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Home My WebLink About12-3974 Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com !. G .. t v CUWE EFi A.k' J i NG. -3y7 y U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. ANDREW M. BAILEY Defendant 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, 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. COUNTY CUMBERLAND CUMBERLAND COUNTY BAR ASSOCIAT ON 32 SOUTH BEDFORD STREET 03`, CARLISLE, PA 17013 C/(--# 1775-Y3 717-249-3166 /Le ?, 77136 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. ANDREW M. BAILEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ANDREW M. BAILEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 and as amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through the Pennsylvania Housing Finance Agency ("Agency"), its appointed Limited Power of Attorney, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. The Limited Power of Attorney executed October 4, 2006 between the Plaintiff and the Agency is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 11, 2006 in Book 731, Page 421. The Limited Power of Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 2. Defendant, ANDREW M. BAILEY, is an adult individual whose last known address is 505 NORTH WEST STREET, CARLISLE, PA 17013. 3. On or about, October 15, 2010, the said Defendant executed and delivered a Mortgage Note in the sum of $88,704.00 payable to VISION MORTGAGE CAPITAL, a division of CONTINENTAL 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, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 19, 2010 as Instrument Number 201029902 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 22, 2010 as Instrument Number 201030407. The Assignment was re-recorded on March 1, 2011 as Instrument Number 201106774 in order to correct the recording date of the Mortgage on the originally recorded Assignment. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording, which Assignment is attached hereto and marked Exhibit "B". The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 505 NORTH WEST STREET, CARLISLE, PA 17013 and is more particularly described in Exhibit "C" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on July 01, 2011 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $87,913.45 Interest at $11.60 per day $4,582.00 From 06/01/2011 To 07/01/2012 ( based on contract rate of 4.7500%) Accumulated Late Charges $55.53 Late Charges $18.51 $222.12 From 07/01/2011 to 07/01/2012 Escrow Deficit $1,423.34 Attorney's Fee at 5% of Principal Balance $4,395.67 TOTAL $98,592.11 "Together with interest at the per diem rate noted above after July 01, 2012 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 Defendant by letter dated September 27, 2011 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the September 27, 2011 Act 6 Notice is attached hereto and marked Exhibit "D". 9. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non-active military duty is 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 4.7500% ($11.60 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: PURL L, 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) LOAN It 1004001669 NOTE I FHA -04 No. I 446-0470723/703 Multistate L- ??---.. -_ J OCTOBER 15, 2010 Caap Hill, PENNSYLVANIA (City] IBtste] 505 North Hest Street, Carlisle, PA 17013 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means VISION MORTGAGE CAPITAL, A DIVISION OF CONTINENTAL BANK. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of .....EIGHTY EIGHT THOUSAND SEVEN RUNDRED FOUR AND NO/100•••••.•••• ................................. Dollars (U. S. S88,104.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the ban proceeds by Lender, at the rate of POUR AND THREE-POURTNS percent ( 4.7501 ) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the 1sT day of each month beginning on DECEMBER 1, 2010. Any principal and interest remaining on the 18T day of ROVEMER, 2040 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 620 M OERMAHTONN PIKE1350 PLYMOUTH ME6TING,PA 19462 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. $462.72. 