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HomeMy WebLinkAbout12-6040_,i _.~ -~,rr,~_,... ~^` r . ~~f lei. J ! i;lsi:i~ ~ ~.., Leon P. Haller, Esquire Purcell, Krug & Haller l 719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. WALL T. THOMAS Defendant ., ~ r +,. ~ ~ .- ^ r ~' ' .! J ~ 1J 1 tt 6 .~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW ACTION OF MORTGAGE FORE LOSURE ta- CaoN b ~- v < 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 S"i'REET' 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 LISTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PR.OCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE ~' REQUERIRA QUE LISTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE LISTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 Q ~\c~3.~5pd p ~a Spa ~ 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 LAV~I ACTION OF MORTGAGE FORECLOSURE WALI T. THOMAS, Defendant 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. WALI T. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 19E2 and as amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through thf; Pennsylvania Housing Finance Agency ("Agency"), its appointed Limited Power of Attorney, with ari 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 v~~ithin 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. 1G19(g). 2. Defendant, WALI T. THOMAS, is an adult individual whose last known address is 3151 CAPE HORN ROAD, SUITE 144, RED LION, PA 17356. 3. On or about, July 15, 2010, the said Defendant executed and delivered a Mortgage Note in the sum of $176,540.00 payable to GRAYSTONE MORTGAGE, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage No1:e, 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 July 22, 2010 as Instrument Number 201019712 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 July 22, 2010 as Instrument Number 2010019713. 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 Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 2284 GLEIM DRIVE, QUIGLEY COVE, ENOL.A., PA 17025 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 May O 1, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $171,721.08 Interest at $21.47 per day $3,929.01 From 04/01 /2012 To 10/0l /2012 ( based on contract rate of 4.5000%) Accumulated Late Charges $44.73 Late Charges $44.73 $223.75 From OS/01 /2012 to 10/01 /2012 Escrow Deficit $1,291.30 Attorney's Fee at 5% of Principal Balance $8,586.05 "TOTAL $18:5,795.92 * * Together with interest at the per diem rate noted above after October O 1, 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. The Plaintiff has complied with the notice procedures required by Pennsylvania Act 6 of 1974 and as amended by Pennsylvania Act 57 of 2008 by sending to each Defendant, by certified mail, Notice of Intention to Foreclose Mortgage and Accelerate Loan Balance. A true and correct copy of the Notice of Intention to Foreclose Mortgage and Accelerate Loan Balance dated July 20, 2012 is attached hereto as 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 Service Members Civil Relief Act, 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 4.5000% ($21.47 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: PURCELL, KRUG & HALLER Leon P. Haller, Esquire I.D. # 15700 Jill M. Wineka I.D. #58802 Attorneys for Plaintiff 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) MIN 1005556-6100100211-8 Loan ID N 6100100211 X30- l~`~ Nom ~2z `~~ 3~ t July 15th, 2010 CAMP HILL, PA (Datcl [City) (State] 2284 GLEIM DRIVE, ENOLA, PENNSYLVANIA 17025 (Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $176, Sd0.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is GRAYSTONE MORTGAGE . [will make a]! payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 1. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 4.500 ~, The interest rate required by this Section 2 is the rate T will pay both before and afrer any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on September lat, 2010 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on Auqust 1st, 2040 , [still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Dace." I will make my monthly payments at 5115 EAST TRZNDLE ROAD MECHANICSBURG, PA 17050 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 894.51 4. BORROWER'S RIGIiT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that J am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Nate. