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HomeMy WebLinkAbout12-3975Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com U i 1 h1 ?faj i ?t? P N,, /.2- 3975-, ?4,& U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTI?D, 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 FL 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 DERECHIOS 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. _ d / j CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET (?L 15r? CARLISLE, PA 17013 717-249-3166 6) U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP, 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, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 0a Iz-3 y75 ? -/ COMPLAINT IN MORTGAGE FORECLOSURE 1. 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(8). 2. Defendants, ARSENE C. BANGOUP and VIRGINIA L. BANGOUP, are adult individuals whose last known address is 1877 DOUGLAS DRIVE, CARLISLE, PA 17013. 3. On or about, March 31, 2008, the said Defendants executed and delivered a Mortgage Note in the sum of $123,556.00 payable to SOVEREIGN BANK, which Note is attached hereto and marked Exhibit "A„ 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on April 1, 2008 as Instrument Number 200809871 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 April 1, 2008 as Instrument Number 200809872. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording, which Assigmment 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: 1877 DOUGLAS DRIVE, CARLISLE, PA 17013 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 January 01, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $117,232.49 Interest at $18.72 per day $3,968.64 From 12/01/2011 To 07/01/2012 ( based on contract rate of 5.7500%) Accumulated Late Charges $28.84 Late Charges $28.84 $173.04 From 01 /01 /2012 to 07/01/2012 Escrow Deficit $559.86 Attorney's Fee at 5% of Principal Balance $5,861.62 TOTAL $127,824.49 "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 Defendants by letters dated April 18, 2012 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the April 18, 2012 Act 6 Notices is attached hereto and marked Exhibit "D". 9. 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 5.7500% ($18.72 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PURCELL G HALL 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) • r c? NOTE rnA Case No. State of Pennsylvania 1441-8240199 March 31, 2008 3 J Date 1 1877 Douglas Drive 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 Sovereign 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 one Hundred Twenty Three Thousand Five Hundred Fifty Six And Zero/100 Dollars (U.S. $ 123,556. 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 Five and three quarters percent ( 5.750 %) 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 first day of each month beginning on May 01 , 2008 . Any principal and interest remaining on the first day of April 2038 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 1130 Berkshire Blvd. , Wyomissing, PA 19610 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. $ 721.04 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 ?Ohher [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. 0096201283 FHA Pennsylvania Fixed Rate Note - 10/95 Wolters Kluwer Financial Services VMP S-1 RiPAI 10707) fly/ Page 1 of 2 INtials: 0802285020 I k /a ( 4 ?3 a OJ(D UP 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4. 000 %) of the 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 ?t 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 of the amounts owed under this Note. This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b). BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. ?V _ ? 3/?S (Seal) Arsene C Bangoup -Borrower (Seal) -Borrower (Seal) Virginia L Bangoup -Borrower - (Seal) Borrower 0096201283 VMPOIRIPA) (0707) - (Seal) PMrrMQr THE ORDER 0 A HOUST?G FINANCE AGENCY (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower 0802285020 T. 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: 29161094358 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): ARSENE C. BANGOUP VIRGINIA L. BANGOUP Secured by the real property located at: 1877 DOUGLAS DRIVE, CARLISLE, PA 17013 Municipality of. TOWNSHIP OF NORTH MIDDLETON Original Principal Amount: $123,556.00 County Recorded in: CUMBERLAND Mortgage Recorded: April 1, 2008 Instrument#: 200809871 Last Assignment to: PA Housing Finance Agency Instrument#: 200809872 IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 100, PHFA) [GUTSHALE] DATED: May 11, 2012 By: PENNSAVANIA HOUSING F&NANCE AGENCY Anthony J. Juliaih" V I/ Director of Accounting and L Van Servicing COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the day of 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. YA ' $ n Notary Public COMMi.NWEAI.'t11 OF PENNSYLVANIA Notarial Seal IGmberiey A. Ayala, Notary Public City of Harrisburg, Dauphin County My CornnYh Ton 6iphes Jan. 15, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF WTAIM 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 ania 7105-5057 1j"roftw A0 utho ' ed Officer &h(bJ"g, ALL THAT CERTAIN lot of ground with the improvements situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 102 on the Resubdivision Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 39, Page 30; containing 146.86 feet along the North along Lot No. 101, Section 12; containing 47.527 feet along the East along Section 8, Noll Manor; containing 148.42 feet along the South along Lot No. 103, Section 12; and containing 47.50 feet along the West along Douglas Drive as shown on said Plan. CONTAINING 7,018 square feet and having erected thereon a two-story townhouse dwelling numbered 1877 Douglas Drive, Carlisle, PA 17013. UNDER AND SUBJECT, nevertheless, to an easement for the purpose of ingress, egress and regress along the eastern and southern 10 feet of the above described premises, as shown on the above mentioned Plan, in favor of Lots Nos. 95, 96, 97, 98, 99, 100, and 101. Pennsylvania Housing Finance Agency Accounting & Loan Servicin 211 North Pront.kreet, P.0. Rox 15057 Ilurrishurg, PA 17105-5057 000) 346-3597 FAX (717) 780-3899 l'TY ("717) 780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 4/18/2012 RE: Account No. 1739663 ARSENE C. BANGOUP VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013-4612 RE: 1877 DOUGLAS DRIVE CARLISLE, PA 17013-4612 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 1877 DOUGLAS DRIVE, CARLISLE, PA 17013-4612, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $969.00 for 1/2012 through 4/2012 for a total of $3,876.00. Late charges and NSF charges that have accrued to this date in the amounts of $115.36 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 $3,500.36. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $3,500.36, 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. 64 N i) ? 1 --o 1 \ 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 Sher'iff'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 it 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 lt 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, --j"" Ls 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/ALSV/ rennsylvania Housing Finance Agency Accounting & Loan Servicin II North Front Street, P. U. Box 15057 Iktrrisbrrr'g, Pal 17105-5057 (800) 346-3597 FAX (717) 780-3899 TTY(717) 780-1869 NOTICE 4/18/2012 ARSENE C. BANGOUP VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013-4612 RE: Account #1739663 TO: ARSENE C. BANGOUP VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013-4612 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. If these agencies are not near you, you can call HUD's toll free number (800) 569-4287 for financially distressed mortgagors for information concerning HUD-approved housing counseling agencies. Attachment: Housing Counseling List FHAACT/dtmdocs/ALSW *** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY *** CCCS OF WESTERN PA-HARRISBURG 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 NACA 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 Phone:888-297-5568 HOUSING ALLIANCE OF YORK DEVELOPMENT 34 S. Duke St. York, PA 17401-1106 Phone: 800-864-4909 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/ALSV/ i 7196 9008 9111 4385 9106 TO: ARSENE C BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 SENDER: GUTSHALE REFERENCE: 1739663 RETURN -POORP .45 RECEIPT CerdW Fee 2.95 SERVICE Retum Receipt Fee 2-35 Rwki&ed Del very Total Postage & Fees 5.75 US Postal S6rvioso POSTMMK-OR DATE'-; Receipt for Certified Mail"' No o bt ? D Mteffm o W Md ----------- ---- -------------- ---- wa , o0 ?a n N q J .i •+ n \ G N M N I b C W 0 n M M ?t O O L O1 \ W N v Q d' W 1 o N .-i O % 1 0 M M N N In N t N N M n U N 1 Z Z N 1 .' 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I .. .. r I In CIO 00 W C L. .-i •H L. -4 -1 CL L L m > H m •• L n m L. a M 0a •.