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 R an allong• 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 Nota as if the allongeware 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 forth* 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 Lander 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 15 calendar days after the payment is due, Lender may collect a late charge in the amount of POUR percent ( 4.0004 ) of the overdue amount of each payment. (B) Default 9 Borrower defaults by failing to pay in full any monthly payment then Lender may, except as limited by regulations of the Secretary it the use 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 wilhoutwalving its rights In the event of any subsequent default. In many circumstances regulations issued by the, Secretary will IenR Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not penMttad by HUD regulations. As used in this Note, "Secretary* means the Secretary of Housing and Urban Development or his or her disc' FHA Mutd.tat. Fixed R.I. Not. - 10/95 lapis la r - O„ 6,,. Da-M.. I... Page I of 2 i Gch,6t f li' 0 k (C) Payment of Costs and Expenses LO" 11, 1004001668 It Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' lees 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 it 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(8) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the ! rms d-e nNote. drav N eeilFHA rAualat,N Fixed Rat, Now. f tins Ook- Doeum w. inc. Page 2 of 2 Pe700N0T Ostia ALLONGE TO NOTE LOAN Nt 1006001666 LOAN AMOUNT. $86,704.00 PROPERTY ADDRESS1 505 Mortb West Street Carlisle, PA 17011 ALLONGE TO NOTE DATED OCTOBER 15, 2010 IN FAVOR OF VISION MORTGAGE cAnITAL, A Division or CONTINENTAL BARK AND EXECUTED BY Andrew M Bailey PAY TO THE ORDER OF PENMSILVANIA HOUSING FINANCE AGENCY VISION MORTGAGE CAPITAL, A DIvISIOS OP COsTINEMTAL BANK BY D.--" eLSU LFF10S 0 1095-2003 O.N. Do 'W t., IM. ON13 0301 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: 06201798076 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): ANDREW M. BAILEY Secured by the real property located at: 505 NORTH WEST STREET, CARLISLE, PA 17013 Municipality of: CARLISLE Original Principal Amount: $88,704.00 County Recorded in: CUMBERLAND Mortgage Recorded: October 19, 2010 Instrument#: 201029902 Last Assignment to: PA Housing Finance Agency Instrument#: 201106774 IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 109, PHFA) [GUTSHALE] DATED: May 11, 2012 By: PENNS V HOUSING INAl?j E AGENCY Anthony J. Juli Director of Accounting and Loan Servicing COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the I day o 2012, before me, the undersigned officer, personally appeared Anthony J. Julian, Director of Accountin d 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. UL A'" ? A (z? A !j Notary Public COMMONWEAL,rii OF PENNMVANIA Notarial seal l(i erlA. Ayala, Notary public aty Of Harrisburg, Dauphin County My Cron Jan. 15, 2015 MEMBER PBINSYLVANIA ASSOQATION OF NOTARIES CERTIFICATE OF RESIDENCE OF ASSIGNEE 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, Penns vama 17105-5057 Aut rizjA7 Officer ALL "THAT CERTAIN lot or piece of ground situate in Carlisle Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey made `larch 28, 1973, by Thomas A. Neff, Jr., Registered Surveyor, as follows: BEGINNING at a point marked by a '/. inch drill hole in the eastern side of North West Street, said point being 25.00 feet north of "A" Street; thence extending from said point, North 16 degrees 10 minutes East, 25.00 feet to a point on line of lands now or formerly of Bertha Berry; thence along the same, South 77 degrees East, 190.00 feet to a point marked by a %. inch drill hole in the western side of a 16 feet wide public alley; thence along the same, South 13 degrees 10 minutes West, 25.00 feet to a stake on line of lands now or formerly of Harry C. Eckrich; thence along the same and passing through the center of a partition wall, North 77 degrees West, 190.00 feet to the point and place of BEG MING. BEING Lot No. 1 I in Block No. 9, according to the Plan of Lots laid out and adopted