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. [f I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing co those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or m be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAII,URE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of Fifteen calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each lace payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I wiil be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain dace, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days afrer the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will stilt have the right to do so if I am in default a[ a later time. MULTISTATE FIXED RATE NOTE--Single Family--Fannie MaelFreddie Mac [INFORM LNSTR NT Form 3200 1/Ot (page 1 of 2 pages) AA1CN1 -04132009 ~~ i ~ ~ I ( ^ i n wwv+.ProCiose.com Loan ZD $ 6100100211 (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class [nail to me at the Property Address above or at a different address if [give the Note Holder a notice of my different address. Any notice that must be given co the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. S. 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 iu this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Noce 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. The No[e Holder may enforce its rights under this Note against each person individually or against all of us together, This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I 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 the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (rhe "Security Instrument"), dated the same date as this Noce, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Properyy is sold or transferred (or if Borrower is not a natural persoa and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Inswment. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section IS within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) pF THEAAU//NDER~~S77IGNED. ~~1 ~ c.J~ WALZ T THOMAS (Seal) PAY TO THE ORDER OF: -Borrower PENNSYLVANIA HOUSZNG FINANCE AGENCY [Sign Original Only] WITHOUT E; GRAYSTO TGAGE It~: PRESIDENT ~~ MULTISTATE FIXED RATE NOTE--Single Family--Fannie MedFreddie Mae UNIFORM INSTRUMENT AA1CN2 -041321109 Form 3200 1/01 (page 2 of 2 pages) wk~v.PrnClosc.com ALLONGE ENDORSING MORTGAGE NOTE This Allonge (the "Allonge") is being executed and delivered by GRAYSTONE MORTGAGE 20 endorse the Mortgage Note made by WALI T THOMAS (Originator") as of July 15th, 2010 which this Allonge is attached and made a part (together with U extensions2r0en0ewals, replacements and tameOnrdmentsr, to thereto, the "Note"). The Note relates to the following loan information: Loan Number: 6100100211 Mortgagor(s) Name(s): WALI T THOMAS Property Address: 2284 GLEIM DRIVE ENOLA PENNSYLVANIA 17025 Amount of Note: $ 176,540.00 NOW THEREFORE, the Note is hereby endorsed payable to the order of: PENNSYLVANIA HOUSING FINANCE AGENCY without recourse. IN WITNESS WHEREOF, Originator has duly executed and delivered this Allonge by its authorized officer to be effective as of July 15th, 2010 ?u1NDE1 - 03042(82 www, jlgortgegeBanldng5yntems. com 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 17]05-5057 717-780-3800 or 1-800-346-3597 PIN / ID Number: 10130997040 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): WALI T. THOMAS Secured by the real property located at: 2284 GLEIM DRIVE,QUIGLEY COVE, ENOLA, PA 17025 Municipality o£ TOWNSHIP OF HAMPDEN Original Principal Amount: $176,540.00 County Recorded in: CUMBERLAND Mortgage Recorded: July 22, 2010 Instrument#: 201019712 Last Assignment to: PA Housing Finance Agency Instrument#: 20101971.