•I 'O Ol w= 01 O eBO L!BLV me d NCD JL) mWWca W(L Ea J O w C M C M m 7 00 J X O N N Z b A .y I LL LL C vl L d 7 0 M h d mot L 1 'O N a .? Q LL V C m C H m ' OI O @ J m z > ; M iL C N ; O 1 •'I LL ; V V a m '0 m N +i LL ? C1 m O' J ? N m 41 C -4 Q' E X W d! m N OI; t> M m,a LL IL N ?196 9008 9111 4385 9113 TO: VIRGINIA L BANGOUP 1877 DOUGLAS DRIVE CARLISLE,PA 17013 SENDER: GUTSHALE REFERENCE: 1739663 J RETURN 4 FA RECEIPT CerdW Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees us Peal SerAw* POSTMARK OR DATE ` Receipt for Certified Mail"` m Lo X d C3 Z'GgZ? C3 r-q ir u7 N ? m r ? ??. QI 0 C3 r 0' M1 W _ a4H? 0 Q !h ILU s as a U Uaa QCJ) U W [? rNa i ? C- P4 &0 IC W 0c) U M ? r W a E-I M lp rn M C` fS j U cc C L C C c M 1 i E IL 'Department of Defense Manpower Data Center status Report Pursuant to Saviclemembers Civil Relief Act Last Name: BANGOUP First Name: ARSENE C Active Duty Status As Of: Jun-02-2012 Results as of : Jun-02-2012 05:20:58 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 reflects 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 Date 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 His/Her Unit Was Notified of a Future Call-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 hlsrher 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, NQAA, 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. y6t Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 rA_, I ? If " r-_., ", 'Department of Defense Manpower Data Center statu's 'n Kapalt Pursuant to Ser emembers Civil Relief Acct Last Name: BANGOUP First Name: VIRGINIA L Active Duty Status As Of: Jun-02-2012 Results as of : Jun-02-2012 05:21:36 SCRA 2.2 Active Duty Start Dale Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects 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 Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status wHhin 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notflied of a Future CaIWp to Active Duty on Active Duty Status Date Order Notification Start Dale Order Notification End Data Status Service Component NA NA No NA This response reflects whether the individual or his/her 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, NOAH, 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. 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 Mlg?- By Anthony'i,`46lian, Di ctor of Accounting & Loan Servicing for the I - ' vania Housing Finance Agency, Attorney-in-Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency BANGOUP 1739663 U.S. BANK NATIONAL ASSOCIATION AS IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff(s) ._ -:;rte ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP_ cco?q tcJ"! 7 ;? ; Defendant(s) Y Civil - ,` 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. Respectfully submitted: _ 6/22/12 Date Leon P.,'aller / Jill M. Wineka Attorney for Plaintiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 PA ID 1570a / 58802 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff(s) VS. ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date 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: Is the property for sale? Realtor Name: Yes E] No E] Listing date: Borrower Occupied: Yes El Mailing Address (if different) City: Phone Numbers: Home: Cell: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: No ? Home: Cell: State: Zip: _ Price: $ Realtor Phone: State: Zip: _ Office: Other: How long? State: Zip: _ Office: Other: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes and Insurance: Date of Last Payment: _ Primary Reason for Default: Is the loan in Bankruptcy? Yes E] No ? 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: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: _ Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. 2. Borrower Pay Days: Monthly Gross Monthly Gross Monthly Gross Monthly Amount: _ Monthly Amount: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses You are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alien. 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: Fax: Yea r: Year: Monthly Net Monthly Net Monthly Net 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: I/We, named purpose of evaluating understand that I/we named Phone: authorize''the above to use/refer this information to my lender/servicer for the sole my financial situation for possible mortgage options. I/we am/are under no obligation to use the services provided by the above 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor F.F? -0FF1" ..?F THE ,"Rn, 1 gN0Trjs dY THE t 1,2 JUL 12 AM 8-'104 Ct1MSERLA- Q COU TY A7 US Bank National Association vs. Virginia Bangoup (et al.) Case Numb 2012-3975 SHERIFF'S RETURN OF SERVICE 06/26/2012 05:08 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 1877 Douglas Drive, 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 1877 Douglas Drive, Carli le, Pennsylvania 17013 is vacant. 