by the Carlisle Land and Development Company, said Plan recorded in Miscellaneous Docket 11, Page 575. HAVING thereon erected a two and one-half (2'/z) story stone and frame dwelling numbered 505 N. West Street, Carlisle. Pennsylvania. , Pennsylvania Housing Finance Agen Ac'eu )ntinLy & Loan Servicing (800) 346-3597 FAX (717) 780-3899 TTY (717) 780-1869 North Front .Street, P. O. Box 15057 11urrishurg, PA 17105-5057 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 4/30/2012 RE: Account No. 2334373 ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE, PA 17013-1965 RE: 505 NORTH WEST STREET CARLISLE, PA 17013-1965 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 505 NORTH WEST STREET, CARLISLE, PA 17013-1965, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $681.00 for 7/2011 through 4/2012 for a total of $6,810.00. Late charges and NSF charges that have accrued to this date in the amounts of $240.63 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 $7,210.63. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $7,210.63, 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 properly. 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 4 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 h ll-J ` FHAACT/dtmdocs/ALSV/ We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriffps foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-822-7375. This payment must be made payable in cash in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND 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 lt. 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/ FH AACT/dtmdoc s/ALSV/ ,rennsylvania HousingFinance Agency NOTICE 4/30/2012 ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE, PA 17013-1965 RE: Account #2334373 .?Ccu)ntin & Loan Servicing 'I I /North Frow Street, l'. (). Ro.s 150.5 7 Ilrurr.?hiu,?, PA 17105-5057 (800) 346-3597 FAX (717) 780-3899 I'TY (717) 780-1869 TO: ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE, PA 17013-1965 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 F H AACT/dtmdocs/ALSV/ *** 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 FH AACT/dtmdocs/AL SV/ •- r ? ,f 7196 9008 9y'y1 4385 5771 M ANDREW M BAILEY 505 NORTH WEST STREET CARLISLE,PA 17013 SENDER: GUTSHALE REFERENCE: 2334373 RETURN OO- RECEIPT Certified Fee SERVICE Rstwn Receipt Fee .? Y Nn ,4,4 I ?4 0% N N N rl r-4 \ \ \ 0% ?7 O i !f1 N r+ n M O N N o o 'r ?D 1 do \.. \\ o 1 w •• v M n 00 i M M Ln 3 1 a_.? N OO /1 ? i O O N Q J •••? C VI s] in A I M in N N O N N 1 ?o V• O O O L w 4. \ 1 A O 134 .. C Ir N I O M O rl M O N 1 rl r-1 O +-1 M N N 0% L C ++ N N n n o U N 7 A A w ZO Z 00 A N \ \ 4- J N N •• } o •• } O 4J N A .? o rl ++ 4 1 N 0r-4 m O M L. 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'i K U1 Q 7 Co N C L .i r1 L .i M O L r-4 L M W 0 > F f0 •• L C LM L CL f0 O •.a 'O P N w o:Q 00. O a O e 11 L v My 0 M M L/1U Ju m a1W to Wa.Q X4 J Li. CL Total Postage & Fees U$ o"atal Qmftmas POSTMARK OR DATE Receipt for Certified Maim" NO w" we COL wno Provided 00 Nat UN for Ind Md 2 Article Nur _ ANDREW M BAILEY 505 14ORTII WEST S`1.'REE`i' CARLISLE, PA 1701.3 GU`I'SHALE 3811, January 2005 m V. ? ti _s e? Domestic Retum Receipt 7196 9008 9111 1436 1904 M: ANDREW M BAILEY 505 NORTH WEST STREET CARLISLE,PA 17013 1 a SENDER: GUTSHALE C 1 oC = o 4; J.' REFERENCE: 2 3 3 4 3 7 3 41, $ ? x c; a ?• o z `• c? LL ?I PS Form 380 0 2006 X s e ; ,; RETURN Postage 'j RECEIPT Certified Fee ` W a2 o ii SERVICE Return Receipt Fee . , `" r a m o; L 1: Restricted De" W CA <U! Total Postage 1E Fees t,5 ,n W H RS rh- c US Poew Services POSTMARK OR DATE/ M w 'a•l? ..al s = - o a I` Receipt for z '" H W r-4 , Certified Mail ` w m o No Iraumnw Covem9e Pro~ .? ? -o x o c Do Not Use for kaamatiord Mai u [1 W .? L_----------------- _---------------------- _.__ ------ _------------------ _------------ ? ?? ,? S p u1 r r- a Z -- .? -- _ z a Q m r` to P4 E LL M r C) fh LL LL D r) to U (V c N ai v +- a o J -r ?O a L v1 1, J O Q . F _ •• •• lLl ,••. .. N .. U l11 U Q a+ C H O t11 n=3 cow > F C M •. L .-i •.? L .-i •.q a L L a M L a f0 O 9 .•i L -10 N 01 W G1 1 Q Ix 7 W0 O J CL U O a: M O a !