~~ 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) [FISSEL] DATED: August 24, 2012 By: PENNS V IA HOUSI G INA E AGENCY Ant ny Julian Director of cc ntin nd oan Servicing; COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, th~;~l't''~ day of ~r 2012, before me, the undersigned officer, personally appeared Anthony J. Julian, Director of Accoun ' g and Loan Servicing, an authorized officer of the Pennsylvania Housing Finance Agency, and acknowledged that he, being authorized to do so, executed the foregoing instrument for the purposes therein contained. In witness whereof, I have hereunto set my hand and official seal. ~ 1 1 `1~ ' , a t `~~ Nota Pubhc~/ ~ (~~ n' CdMMt1NiNEALTH CAF PENNSILVANIA Notarial Seal Kimberley A. Ayala, Notary Public City of Harrisburg, Dauphin County My Commission Expires Jan. 15, 2015 CERTIFICATE OF RESIDENCE OF ASSIGNEE MEMBER, PENN5YLVANFA.A~:SOCTATL"N OF NQTARIFS I certify that the principal business and mailing address for this assignment and assignee is: U.S. Bank National Association, c/o PHFA-Accounting & Loan Servicing 211 North Front Street, P.O. Box 15057, Harrisburg, Pennsy ania 1 105-5057 uth i Officer ~~ ~ l ALL THAT CERTAIN UNIT, being Unit No. 18 of Quigley Cove, A Planned Community, such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove, A Planned Communtiy and Declaration Plats and Plans recordE;d in Instrument No. 200744632, together with any and all amendments thereto. The above Unit is commonly known 2284 Gleim Drive. ~rti~bif ~ ~'~°nrisylvania ~OUSin~ F111i117Ce ~ge11Cy _ ;~ccountin_k ~~ Loan Servicing ~~ll Noi7f~ h7•au.y'p•c'et, l'. U. Bo.r l5i'h7 llc;rr•i.ti~h~n;~, !',4 /7!O5-~I)~7 (800) 34h-35J7 F:~IX (717) 780-38J> 7I'1' %717) 780-18(9 CERTIFIED MAIL -RETURN RECEIPT REQUESTED 7/20/2012 RE: Account No. 2285369 WALT T. THOMAS 3151 CAPE HORN RD STE 144 RED LION, PA 17356-9071 RE: 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025-1849 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 2284 GLEIM DRIVE, QUIGLEY COVE., ENOLA, PA 17025-1849, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,177.00 for 5/2012 through 7/2012 for a total of $3,531.00. Late charges and NSF charges that have accrued to this date in the amounts of $178.92 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 $3,709.92. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $3,709.92, 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 ri ht 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 mort a eed rp operty. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty-day period, you will not be required to pay attorney fees. i ~ t FHA.4CT/dtmdocs/ALSV/ ~ ~I 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 sheriffas foreclosure sale. You may do so by paying the total amount of the un aidl 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 nnay have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them a.nd 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 dE~fault. Sincerely, ~. Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 TLG/ FHAACT/dtmdocs/ALSV/ f'°,nr,sy(vania ~ou~sin~~Finance A~enc NOTICE 7/20/2012 WALT T. THOMAS 3151 CAPE HORN RD STE 144 RED LION, PA 17356-9071 RE: Account #2285369 TO: WALT T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 1 7025-1 849 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY :~ccountin,~.~c_Lo=in Servicing ?Il Nr~rth 1~'r~~n! S'uret, !'. U. Bur 1~U57 llru•ri,ehlu•,~r, 1',4 /7l US-~1,1~7 /~YUI)) ~'d 6-_i i>7 /~:1,t" (7I7) 78O-.ib''I) IY'Y(717) 7RlI-I~~G~J 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 FH AACT/dtmdors/ALSV/ **" PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR CC)UNTY *''* 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 5. Duke St. York, PA 17401-1106 Phone:800-864-4909 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 1 760 8-1 676 Phone: 717-397-5182 PHILADELPHIA COUNCIL OF COMMINITY ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-930-4663 FHAACT/dtmdocs/ALSV/ iniu~ii~iii~i~i~iw n...oo...,,.o,..... . „n~c~e r+aaressea to: WALI T THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 2285369 IIIYV~III~III~I~UNVI~ ,.,. ,oo. ,.,, ,o,..... 4: Ras{trictd DeYvery? (Exba Feel ^ Yes 1. Artide Addressed to: WALI T THOMAS 3151 CAPE HORN RD STE 144 RED LION, PA 17356 2285369 FISSEL ~ ft~Itit ~~, .M+uarv 20D5 Domestic Return Receipt 7196 900b 9111 5D3b bb59 T0: WALI T THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 ~~ SENDER: ' FISSEL REFERENCE: 2285369 719b 900b 9111 5D3b bb66 TO: WALI T THOMAS 3151 CAPE HORN RD STE :144 RED LION, PA 17356 SENDER: FISSEL REFERENCE: 2285369 RETURN Postage . 4 5 RETURN Postage , 4 5 RECEIPT Certified Fee SERVICE 2 . 9 5 RECEIPT Certified Fee SERVICE 2 , 9 5 Retum Receipt Fee 2.3 5 Retum Receipt Fee 2.3 5 Restricted Detiv Restricted Delivery Total Postage ~ Fees tj , 7 5 Total Postage & Fees [j , '] cj US Postal Service® POS ~ US Postal Service® POS 9 Receipt for i 9~ Receipt for Q~ '" r ~?