink.mil/fag?is/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 4/1/2011
Request for Mi'itary 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:EGQ7D3OK7Q
"ps://www.dm&.osd.mil/appj/scra/popreport.do 4/1/2011
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.. 4 3
By
Director of Accounting and Loan Servicing
SWEENEY 1449040
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
VS.
BRIAN SWEENEY AND
SHANNON WATSON N/K/A SHANNON SWEENEY,
DEFENDANT(S)
NO. 11-3 799-CIIV L
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
2C.)
t?g
I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on
41al b0 it , 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:
BRIAN S WEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
SHANNON WATSON N/K/A
SHANNON SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
101 APRIL DRIVE
CAMP HILL, PA 17011
By
PUR , KRUG & HALLER
AZ&r6ys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
HOWARD B. KRUG
LEON P. HALLER
JOHN W. PURCELL JR.
JILL M. WINEKA
LISA RYNARD
BRIAN SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
SHANNON WATSON N/K/A
SHANNON SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
101 APRIL DRIVE
CAMP HILL, PA 17011
6
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 2344178
FAX (717) 234-1206
HERSHEY
(717)533-3836
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court
of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate
will be exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be
divested by the sale and that you have an opportunity to protect your interest, if any, by bein tified of
said Sheriffs Sale.
By:
Haller PA I.D.15700
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION TRUSTEE
FOR THE PENNSYLVANIA HOUSING FINANCE
AGENCY,
PLAINTIFF
VS.
BRIAN SWEENEY AND
SHANNON WATSON N/K/A SHANNON SWEENEY,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 11-3799-CIIVL
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:
101 APRIL DRIVE
CAMP HILL, PA 17011
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 11-3799-CIIVL JUDGMENT AMOUNT $154,168.63
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
BRIAN SWEENEY AND SHANNON WATSON N/K/A SHANNON SWEENEY
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of
Common Pleas of the within County at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY
THE JUDGMENT
You may have legal rights to prevent your property from being taken away. A lawyer can advise
you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill (formerly Hampden
Township) Cumberland County, Pennsylvania, more particularly bounded and described as follows, to
wit:
BEGINNING at a point on the Eastrn side of April Drive which point is one hundred ten and fifty five
hundredths (110.55) feet South of the Southeast corner of Trindle Road and April Drive and at the
division line of Lots Nos. 10 and 12 on the hereinafter mentioned plan of lots; thence North 65 degrees
34 minutes East along said division line one hundred thirty two and sixty-one hundredths (132.61) feet
to a point; thence South 20 degrees 23 minutes East seventy eight and thirteen hundredths (78.13) feet to
a point at the division line of Lots Nos. 12 and 13; thence South 71 degrees 15 minutes West along said
division line one hundred thirty three and eighty-four hundredths (133.84) feet to a point on the Eastern
side of April Drive; thence North 18 degrees 45 minutes West along the aforementioned April Drive
sixty five (65) feet to a point, the place of BEGINNING.
BEING Lot No. 12, Block C on Plan of Lots of Trindle Village, Section 3, recorded in and for the
County of Cumberland in Plan Book 10, Pages 54, 55 and 56.
UNDER AND SUBJECT to covenants, easements and restrictions of record, including but not limited to
a seven and one half (7 '/z) foot sewage easement along the Northern line of said lot.
HAVING THEREO ERECTED A DWELLING KNOWN AS 101 APRIL DRIVE, CAMP HILL,
PA 17011.
TAX PARCEL: 01-21-0275-085.
BEING THE SAME PREMISES WHICH Linda Mae Martin and Dianne E. Hixon, Executrixes of the
Estate of Catherine Butt, by deed dated 8/31/06 and recorded 9/7/06 in Cumberland County Record Book
276 Page 2722, granted and conveyed unto Brian Sweeney and Shannon Watson. (Shannon Watson is
now known as Shannon Sweeney).
TO BE SOLD AS THE PROPERTY OF BRIAN SWEENEY AND SHANNON WATSON N/K/A
SHANNON SWEENEY ON JUDGMENT NO. 11-3799-CIIVL
7160 3401 4844 3036 2203
TO: SHANNON WATSON N/K/A
SHANNON SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
SENDER:
REFERENCE: NOS 09/07/11
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return ReceiEFee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
POSTMARK
%a
7160 3101 4844 3036 2210
TO: BRIAN SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
SENDER:
REFERENCE: NOS 09/07/11
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
-------- ------------
OSTMIt1iK C n?\A
9,9 1
i?
. - Leo ? 1`dD .
r
PENNSYLVANIA HOUSING FINANCE AGENCY v. BRIAN SWEENEY SHANNON WATSON N/K/A SHANNON
SWEENEY 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:
BRIAN SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
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:
SHANNON WATSON N/K/A
SHANNON SWEENEY
101 APRIL DRIVE
CAMP HILL, PA 17011
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Postmark:
P?5QS74
U'
C
s `ao?y?