07/09/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent see and inquiry for the within named defendant to wit: Arsene C. Bangoup, but was unable to locate him it 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 Arsene C. Bangoup. Requ for service at 1877 Douglas Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. Deputi( were advised, Arsene C. Bangoup has not resided at this address in over one year. 07/09/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent sea and inquiry for the within named defendant to wit: Virginia Bangoup, but was unable to locate her in hi: 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 Virginia Bangoup. Request service at 1877 Douglas Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisl Postmaster has confirmed, Virginia Bangoup has moved and left no forwarding address. SHERIFF COST: $81.00 SO ANSWERS, July 09, 2012 4RON ANDERSON, SHERIFF his Ic) Ccu^tySU,to jher+f. Te:-ec,,sc;'i. Inc U.S. BANK NATIONAL ASSOCIATION, AS _.? IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA Hi:fO ? CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY ?C CQ NTH Plaintiff pENNSY CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLO URE ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP No. 12-3975 Defendants PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: August 2, 2012 PURCELL, KRUG, & HALLER Leon P. Halle 1719 North ront Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 o&+ ? p sag 7 7 0 to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff Vs. ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 12-3975 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE 1, Leon P. Haller, hereby certify that a true and correct copy of the Complaint, Notice of Residential Mortgage Foreclosure Diversion Program, Request for Conciliation Conference and Financial Worksheet in the above captioned action was forwarded to the following individual by regular U. S. Mail, first class service, postage prepaid, and by certified mail, return receipt requested, postage prepaid, on February 6, 2013, addressed as follows: VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 Attached hereto is the original Certificate of Mailing postmarked February 6, 2013 along with the original Receipts for Certified Mail also postmarked February 6, 2013. SWORN /to and su this/ day of 20/J. N lf? Leon P. aller My commission expires: COMMON "9" PUMMUANA 912 3 Sono E. Pruseack Nowt' ftNIC aty of OM &Oreu? CMILY 9epL 26, A13 (SEAL) yC Member. Penns~ M 1 r. , t C-j Cc C) r; > w PENNSYLVANIA HOUSING FINANCE AGENCY v. ARSENE C. BANGOUP VIRGINIA L. BANGOUP CUMBERLAND County 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: VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 9 1J e.?? po$r4 =?. t>IiNf.V ROW, S Q2 1fw, $ 02.40° QE1 428432 v5?8 :?0?3 lMAILED FROM ZIP CODE 1 r' 22 7196 9008 9111 4949 5634 7196 9006 9111 4949 5841 TO: VIRGINIA L. BANGOUP TO: VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE 431 N. HANOVER STREET CARLISLE, PA 17013 CARLISLE,, PA 17013 SENDER: MSH/CO SVC SENDER: MSH/CO SVC REFERENCE:PHFABANGOUP REFERENCE:PHFA/BANGOUP PS Form 3800 Janua 2005 /, PS Form 3800 Janua 2005 / RETURN Postage RETURN Postage RECEIPT Certified Fee 31 RECEIPT Certified Fee 3.10 SERVICE Return Receipt Fee 2. SERVICE Return Receipt Fee 2.55 4. 4.75 Restricted Delivery Restricted Delivery Total Postage & Fees Total Postage & Fees " POSTMARK>aATE Q US Postal Service'" US Postal Service`9' POSTMARK Receipt for Receipt for Certified Mail'" Certified Mail'" No Insurance Coverage Provided No Insurance Coverage Provided \ Do Not Use for International Mail ^`- Do Not Use for International Mail \? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW AT NO. 12-3975 U.S.BANK NATIONAL ASSOCIATION,AS Total Judgment Amount $127,824.49 TRUSTEE FOR THE PENNSYLVANIA HOUSING Interest $7,901.77 FINANCE AGENCY, Per diem of$18.72 to sale PLAINTIFF date 9/4/2013 Late Charges $400.16 VS. $28.84 per month to sale date 9/4/2013 ARSENE C.BANGOUP AND Escrow Deficit $3,163.64 VIRGINIA L.BANGOUP, DEFENDANT(S) TOTAL WRIT $139,290.06 *Plus additional interest,late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday,September 04,2013 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION-MORTGAGE FORECLOS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. CD-1 n C-1, Date: May 21, 2013 C E5 tom, C,3 Attorney for Plaintiff - . 1719 North Front Street eon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717)234-4178 WRIT OF EXECUTION-MORTGAGE ORECLOSURE COMMONWEALTH OF PENNSYLVANI SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in e a ve captioned case,you are directed to levy upon and sell the property described in the attached descripti known 1877 DOUGLAS DRIVE CARLISLE,PA 17013 Date: n PROTHONO RY/CLERK CIVIL DIVISION lr't BY (J1�1 4*0(. 0o Car a DE TY l�L 60 1;C I�3IO tCQ.