• L 9 COW WOOW WriQ O 9 EQ N J M M LL 6. Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: BAILEY First Name: ANDREW M Active Duty Status As Of: Jun-03-2012 Results as of : Jun-03-2012 03:47:11 SCRA 2.2 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response re9ecls the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Dale Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HlsfHer Unit Was Notified of a Future Cali-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or hlslher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 41131 )4. 0 01160,0i'_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. PENNSYLVANIA HOUSING FINANCE AGENCY, Attorney-in-Fact for U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Dated &/7//d1- By Anthoh?" li? Di or of Accounting & Loan Servicing or the Penns ania Housing Finance Agency, Attorney-in-Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency BAILEY 2334373 S U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff(s) V5. ANDREW M. BAILEY Defendant(s) ry IN THE COURT OF COMMON PLEAS OF t = r?i CUMBERLAND COUNTY, PENNSYLVANIA i ?- i 3 ! ! Ci il -, v NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. 6/22/12 Date Respectful itt Leon 'f. Haller Jill M. Wineka Attorney for Plaintiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 PA ID 15706 / 58802 U.S. BANK NATIONAL ASSOCIATION AS ; IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA ; CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff(s) VS. ANDREW M. BAILEY Defendant(s) REQUEST FOR CONCILIATION CONFERENCE Civil Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendants Counsel/Appointed Date Legal Representative Signature of Defendant Signature of Defendant Date Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes E] No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ? No ? Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $, Date of Last Payment: Primary Reason for Default: Date You Closed Your Loan: Included Taxes and Insurance: Is the loan in Bankruptcy? Yes E] No E] If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Home: $ Other Real Estate: $ Retirement Funds: $ Investments: $ Checking: $ Savings: $ Other: $ Automobile #1: Model: Amount owed: Automobile #2: Model: Amount owed: Other transoortation (automobiles, boats, motorcycles) Year: Amount owed: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. 2. Borrower Pay Days: Value: Model: Value: Monthly Gross Monthly Gross Monthly Gross Monthly Amount: Monthly Amount: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paving) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Autolnsurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Payment Cable N Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Email: Value: Value: Year: Yea r: Monthly Net Monthly Net Monthly Net Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: [/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed SHERIFF'S OFFICE OF CUMBERLAND COUNTY 17 `LL??° t r E Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor oFrK'E OF1,F ='ERIFF 2012 JUL 16 AEA 8: 48 CU PENNSYLVAN A T,? US Bank National Association Case Numbe vs. Andrew M. Bailey 2012-3974 SHERIFF'S RETURN OF SERVICE 06/26/2012 06:41 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made diligent search and inquiry for the within named defendant to wit: Occupant of 505 N. West Street, Carlisle, Pennsylvania 17013, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Occupant. Request for service at 505 N. West Street, Carll Pennsylvania 17013 is only occupied by Andrew M. Bailey. ROBIERT BITNE 06/26/2012 06:41 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2012 at 1841 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notic of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Andre M. Bailey, by making known unto himself personally, at 505 N. West Street, Carlisle, Cumberland Cou ty, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and coned copy of the same. SHERIFF COST: $55.00 June 28, 2012 ROBERT BITNER, DEPUTY SO ANSWERS, Gn• RON R ANDERSON, SHERIFF (04 CourtySuite ghentt Teie<?seft. 6n:. U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIViL ACTION LAW VS. NO. 12-3974 '' ~' -ts.3 ANDREW M. BAILEY, ~~ DEFENDANT(S) MORTGAGE FORECLOSURE ~r~-.' --~r- PRAECIPE ~~ .,"~_ G TO THE PROTHONOTARY OF THE WITHIN COUNTY: v .,. Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendants) v O a Z :~~ , ~tr`~ a ~-', ~~~' c=, .._., rx. ANDREW M. BAILEY for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance $87,913.45 Interest $4,582.00 Per diem of $11.60 From 06/01 /2011 To 07/01 /2012 Accumulated Late Charges $55.53 Late Charges $222.12 ($18.51 per month to 07/01/2012) Escrow Deficit $1,423.34 5% Attorney's Commission $4,395.67 TOTAL $98,592.11 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HAL By _ `%/~Haller PA LD. # 1570 19 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~.~ (~lloS ~~~83~3 ~~~~ ~ U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. ANDREW M. BAILEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW s ~ ,°., c~ ~ . - - NO. 12-3974 -a3 N ~~.{ Zm p rj,.'! IN MORTGAGE FORECLOSURE ~ ~ •c ..,., _ -< r N r ~ ~, r . ~a ° d ~ c~ C ~ ~` ~ . ~~. r_ -,~. , ~ , CERTIFICATE OF SERVICE `' ~" ~' r_` =~ ~._ PURSUANT TO PA. R.C.P. 237.1 ....~ ~ I hereby certify that on September 11, 2012 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Hall A I.D. # 15700 Attorne r Plaintiff Purce ,Krug & Haller 1719 North Front Street Harrisburg, PA 17102 -' ~ U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. ANDREW M. BAILEY Defendant DATE OF THIS NOTICE: September 11, 2012 TO: ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3974 CIVII., ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FHtM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, G & H LER B LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ANDREW M. BAILEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 12-3974 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SV ~~`3 C ~-T-. ^ ' r ~ ~- ~ - , s$„ ` 1 ! y r T w,..y Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ~ day of~ ~~~ 20~ otary ublic . HALLER, ESQUIRE WRIT OF EXECUTIQN and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-3974 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U. S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff (s) From ANDREW M. BAILEY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $98,592.11 L.L.: $.50 Interest $2,794.43 PER DIEM OF $11.60 TO SALE DATE 3/6/13 Atty's Comm: Due Prothy: $2.25 Atty Paid: $206.25 Plaintiff Paid: Date: 11/21/12 (SPaI) KEQ[1ESTING PARTY: Other Costs: LATE CHARGES - $148.08 $18.51 PER MONTH TO SALE DATE 3/6/13 ESCROW DEFICIT - $1,801.44 _~l vid Jam. ~~el) David .Buell, Prothonotar i By: Deputy Name: LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG &HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW AT NO. 12-3974 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. ANDREW M. BAILEY, DEFENDANT(S) TOTAL WRIT $103,336.06 *Plus additional interest, late charges and other costs to date of sheriff s sale. SALE DATE: Wednesday, March 06, 2013 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk- Other Costs PRAECIPE FOR WRIT OF EXECUTION -MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above Date: November 15, 2012 Attorney for Plaintiff 1719 North Front Street eon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717)234-4178 WRIT OF EXECUTION -MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: Total Judgment Amount $98,592.1 l Interest $2,794.43 Per diem of $11.60 to sale date 3/6/2013 Late Charges $148.08 $18.51 per month to sale date 3/6/2013 Escrow Deficit $1,801.44 ~ C ,~, c, ,--. -r_' ~ ~ ~ .-;. _. cn r- ""c .,~ r r '_ ~ -, _ a ~ - ~ .~. ~ti: ~ ~ ~`:~ _ ,.~ ~ r- ~. , -'~ To satisfy the judgment, interest and costs in the above captioned case, you. are directed to levy upon and sell the property described in the attached description known as 505 NORTH.~TREET CARLISLE, PA 17013 ~ Date: ~ ss .~ ~F Ic~3.7~ <<,. ICo. SD ~` •, ~. 