~ , '" { _ '~2~~l12 Certified Mail ~ q Certified Mail No N>,wrance Coverage Provldsd No Iruurancs Coverepe Provided Do Not Uae for Intemstlonal MaN (/S.P S . _. _. _ _~._. - - - - ~ Do Nol Uee for Inlematlonal Mall _ - i....,. i.R.,.ra.. -... ~ .., _ . ~S P S , . _ . ~..r Lb6t09ZLaLlO -- -- ---- --„ a --~..__ - 1t+6~09Z1O110 LOILI dIZ lOlLl diZ 0~ ~ . ~ O$ ' 05 ~ . ~ O~ • ZLOZ,OZ/LO ZLOZIOZ/LO ~I~H' aa~sQH ~I ~ I u ,i ~ ~ ~ m ,~ m o ~ `° ctf Y ~~ ~'s~a. i ~I a ~ a w w ~ A o ~ ~ ~HO~ E w 1~arn ~ - HC7W ~ ~ tn . 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SdS~ o ~tl0z ~ Z ~~ r-t fan '~na5 Department of Defense Manpower Data Center ~$t11fi ~K?I'C ~ua~:t to ~~rv~~mbers civil R,~ief Apt Last Name: THOMAS First Name: WALT Middle Name: T Active Duty Status As Of: Sep-06-2012 Results as of :Sep-06-2012 11:06:55 SCRA 2.3 On Active Duty On Active Duty Status Date Active Duty Slan Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Dury Status Date left Active Duty Within 367 Days of Active Duty Status Date Active Duly 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 iha Active Duty Status Date The Member or HislHer Unit Was Notified of a Future CaiV-Up to Active Duly on Active Duty Status Date Order Notification Start Date Order Not~wtlon End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received eady notification b 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. ~ -~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 /' ~ ~~ ~ ~t Ct 1 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 ~~,~ ~-- ~t~~~1 sy Anthon J. Ju an, re of Accounting & Loan Servicing fo e Pennsyly nia Housing Finance Agency, Attorney-in-Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency THOMAS 2285369 - ,.=~ °~ i ~ ..~ ._... "._S U. S . BANK NATIONAL ASSOCIATION AS IN THE COURT OF COMMON PLEAS OF _ -,~ '~ TRUSTEE FOR THE PENNSYLVANIA HOUSING : CUMBERLAND COUNTY, PENNSYLVANIA --- -~;+ ~-,t FINANCE AGENCY Plaintiff(s) c ~= r_.. !'~~ ~;• , _-~: - ~ ' - ' _ - i --~^a -.- 4 i c-i~ -, .- . _~ -_ N ` , c .t~: WALL T . THOMAS rr~~ ~~ I ~ ' ~ ~.,z c^. ~;~ :%=^ Defendant(s) ,p lJ 1 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 acourt-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 MidPenin 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 kre 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 W/SH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s r 9/24/12 Date Leon P. g:aller / Jill M. Wineka Attorney for Plainfiff Purcell, Krug and Haller 1719 North Front Street Harrisbur PA 17101 PA ID 1570a / 58802 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 ^ No ^ Listing date: Borrower Occupied: Yes ^ No ^ Mailing Address (if different) City: Phone Numbers: Home: Cell: State: Zip: Price: $ Realtor Phone: State: Zip: _ Office: 0th er: Email: # of people in household: How tong? • :• -• 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: 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 ^ No ^ If yes, provide names, location of court, case number 8c attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ _ Investments: $ $ Checking: $ $ Savings: $ $ _ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: _ Amount owed: Value: Other transportation (automobiles, boats, motorcyclesl: Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net, _ 2. Monthly Gross Monthly Net. 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthtv Expenses: (Please only include expenses you are currently pavinel 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 CableTV Child Support/Alim. Spending Money Day/Child Care/Tuft. 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: 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: .- I/We, .authorize the above named to use/refer this information to my lender/servicer for th~a 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 ~ Letter explaining reason for delinquency and any supporting documentation ~ (hardship letter) Listing agreement (if property is currently on the market) ~ Copy of 2 years of federal income tax returns ~ Copy of deed 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) . vs. WALI T. THOMAS Defendant(s) REQUEST FOR CONCILIATION CONFERENCE Civil Pursuant to the Administrative Order dated February 28 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff R Anderson ,',~ ~-~~, p~o_~F~/C'Y sl ; e~i i:.rn~tarr t .? 