�a tt t qb q . W,1� � r ' ALL THAT CERTAIN lot of ground with the improvements situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 102 on the Resubdivision Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 39, Page 30; containing 146.86 feet along the North along Lot No. 101, Section 12; containing 47.527 feet along the East along Section 8,Noll Manor; containing 148.42 feet along the South along Lot No. 103, Section 12; and containing 47.50 feet along the West along Douglas Drive as shown on said Plan. CONTAINING 7,018 square feet. HAVING THEREON erected a two story townhouse dwelling known as 1877 DOUGLAS DRIVE, CARLISLE, PA 17013 ASSESSMENT NO. 29-16-1094-358 UNDER AND SUBJECT nevertheless,to an easement for the purpose of ingress, egress and regress along the eastern and southern ten(10) feet of the above described premises, as shown on the above mentioned Plan, in favor of Lots Nos. 95, 96, 97, 98, 99, 100 and 101. BEING THE SAME PREMISES WHICH Noll Associates,by deed dated 03/31/08 and recorded 04/01/08 in Cumberland County Instrument No. 2008-09870, granted and conveyed unto Arsene C. Bangoup and Virginia L. Bangoup, his wife. TO BE SOLD AS THE PROPERTY OF ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP ON JUDGMENT NO. 12-3975 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. 12-3975 ARSENE C.BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L. BANGOUP, 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 1877 DOUGLAS DRIVE CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): ARSENE C. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 ; " -: - ARSENE C. BANGOUP M M Tl 1877 DOUGLAS DRIVE �r- w ' CARLISLE, PA 17013 -<> CD CD ARSENE C. BANGOUP =o 106D WOLF BRIDGE ROAD y CARLISLE, PA 17013 < -- _.4 VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 VIRGINIA L. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 VIRGINIA L. BANGOUP 431 N. HANOVER 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: NONE 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Redevelopment Authority of The County of Cumberland 114 North Hanover Street #103 Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: NONE 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 1877 DOUGLAS DRIVE 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 are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. L aller PA I.D. #15700 uurcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:May 21, 2013 ,f 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. 12-3975 ARSENE C. BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L.BANGOUP, DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE c r°} PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 cn r- ro .- TAKE NOTICE: r �CD .�o - , n r7 - ; s That the Sheriffs Sale of Real Property(real estate) will be held: ° , )n DATE: Wednesday, September 04,2013 - `- 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: 1877 DOUGLAS DRIVE 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. 12-3975 JUDGMENT AMOUNT $127,824.49 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP r 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. a r 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 ,S ALL THAT CERTAIN lot of ground with the improvements situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 102 on the Resubdivision Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 39, Page 30; containing 146.86 feet along the North along Lot No. 101, Section 12; containing 47.527 feet along the East along Section 8, Noll Manor; containing 148.42 feet along the South along Lot No. 103, Section 12; and containing 47.50 feet along the West along Douglas Drive as shown on said Plan. CONTAINING 7,018 square feet. HAVING THEREON erected a two story townhouse dwelling known as 1877 DOUGLAS DRIVE, CARLISLE, PA 17013 ASSESSMENT NO. 29-16-1094-358 UNDER AND SUBJECT nevertheless,to an easement for the purpose of ingress, egress and regress along the eastern and southern ten (10)feet of the above described premises, as shown on the above mentioned Plan,in favor of Lots Nos. 95, 96, 97, 98, 99, 100 and 101. BEING THE SAME PREMISES WHICH Noll Associates,by deed dated 03/31/08 and recorded 04/01/08 in Cumberland County Instrument No. 2008-09870, granted and conveyed unto Arsene C. Bangoup and Virginia L. Bangoup, his wife. TO BE SOLD AS THE PROPERTY OF ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP ON JUDGMENT NO. 12-3975 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 12-3975 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 FIANCE AGENCY Plaintiff(s) From ARSENE C.BANGOUP AND VIRGINIA L. BANGOUP (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: $127,824.49 L.L.: $.50 Interest $7,901.77(PER DIEM OF x'18.72 TO SALE DATE 9/4/2013 Atty's Comm: Due Prothy: $2.25 Atty Paid: $354.25 Other Costs: LATE CHARGES-$28.84 Per month to sale date 9/4/2013-$400.16-ESCROW DEFICIT-$3,163.64 Plaintiff Paid: Date: 5/22/13 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: 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 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. 