50 << <, ~-~~~ ~S ARY/CLERK CIVIL DIVISION SS BY DEPUTY ~„ sc~ u~ ALL THAT CERTAIN lot or piece of ground situate in Carlisle Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey made March 28, 1973 by Thomas A. Neff, Jr., Registered Surveyor, as follows: BEGINNING at a point marked by a `/a inch drill hole in the eastern side of North West Street, said point being 25.00 feet north of "A" Street; thence extending from said point, North 16 degrees 10 minutes East, 25.00 feet to a point on line of lands now or formerly of Bertha Berry; thence along the same, South 77 degrees East, 190.00 feet to a point marked by a'/a inch drill hole in the western side of a 16 feet wide public alley; thence along the same, South 13 degrees 10 minutes West, 25.00 feet to a stake on line of lands now or formerly of Harry C. Eckrich; thence along the same and passing through the center of a partition wall, North 77 degrees West, 190.00 feet to the point and place of BEGINNING. BEING Lot No. 11 in Block No. 9, according to the Plan of Lots laid out and adopted by the Carlisle Land and Development Company, said Plan recorded in Miscellaneous Docket 11, Page 575. HAVING THEREON ERECTED A TWO AND ONE HALF STORY STONE AND FRAME DWELLING KNOWN AS 505 NORTH WEST STREET, CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Matthew R. Appleby and Catherine A. Appleby by deed dated 10/15/2010 and recorded 10/19/2010 in Cumberland County Instrument No. 201029901, granted and conveyed unto Andrew M. Bailey. TO BE SOLD AS THE PROPERTY OF ANDREW M. BAILEY ON JUDGMENT NO. 12-3974 ASSESSMENT NO. 06-20-1798-076 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGF,NCY, PLAINTIFF V S. ANDREW M. BAILEY, DEFENDANT(S) I1V THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL~NiA, _~ -a 3 y CIV[L ACTION LAW ~~ , ~~' 2~ ~ r' ~; NO. 12-3974 ~ r- om ^~ ~ ?'if t - ~ d E==; b G ~ T ~' IN MORTGAGE FORECLOSUR~~ ~ ~-'~ .~ O '~ "'-,, ~ ---s _., AFFIDAVIT PURSUANT TO RULE 3129.1 '`~ ~' The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 505 NORTH WEST STREET CARLISLE, PA 17013: Name and address of the Owner(s) or Reputed Owner(s): ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN a 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 505 NORTH WEST STREET CARLISLE, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to aut itie Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 15, 2012 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 12-3974 ANDREW M. BAILEY, I IN MORTGAGE FORECLOSURE DEFENDANT(S) 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, March 06, 2013 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 C""~ `U y`"' a' ti ~ ~ _-_~= v`i~ ~ ~~' -c.b ~v -~ °''_ r „~ -~ ~, "C G { Vic;' 2 *~-,_; ., *~ ~; c, n-; ,-- .t~. 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: 505 NORTH WEST STREET CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-3974 JUDGMENT AMOUNT $98,592.11 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ANDREW M. BAILEY A SCHEDULE OF DISTRIBUTION, being a list of the persons andJor 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 CAU_ SE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot or piece of ground situate in Carlisle Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey made March 28, 1973 by Thomas A. Neff, Jr., Registered Surveyor, as follows: BEGINNING at a point marked by a'/4 inch drill hole in the eastern side of North West Street, said point being 25.00 feet north of "A" Street; thence extending from said point, North 16 degrees 10 minutes East, 25.00 feet to a point on line of lands now or formerly of Bertha Berry; thence along the same, South 77 degrees East, 190.00 feet to a point marked by a'/4 inch drill hole in the western side of a 16 feet wide public alley; thence along the same, South 13 degrees 10 minutes West, 25.00 feet to a stake on line of lands now or formerly of Harry C. Eckrich; thence along the same and passing through the center of a partition wall, North 77 degrees West, 190.00 feet to the point and place of BEGINNING. BEING Lot No. 11 in Block No. 9, according to the Plan of Lots laid out and adopted by the Carlisle Land and Development Company, said Plan recorded in Miscellaneous Docket 11, Page 575. HAVING THEREON ERECTED A TWO AND ONE HALF STORY STONE AND FRAME DWELLING