1. Jody S Smith ~.,~~. ~, Z~~,~© ~©~~T~R' Chief Deputy ~V Cr 23 ~ i~ P , Richard W Stewart ~BEiy~( ~~ 2~ ~ ~l solicitor EN~S~~ Aklq'~rY US Bank National Association vs. Case Number Wafi T. Thomas 2012-6040 SHERIFF'S RETURN OF SERVICE 10/02/2012 07:40 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 2284 Gleim Drive, Enola, Pennsylvania 17025, 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 2284 Gleim Drive. Enola, Pennsylvania 17025 is vacant. 10/08/2012 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: Wali T. Thomas, but was unable to {ocate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residentia{ Mortgage Foreclosure Diversion Program as not found as to the defendant Wali T. Thomas. Request for service at 2284 Gleim Drive, Enola, Pennsylvania 17025 is vacant. The Enola Postmaster has confirmed, Wali T. Thomas' new address is 3151 Cape Horn Road, #144, Red Lion, Pennsylvania 17356. SHERIFF COST: $69.00 October 10, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. WALI T. THOMAS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant No. I2-6040 ~•, ,::~. r~ - ~~: . ~ . ~,~ .. - _ . ~ ~- ,., C., . ~ ,~,. t ~ ,~~ -- _ . ~ ,,,. 1"~ - ' . .. ~'~ fir ~„, PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: November 19, 2012 PURCELL, KRUG, & HALLER BY Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 ~.~~ ~~ a~ Q g,,,al ~-~~ae3gy~ U. S. BANK NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY C-) CIVIL ACTION - LAW M Plaintiffs -) I ,I F* NO. 12-6040 CIVIL =.----) VS. Z:5 I -<r-3:> Ln Ca IN MORTGAGE FORECLOSURE r-;r- WALI T. THOMAS :X Co Defendant ORDER FOR SERVICE AND NOW, to wit, this -.�-7day of l 2013, upon consideration of the within Affidavit, is a pearing that a good faith investigation and effort to locate the Defendant, Wali T. Thomas, 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 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed by mailing) , to Defendant, Wali T. Thomas, at his last known addresses of 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and 6344 Galleon Drive, Mechanicsburg, Pennsylvania 17050, AND FURTHER, that in the event this case should be reduced to judgment and execution shall be issued, service upon the Defendant, Wali T. Thomas, 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, Wali T. Thomas, at his last known addresses of 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and 6344 Galleon Drive, Mechanicsburg, Pennsylvania 17050. BY THE COURT J 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. ACTION OF MORTGAGE FORECLOSURE WALI T. THOMAS Defendant No. 12-6040 PRAECIPE TO REINSTATE c ° ` w --� rncD o '�- Z�L7 TO THE PROTHONOTARY: �r{o a oC) ac z , Kindly reinstate the complaint on the above captioned matter. c DATE: April 11, 2013 PURCELL, KRUG, & HALLER B Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 S I--7T 30g' U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA IN THE COURT OF COMMON PLEAS HOUSING FINANCE AGENCY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 12-6040 Vs. CIVIL ACTION-LAW WALI T.THOMAS IN MORTGAGE FORECLOSURE Defendant(s) 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, Financial Worksheet and Request for Conciliation Conference 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 April 23,2013, addressed as follows: WALI T. THOMAS WALI T. THOMAS 2284 GLEIM DRIVE 6344 GALLEON DRIVE QUIGLEY COVE MECHANICSBURG, PA17050 ENOLA, PA 17025 Attached hereto is the original Certificate of Mailing postmarked April 23, 2013 along with the original Receipts for Certified Mail also postmarked April 23, 2013. Leon P. Haller SWORN to and subscribed t h 2�- d Way 0 r"t CZ 20&/ vZ Notary fZo%Public r-- rn CD My commission expires: =COMMOUNWE—ALTH OF LVANIA C) -Z zi LV '>C: IA Cj fyotarw Seat rn Bonita P Bonita E.Prussack,Notwy Pubiic ft (SEAL) city of Harrisburg,Dauphin county ou I Commission 0 W Commission B(drv�g 26,2013 �.t 2 or Notali6g PENNSYLVANIA HOUSING FINANCE AGENCY v. WALI T. THOMAS 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: WALI T. THOMAS Postmark: 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller 1719 North Front Street Postage: Harrisburg, PA 17102 One piece of ordinary mail addressed'to: Postmark: WALI T. THOMAS 6344 GALLEON DRIVE MECHANICSBURG, PA 17050 �ag� FF�F'Q CO " co cy .