12-3975 :Tt ARSENE C. BANGOUP AND �<�' VIRGINIA L. BANGOUP, MORTGAGE FORECLOSURE DEFENDANT(S) "C7 - - Z=S PRAECIPE co TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP 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 $117,232.49 Interest $3,968.64 Per diem of$18.72 From 12/01/2011 To 07/01/2012 Accumulated Late Charges $28.84 Late Charges $173.04 ($28.84 per month to 07/01/2012) Escrow Deficit $559.86 5% Attorney's Commission $5,861.62 TOTAL $127,824.49 "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 & HALLE By Leo aller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 CL 0 LL ago-) lvo�U. lb� 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. 12-3975 IN MORTGAGE FORECLOSURE ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP, DEFENDANT(S) CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on March 6, 2013 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 Leo . Haller PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, HOUSING FINANCE AGENCY, PENNSYLVANIA Plaintiff NO. 12-3975 VS. ARSENE C. BANGOUP AND CIVIL ACTION LAW VIRGINIA L. BANGOUP IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: March 6,2013 TO: ARSENE C.BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 ARSENE C. BANGOUP 106D WOLF BRIDGE ROAD CARLISLE, PA 17013 ARSENE C. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, K UG& HALLER By LEON P. HALLER,Attorney for Plaintiff 1.D.# 15700 1719 N. Front St., Harrisburg, PA 17102 (717)234-4178 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. 12-3975 ARSENE C. BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L. BANGOUP, _ DEFENDANT -7M tTt-- NON-MILITARY AFFIDAVIT "' <- COMMONWEALTH OF PENNSYLVANIA - CD C SS COUNTY OF DAUPHIN Personally appeared before me,a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s)above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this,,&day of 20a : t P. HALLER, ESQUIRE 16tary blic . . _ YL1fAPfIA NOTARIAL SEAL MARYLAND 1•.FERRET'?,Notary Public Lower Paxton Twp.,Dauphin County My Commission Expires Aug.8,2014 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. 12-3975 ARSENE C.BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L.BANGOUP, DEFENDANT ) ca AFFIDAVIT E5 f"r COMMONWEALTH OF PENNSYLVANIA c. SS COUNTY OF DAUPHIN I, LEON P. HALLER, Attorney for the Plaintiff in the above matter, being duly sworn according to law, hereby certify that the Mortgage in the above case is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 1715z11) and therefore does not fall within the provisions of PA Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program). Sworn to and subscribed : before me this o/ day : of 20z ON P. HALLER, ESQUIRE Notary blic fdNWEALTH 9+=PENNSYLVANIA NOTARIAL SEAL MARYLAND K.FERRETTI,Notary Public Lower Paxton Twp.,Dauphin County My Commission Expires Aug.S,2014 t 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. 12-3975 ARSENE C.BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L.BANGOUP, DEFENDANT(S) RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 1 I i a, l aL 13 , 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: ARSENE C. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 ARSENE C. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 c-> C ARSENE C. BANGOUP 106D WOLF BRIDGE ROAD CARLISLE, PA 17013 VIRGINIA L. BANGOUP :© g`-) ' = c, ,7 1877 DOUGLAS DRIVE to o CARLISLE, PA 17013 CO Y VIRGINIA L. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 A DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1877 DOUGLAS DRIVE CARLISLE, PA 17013 Redevelopment Authority of The County of Cumberland 114 North Hanover Street #103 Carlisle, PA 17013 By LL, KRUG & HALLER ttorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES A xe 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 HERSHEY LEON P.HALLER TELEPHONE(717)2344178 (717)533-3836 JOHN W.PURCELL JR. FAX(717)234-1206 JILL M.WINEKA LISA RYNARD ARSENE C. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 ARSENE C. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 ARSENE C. BANGOUP 106D WOLF BRIDGE ROAD CARLISLE, PA 17013 VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 VIRGINIA L. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 1877 DOUGLAS DRIVE CARLISLE, PA 17013 Redevelopment Authority of The County of Cumberland 114 North Hanover Street #103 Carlisle, PA 17013 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 g notified of said Sheriffs Sale. By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff 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. 12-3975 ARSENE C.BANGOUP AND IN MORTGAGE FORECLOSURE VIRGINIA L.BANGOUP, 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, September 04, 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: 1877 DOUGLAS DRIVE 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. 