KNOWN AS 505 NORTH WEST STREET, CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Matthew R. Appleby and Catherine A. Appleby by deed dated 10/15/2010 and recorded 10/19/2010 in Cumberland County Instrument No. 201029901, granted and conveyed unto Andrew M. Bailey. TO BE SOLD AS THE PROPERTY OF ANDREW M. BAILEY ON JUDGMENT NO. 12-3974 ASSESSMENT NO. 06-20-1798-076 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4 ��x, of t ax�r�tr�r/fir �ji TH PR0 i 0, Jody S Smith Chief Deputy 10013 MAY —6 A14 Richard W Stewart Solicitor =ark t F CUMK7RLAt4D COUti p?' PENNSYLVANIA, US Bank National Association Case Number vs. 2012-3974 Andrew M. Bailey SHERIFF'S RETURN OF SERVICE 12/28/2012 05:17 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 505 North West Street, Carlisle, PA 17013, Cumberland County. 12/28/2012 05:17 PM - 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: Andrew M. Bailey, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found"at 505 North West Street, Carlisle, PA 17013, address is vacant. 01/25/2013 08:38 PM - Deputy Shawn Harrison, 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: Andrew M. Bailey at 249 W. North Street, Carlisle, PA 17013, Cumberland County. 03/06/2013 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, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Leon Haller, on behalf of US Bank National Association Trustee for the Pennsylvania Housing Finance Agency, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $890.27 SO ANSWERS, KZ `"- April 30, 2013 RONNY R ANDERSON, SHERIFF 9o1,03 .;our Y's re Si`-f. i,T soa,Ir,c COPY" U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 12-3974 ANDREW M.BAILEY, IN MORTGAGE FORECLOSURE DEFENDANT(S) AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action,by its attorneys, Purcell, Krug& Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 505 NORTH WEST STREET CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ANDREW M. BAILEY 505 NORTH WEST STREET CARLISLE,PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in(1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 505 NORTH WEST STREET CARLISLE, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein ar subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to aut sties n P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 15, 2012 U.S. BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 12-3974 ANDREW M. BAILEY, IN MORTGAGE FORECLOSURE DEFENDANT(S) 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, March 06,2013 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: 505 NORTH WEST STREET CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-3974 JUDGMENT AMOUNT $98,592.11 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ANDREW M. BAILEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot or piece of ground situate in Carlisle Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey made March 28, 1973 by Thomas A. Neff, Jr.,Registered Surveyor, as follows: BEGINNING at a point marked by a 'l4 inch drill hole in the eastern side of North West Street, said point being 25.00 feet north of"A" Street; thence extending from said point,North 16 degrees 10 minutes East, 25.00 feet to a point on line of lands now or formerly of Bertha Berry; thence along the same, South 77 degrees East, 190.00 feet to a point marked by a Il4 inch drill hole in the western side of a 16 feet wide public alley;thence along the same, South 13 degrees 10 minutes West, 25.00 feet to a stake on line of lands now or formerly of Harry C. Eckrich; thence along the same and passing through the center of a partition wall,North 77 degrees West, 190.00 feet to the point and place of BEGINNING. BEING Lot No. 11 in Block No. 9, according to the Plan of Lots laid out and adopted by the Carlisle Land and Development Company, said Plan recorded in Miscellaneous Docket 11, Page 575. HAVING THEREON ERECTED A TWO AND ONE HALF STORY STONE AND FRAME DWELLING KNOWN AS 505 NORTH WEST STREET, CARLISLE, PA 17013 BEING THE SAME PREMISES WHICH Matthew R. Appleby and Catherine A. Appleby by deed dated 10/15/2010 and recorded 10/19/2010 in Cumberland