� PITNEY now" 02 1M $ 02.40° • 0004284324 APR 23 2013 MAILED FROM ZIPCODE 1710 2 7196 --- 9008 9111 8545 7209 - • TO: WALI T. THOMAS 7196 9008 9111 8545 7193 2284 GLEIM DRIVE TO: WALL T. THOMAS QUIGLEY COVE 6344 GALLEON DRIVE _ ENOLA, PA ]7025 MECHANICSBURG,PA 17050 SENDER: MSH/CO SVC a SENDER: MSHCO SVC • REFERENCE: PHFA/THOMAS i REFERENCE: PHFA/THOMAS i PS Form 3800 January 2005 RETURN Postage PS Form 3800 Janua 2005 RECEIPT Certified Fee � SERVICE 10 , RETURN Postage I Return Receipt Fee ' RECEIPT 2.55 SERVICE Certified Fee 1 110 Restricted Delivery Return Receipt Fee Total Postage&Fees 4.75 ' 2 i Restricted Delivery 4 i I USPSO POSTMAR .O,F 6ATE;� Total Postage&Fees �Z Receipt for ��� i LISPS* POS= AFiK�'R D TEO� Certified Mail"" rcS p Receipt for��L Z T '&o! r ' Certified Mail tS�� No Insurance Covere — rag Pravided 14a+" C Q n Do Not Use for Intemational Mall 7g5,'aadN�y No Insurance Coverage Prbvided �+ } Do Not Use for international Mail �8SI2l2lda SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson MED-aPPI�'L Sheriff � �r�p6 or THE PROTHONO Chief Deputy 2013 APIA 29 Richard W Stewart CUMBERLAND"* °- Solicitor OFFICE"7FTPES =FIFw T US Bank National Association Case Number vs. 2012-6040 Wali T. Thomas SHERIFF'S RETURN OF SERVICE 04/18/2013 06:08 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Wali T.Thomas, pursuant to Order of Court by"Posting"the premises located at 2284 Gleim Drive, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. Qv SON KINSLER, DEPUTY SHERIFF COST: $50.50 SO ANSWERS, April 22, 2013 RON R ANDERSON, SHERIFF C (c)County Suite Sheriff,'ieleosoft.Inc. F HLED-0 F FIU;r LEON P. HALLER, ESQUIRE €f f" THE PRO Ti ONO iAI\ PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET 20 13 MAY 22 AV,!, 11., it 7 HARRISBURG, PA 17102-2392 (717) 234-4178 CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF PENNSYLVANIA U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW VS . NO. 12 -6040 WALI T. THOMAS IN MORTGAGE FORECLOSURE Defendant MOTION TO LIFT STAY IMPOSED BY THE MORTGAGE FORECLOSURE DIVERSION PROGRAM AND NOW comes Plaintiff, U. S . Bank National Association Trustee for The Pennsylvania Housing Finance Agency, through it ' s counsel, Leon P . Haller , and in accordance with Paragraph (k) of the Order of February 28, 2012 , establishing the Mortgage Foreclosure Diversion Program, represents as follows : 1 . The within foreclosure action was filed September 26 , 2012 . 2 . Service of the Complaint and Notice of Residential Mortgage Foreclosure Diversion Program was made on April 18, 2013 . 3 . The within property is not owner occupied. 4 . Defendant, in his Bankruptcy, filed to No . 12 - 06606 in the Middle District of Pennsylvania, had indicated an intent or surrender the property, a copy of the Debtor ' s Statement of Intention attached hereto and made a part hereof as Exhibit "A" . t WHEREFORE, Plaintiff requests that the stay imposed by the Cumberland County Mortgage Foreclosure Diversion Program be lifted to allow Plaintiff to proceed with the foreclosure action. PURCELL, KRUG & HALLER By : Leon P . Haller 1719 North Front Street Harrisburg, PA 17102 -2392 (717 ) 234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: May 20, 2013 138(Form 8)(12/08) United States Bankruptcy Court Middle District of Pennsylvania In re Wall T Thomas Case No. Debtor(s) Chapter 7 CHAPTER 7 INDIVIDUAL DEBTOR'S STATEMENT OF INTENTION PART A-Debts secured by property of the estate. (Part A must be fully completed for EACH debt which is secured by property of the estate. Attach additional pages if necessary.) Property No. 1 Creditor's Name: Describe Property Securing Debt: Pa Housing Finance Agency 2284 Gleim Drive Enola,PA 17205 Property will be(check one): ■ Surrendered ❑Retained If retaining the property,I intend to(check at least one): ❑Redeem the property ❑Reaffirm the debt ❑ Other. Explain (for example,,avoid lien using 11 U.S.C. § 522(f)). Property is(check one): ❑Claimed as Exempt ■Not claimed as exempt PART B-Personal property subject to unexpired leases.