12-3975 JUDGMENT AMOUNT $127,824.49 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP 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 of ground with the improvements situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEING Lot No. 102 on the Resubdivision Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 39, Page 30; containing 146.86 feet along the North along Lot No. 101, Section 12; containing 47.527 feet along the East along Section 8,Noll Manor; containing 148.42 feet along the South along Lot No. 103, Section 12; and containing 47.50 feet along the West along Douglas Drive as shown on said Plan. CONTAINING 7,018 square feet. HAVING THEREON erected a two story townhouse dwelling known as 1877 DOUGLAS DRIVE, CARLISLE, PA 17013 ASSESSMENT NO. 29-16-1094-358 UNDER AND SUBJECT nevertheless,to an easement for the purpose of ingress,egress and regress along the eastern and southern ten(10)feet of the above described premises, as shown on the above mentioned Plan,in favor of Lots Nos. 95,96,97, 98,99, 100 and 101. BEING THE SAME PREMISES WHICH Noll Associates,by deed dated 03/31/08 and recorded 04/01/08 in Cumberland County Instrument No. 2008-09870, granted and conveyed unto Arsene C. Bangoup and Virginia L. Bangoup,his wife. TO BE SOLD AS THE PROPERTY OF ARSENE C. BANGOUP AND VIRGINIA L. BANGOUP ON JUDGMENT NO. 12-3975 5 U. S . BANK NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY - CIVIL ACTION - LAW Plaintiff . � NO. 12 -3975 CIVIL a VS . IN MORTGAGE FORECLOSURE 7a C t ARSENE C. BANGOUP AND Q VIRGINIA L: BANGOUP JP ' Defendants ORDER FOR SERVICE AND NOW, to wit, this �./1/� day of ! 2=:P2 , upon consideration of the within Affidavit, is appearing that a good faith investigation and effort to locate the Defendant, Virginia L. Bangoup, has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 1877 Douglas Drive, Carlisle, Pennsylvania 17013 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed by mailing) , to Defendant, Virginia L. Bangoup, at her last known address of 1877 Douglas Drive, Carlisle, Pennsylvania 17013 , AND FURTHER, that in the event this case should be reduced to judgment and execution shall be issued, service upon the Defendant, Virginia L. Bangoup, pursuant to Rule 3129 . 2 (c) (1) (C) shall be effected by posting a copy of the Notice of Sale or Sheriff ' s handbill on the most public part of the premises and by mailing a copy of the Notice of Sale by regular and certified mail to Defendant, Virginia L. Bangoup, at her last known address of 1877 Douglas Drive., Carlisle, Pennsylvania 17013 . BY THE COURT J. Aug. 7. 2013 12: 08PM Cumberland County S h e r r i f No. 7047 P. 2/3 . . ■ Complete Items 1,2,and 3.Also complete A SI nature Rem 4 If Restricted Delivery Is desired. X 13 Agent ■ Print your name and address on the reverse ❑Addressee so that we can return the card to you. 13. R lve d red f rT C. bete of DelNery ■ Attach this card to the back of the mallpiece, or on the front It space permits. D. Is delivery address 0 Yea 1. Articte addressed to: If YES,enter de0v � No Cr Arsene C. Bangoup r 207 Pepper Mill Drive Capital Heights, MD, 20743, a, aeMceType bO certifled Mall Q Express. ad O Realetered ❑Return,Recelpt for Merchandise d InaVred Mall ❑C.O.D. 4. Restdated Delivery?(Orbs Fee) ❑Yea ` 7007 0710 0003 2210 3528 RE PS Form 3811,February 2004 Domestic Return Receipt 1o�sgO2M,tyyp .7196 9008 9111 8545 1856"y 71'96 900879111 8545 1863 •y TO: ARSENE C.BA14GOUP 106D WOLF BRIDGE ROAD :: TO: ARSENE C.BANGOUP CARLISLE,PA 1:7013 1877 DOUGLAS DRIVE CARLISLE,PA 17013 i SENDER: P01455/38701 SENDER: P01455/38701 REFERENCE: NOS 09/04/13 REFERENCE: NOS 09/04/13 . I PS Form 3800 Janua 2005 PS Form 3800 January 2005 I RETURN Postage I RECEIPT Certified Fee RETURN Postage 1 SERVICE I RECEIPT Certified Fee 3 10 Return Receipt Fee SERVICE I Return Receipt Fee 9 55 Restricted Delivery � Restricted Delivery Total Postage&Fees Lj Total Postage&Fees USPSO POSTMaR 0 DATE 1�\ USPS� POSTMAR D Receipt for oti Receipt for �� 50 LA Certified WHY,, o ac , .. ti Certified Mail - !�1 a No Insurance Coverage Peal Mail i No Insurance Coverage Pfbvided p Do Not Use for International Mall Do Not Use for International Mail (1 l a 7196 9008 9111 8545 1894 I T ^71969008 9111^8545 1870 TO: VIRGINIA L.BANGOUP TO: ARSENE C.BANGOUP 431 N.14ANOVER STREET 1789 CESSNA STREET CARLISLE,PA 17013 CARLISLE,PA 17013 I i SENDER: P01455/38701 SENDER: P01455/38701 REFERENCE: NOS 09/04/13 REFERENCE: NOS 09/04/13 PS Form 3800 January 2005 PS Form 3800 January 2005 RETURN Postage ; RETURN Postage RECEIPT Certified Fee I RECEIPT Certified Fee J SERVICE SERVICE Return Receipt Fee r Return Receipt Fee Restricted Delivery Restricted Delivery Total &Postage Fees 9 .