County Instrument No. 201029901, granted and conveyed unto Andrew M. Bailey. TO BE SOLD AS THE PROPERTY OF ANDREW M. BAILEY ON JUDGMENT NO. 12-3974 ASSESSMENT NO. 06-20-1798-076 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-3974 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff(s) From ANDREW M.BAILEY (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $98,592.11 L.L.: $.50 Interest $2,794.43 PER DIEM OF$11.60 TO SALE DATE 3/6/13 Atty's Comm: Due Prothy:$2.25 Atty Paid: $206.25 Other Costs:LATE CHARGES-$148.08 $18.51 PER MONTH TO SALE DATE 316113 ESCROW DEFICIT-$1,801.44 Plaintiff Paid: Date: 11/21/12 CLV-d David Buell,Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LEON P. HALLER,ESQUIRE Address: PURCELL,KRUG& HALLER 1719 NORTH FRONT STREET HARRISBURG,PA 17102 TRUE COPY FROM RECORD In Testimony whereof,I here unto set my hand Attorney for: PLAINTIFF and the seal of said Co tt Cat Carlisle,Pa. This a 1 day of V 2012 Telephone: 717-234-4178 prothonotary Supreme Court ID No. 15700 riOI� �,�� on On November 28, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough , Cumberland County, PA, Known and numbered as, 505 North West Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 28, 2012 By: Real Estate Coordinator �✓ CUMBERLAND LAW JOURNAL Writ No. 2012-3974 Civil US Bank National Association vs. Andrew M.Bailey Atty.: Leon P. Haller ALL THAT CERTAIN lot or piece of ground situate in Carlisle Borough, Cumberland County, Pennsylvania, described in accordance with a sur- vey made March 28, 1973 by Thomas A. Neff, Jr., Registered Surveyor, BEING Lot No. 11 in Block No.9,ac- cording to the Plan of Lots laid out and adopted by the Carlisle Land and Development Company, as recorded in Miscellaneous Docket II,Page 575, and HAVING THEREON ERECTED A TWO AND ONE HALF STORY STONE AND FRAME DWELLING KNOWN AS 505 NORTH WEST STREET, CAR- LISLE,PA 17013. ASSESSMENT NO. 06-20-1798- 076. Cumberland County Instrument No. 201029901, granted and con- veyed unto Andrew M. Bailey. TO BE SOLD AS THE PROPERTY OF ANDREW M. BAILEY ON JUDG- MENT NO. 12-3974. 18 y 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: January 25, February 1, and February 8, 2013 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. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this da of Februar 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 r * The Patriot-News Co. 2020 Technology Pkwy e atr1otwXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Marianne Miller, 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: t An012-W4 CIO 01/22/13 U t1ihlSwd A"ocla*m diwil„ 01/29113 Loon P.Maillor 02/05113 ALL THAT CERTAIN let or Piece of ground situate is Carte Borough, . . . . . . . . . . . . . . . • . . . Fen1 ,de=Ard in acra with a' Mares 1 Sworn to and subs ribed before me thi 14 day of February, 2013 A.D. A.Neff,Jr., Registered Surveyor;BEING Lot No. in Block NO,a=1&g to fire Plan of Lots _ laid out and adopted by the Carlisle Land and Development Company,as recorded in 0 U C tisisce$aneotp Docket II, Page 575, and HAVING 'THEREON E$ECTED A TWO AND ONE STORY STONE, AND FRAME ' CXJM F,AI.TH OF PENNSYLVANIA KNOWN AS 505 NORTH Notarial Seal EG EEI;CARLISI;B,PA 17013 Hotly Lynn Warfel,Nota Public NT NO.06-2061798-076 Notary IC04114 Inshtiment No., Washington Twp.,Dauphin County 2010299111,•granted and wuveyw unto Gammisslon Expires Dec.12,2016 Andrew M.Bailey. MEMBER,PENNSYLVANIA ASSOCIATION or:NOTARIES TO BE SOLI?AS THE PROPERTY OF ANDREW M,HARZY ON JUDGMENT NO.12-3974 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 US Bank National Association Trustee for the Pennsylvania Housing Finance Agency is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the 21st day of November, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 3974, at the suit of US Bank National Association as Trustee for the Pennsylvania Housing Finance Agency against Andrew M. Bailey is duly recorded as Instrument Number 201314709. IN TESTIMONY WHEREOF, I have hereunto set my hand 9 and seal of said office this day of A.D._ 0 A r G ecorder of Deeds Of deed CaM CxW PA My ExpireseFmMax*dJan.Z014