' y?P,Es PosT1
I?
a r
A Awnw
z'
a ac"?asam> irtirv rrowts
$ 01.150
?. 0004284324 iU11 28 2011
MAILED FROM ZIP CODE 1 710 2
A
PENNSYLVANIA HOUSING FINANCE AGENCY v. BRIAN SWEENEY SHANNON WATSON N/K/A SHANNON
SWEENEY
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
101 APRIL DRIVE
CAMP HILL, PA 17011
?'O%es Posrq
e
NTNF Y H0%W S
0 2 1 ivi a 1.15°
00 4284324 -UN28 2011
MAILED FROM ZIP CODE ` 710 2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
sheriff ,, s~
r1r.. PR0Tr?,t.
r?Q TA f?'
Jody S Smith ?Lp"FP 12 Chief Deputy ?M
2? Q3
W Stewart ?. •:???? CUP?ERSY ND
Solicitor jj
US Bank Trust National Association
vs.
Brian Sweeney (et al.)
Case Number
2011-3799
SHERIFF'S RETURN OF SERVICE
06/23/2011 08:36 PM - Deputy Shawn Gutshall, 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 101 April Drive, Camp Hill, PA 170011, Cumberland County.
06/23/2011 08:36 PM - Deputy Shawn 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: Shannon
Watson at 101 April Drive, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County.
06/27/2011 Shawn 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: Brian Sweeney at
101 April Drive, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County.
08/26/2011 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: $2,991.44
September 12, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
a? L/
Coumvsuite Sner"t. ie,eo: Dft 1,
CUMBERLAND LAW JOURNAL
Writ No. 2011-3799 Civil
US Bank National Association
vs.
Brian Sweeney
Shannon Watson n/k/a
Shannon Sweeney
Atty.: Leon P. Haller
ALL THAT CERTAIN piece or par-
cel of land, situate in the Borough of
Camp Hill (formerly Hampden Town-
ship) Cumberland County, Pennsyl-
vania, more particularly bounded
and described as follows, to wit:
BEGINNING at a point on the
Eastrn side of April Drive which
point is one hundred ten and fifty
five hundredths (110.55) feet South
of the Southeast corner of Trindle
Road and April Drive and at the
division line of Lots Nos. 10 and 12
on the hereinafter mentioned plan
of lots; thence North 65 degrees 34
minutes East along said division line
one hundred thirty two and sixty-one
hundredths (132.61) feet to a point;
thence South 20 degrees 23 minutes
East seventy eight and thirteen hun-
dredths (78.13) feet to a point at the
division line of Lots Nos. 12 and 13;
thence South 71 degrees 15 minutes
West along said division line one
hundred thirty three and eighty-four
hundredths (133.84) feet to a point
on the Eastern side of April Drive;
thence North 18 degrees 45 minutes
West along the aforementioned April
Drive sixty five (65) feet to a point,
the place of BEGiNNiNG.
BEING Lot No. 12, Block C on Plan
of Lots of Trindle Village, Section 3,
recorded in and for the County of
Cumberland in Plan Book 10, Pages
54, 55 and 56.
UNDER AND SUBJECT to cov-
enants, easements and restrictions
of record, including but not limited
to a seven and one half (7 `/2) foot
sewage easement along the Northern
line of said lot.
HAVING THEREO ERECTED A
DWELLING KNOWN AS 101 APRIL
DRIVE, CAMP HILL, PA 17011.
TAX PARCEL: 01-21-0275-085.
BEING THE SAME PREMISES
WHICH Linda Mae Martin and Di-
anne E. Hixon, Executrixes of the
Estate of Catherine Butt, by deed
dated 8/31/06 and recorded 9/7/06
in Cumberland County Record
Book 276 Page 2722, granted and
conveyed unto Brian Sweeney and
Shannon Watson. (Shannon Watson
is now known as Shannon Sweeney).
TO BE SOLD AS THE PROPERTY
OF BRIAN SWEENEY AND SHAN-
NON WATSON N/KIA SHANNON
SWEENEY ON JUDGMENT NO. 1
1-3799-CIIVL.
64
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' 0A ,
Lisa Marie Coyn , Editor
SWORN TO AND SUBSCRIBED before me this
29 da of Jul 2011
Notary
NOTARI:BER AL
DEBORAH LLINS
Notary lic
CARLISLE BOROUGH, LAND COUNTY
My Com mission Es Apr 28, 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
at Patr1*0tAyXtW5
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said 'Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
07/15/11
07/22/11
07/29/11
? Y \
Sworn to and s ibed befo a th 18 ugust, 2011 A. D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L Klsrw, Notary Public
Lower Paxton Twp., Dauphin County
My Comml?lon Expires Nov. 26, 2011
Member, Pennsylvania Association of Notaries
us 2011
'Win
' ?^non
Mr. Leon,,, V
ALL
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