( -c9� Total Postage&Fees ± USPS" ' POSTMARK OR DATE'"/ LISPS" POSTMARK OR DATE I Receipt for ! �� y Receipt for y Certified Mail'"' ya ��� Certified Mail"' No Insurance Coverage PibVided W No Insurance Coverage Pibvided t co Do Not Use for International Mail �� �C Do Not Use for International Mail J//JC 7196 9008 9111 8545 1849 7196 9008 9111 8545 1887 TO: VIRGINIA L.BANGOUP TO: VIRGINIA L.BANGOUP 1877 DOUGLAS DRIVE 1789 CESSNA STREET CARLISLE,PA 17013 CARLISLE,PA 17013 SENDER: P01455/38701 SENDER: P01455/38701 REFERENCE: NOS 09/04/13 REFERENCE: NOS 09/04/13 � f PS Form 3800 January 2005 PS Form 3800 January 2005 RETURN Postage RETURN Postage RECEIPT Certified Fee RECEIPT ` SERVICE SERVICE Certified Fee i1 Return Receipt Fee S Return Receipt Fee ' + Restricted Delivery Restricted Delivery' f Total Postage&Fees Total Postage&Fees `V USPSO POSTMARK OR DATE USPS* POSTMAR* ATE d fff Receipt for Receipt for Certified Mail'" �'�� �� Certified Mail'" No Insurance Coverage Provided No Insurance Coverage ftvided Do Not Use for International Mail Do Not Use for International Mail I PENNSYLVANIA HOUSING FINANCE AGENCY v. ARSENE C.BANGOUP VIRGINIA L.BANGOUP Cumberland County Sale 9/4/2013 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: ARSENE C. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ARSENE C. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail'addressed to: Postmark: ARSENE C. BANGOUP 106D WOLF BRIDGE ROAD CARLISLE, PA 17013 ar< eo""Es 79� 02 1M 1• 0004284324 L 1 13 MAILED FROM P 7102 C COP r 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: VIRGINIA L. BANGOUP 1877 DOUGLAS DRIVE CARLISLE, PA 17013 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: VIRGINIA L. BANGOUP 1789 CESSNA STREET CARLISLE, PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: VIRGINIA L. BANGOUP 431 N. HANOVER STREET CARLISLE, PA 17013 C- a ti ti - �CPPOSr `A o c � ® 02 1M $ 01.200 0004284324 JUL 12 2013 MAILED FROM ZIP CODE 17102 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: Redevelopment Authority of The County of Cumberland 114 North Hanover Street #103 Carlisle, PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 1877 DOUGLAS DRIVE C CARLISLE,PA 17013 w ZtF A. i F-1 a('ES �. .200 02 1M JULI; 2013 0004284324 MAILED FROM ZIP CODE 1710 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith I �€ i Chief Deputy { Richard W Stewart Solicitor Qmc or THE SHERIFF PEN N S YLVA NIA US Bank National Association vs. Case Number Virginia Bangoup (et al.) 2012-3975 SHERIFF'S RETURN OF SERVICE 07/03/2013 02:11 PM - Deputy Ronald Hoover, 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 1877 Douglas Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County. 07/05/2013 07:30 PM - Deputy Valerie Weary, being duly sworn according to law, attempted service to the Defendant, to wit:Arsene C. Bangoup at 1877 Douglas Drive, North Middleton Township, Carlisle, PA 17013. The address was found to be vacant. 07/08/2013 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: Virginia Bangoup, 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 431 North Hanover Street, Carilsle, PA 17013, several attempts at service were made defendant could not be located at address stated, Court Order to Post Premises issued on January 3, 2013. 07/11/2013 06:30 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Virginia Bangoup, pursuant to Order of Court by"Posting"the premises located at 1877 Douglas Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 07/12/2013 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: Arsene C. Bangoup, 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 1877 Douglas Drive, Carlisle, PA 17013, property is vacant, per Arthur Du-Rae, friend of relative that defendant was living with, defendant no longer resides at 106D Wolfs Bridge Road, Carlisle, PA 17013, , or 1789 Cessna Street, Carlisle, PA 17013, believed to be residing at: 207 Pepper Mill Drive, Capital Heights, MD 20743. 07/12/2013 Sheriff Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Arsene C. Bangoup at 207 Pepper Mill Drive, Capital Heights, MD, 20743. 07/29/2013 Ronny R. Anderson, Sheriff,who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sheriff's Sale and Legal Description by certified mail, return receipt requested, to the within named defendant, to wit: Arsene C. Bangoup, by mailing a copy of the within documents to the defendant's last known address of 207 Pepper Mill Drive, Capital Heights, MD 20743 on 7/12/13 The return receipt card was recieved by the Cumberland County Sheriffs Office on 7/26/13 signed by Arsene C. Bangoup on 07/23/13. 09/04/2013 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, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Leon Haller on behalf of US Bank National Association, Trustee for the Pennsylvania Housing Finance Agency, being the buyer in this execution, paid to the Sheriff the sum of$ 1.K 00 /0,01" c?CountySuite Sheriff:Telecsoft,Inc. L}� z 93a � ,ta9 ;7.75 SHERIFF COST: $836.16 SO ANSWERS, September 18, 2013 RONNW ANDERSON, SHERIFF (c)CountySuite Sheriff:Teleosoft,Inc.