(All three columns of Part B must be completed for each unexpired lease. Attach additional pages if necessary.) Property No. 1 Lessor's Name: Describe Leased Property: Lease will be Assumed pursuant to 11 -NONE- U.S.C. §365(p)(2): ❑ YES ❑ NO I declare under penalty of perjury that the above indicates my intention as to any property of my estate securing a debt and/or personal property subject to an unexpired lease. Date November 14,2012 Signature /s/Wall T Thomas Wall T Thomas Debtor Software Copyright(c)1996-2012 CCH INCORPORATED-www.testcase.com / C/ Best Case Bankruptcy I&MA Case 1:12-bk-06606-RNO Doc 1 Filed 11/14/12 Entered 11/14/12 13:46:59 Desc Main Document Page 34 of 46 VERIFICATION I verify that the statements made in the foregoing Petition to Lift Stay, are true and correct . I understand that false statements herein are made subject to the penalties of 18 Pa . C . S . Section 4904 relating to unsworn falsification to authorities . Leon P . Haller Dated : May 20 , 2013 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW vs . NO. 12 -6040 WALI T. THOMAS IN MORTGAGE FORECLOSURE Defendant CERTIFICATE OF SERVICE I, Leon P. Haller, the undersigned, Attorney for Plaintiff, hereby certify that I served on the 20th day of May, 2013, a copy of the Petition to Lift Stay Imposed by Mortgage Foreclosure Diversion Program upon each of the following persons at the addresses shown below: Wali T. Thomas 2284 Gleim Drive Quigley Cove, PA 17025 Wali T. Thomas 6344 Galleon Drive Mechanicsburg, PA 17050 Wali T. Thomas Suite 144 3151 Cape Horn Drive Red Lion, PA 17356 Leon P. Haller Dated: May 20, 2013 Attorney for Plaintiff f • u U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW VS . NO. 12 -6040 WALI T. THOMAS IN MORTGAGE FORECLOSURE Defendant ORDER AND NOW, this Z y` day of ?27 , 2013 , upon consideration of Plaintiff Petition to Lift Stay, Notice of the Residential Mortgage Foreclosure Diversion Program having been served on April 18, 2013 and Defendant having not opted to participate in the Mortgage Foreclosure Diversion Program, IT IS HEREBY ORDERED that the stay imposed by the Mortgage Foreclosure Diversion Program be lifted and Plaintiff may proceed with its mortgage foreclosure action. BY THE COURT: J. C) MOD� a; -� Uj k X- CD , c- C/V 'CD "t� U.S. BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA : TRUSTEE FOR THE PENNSYLVANIA HOUSING r FINANCE AGENCY, CIVIL ACTION LAW PLAINTIFF NO. 12-6040 U VS. C-n C WALI T. THOMAS, MORTGAGE FORECLOSURE �:p DEFENDANT(S) x'C) =C) PRAECIPE � � un TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) WALI T. THOMAS 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 $171,721.08 Interest $3,929.01 Per diem of$21.47 From 04/01/2012 To 10/01/2012 Accumulated Late Charges $44.73 Late Charges $223.75 ($44.73 per month to 10/01/2012) Escrow Deficit $1,291.30 5% Attorney's Commission $8,586.05 TOTAL $185,795.92 "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 & HA h: By on P. Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 X14 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. 12-6040 IN MORTGAGE FORECLOSURE WALI T.THOMAS, DEFENDANT(S) CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on May 24, 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 aller PA I.D. # 15700 ttorney for Plaintiff Purcell, Krug& Haller 1719 North Front Street Harrisburg, PA 17102 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK, NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW WALI T. THOMAS NO. 2012-6040 Defendant IN MORTGAGE FORECLOSURE To: WALI T. THOMAS 2284 GLEM DRIVE QUIGLEY COVE, PA 17025 WALI T. THOMAS 3151 CAPE HORN ROAD 4144 RED LION, PA 17356-9071 WALI T. THOMAS 6344 GALLEON DRIVE MECHANICSBURG, PA 17050 DATE OF NOTICE: MAY 24, 2013 IMPORTANT NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE 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 TELEPHONE (717)249-3166 (800)990-9108 PURCELL, KRUG & HALLER By: eon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #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. 12-6040 WALI T.THOMAS, IN MORTGAGE FORECLOSURE DEFENDANT AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA 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 Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. Sworn to and subscribed before me this day of 20./3 HALLER, ESQUIRE of y P lic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARYLAND K FERRETTI,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. 12-6040 WALL T.THOMAS, IN MORTGAGE FORECLOSURE DEFENDANT NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA 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 is not in the Military or Naval Service nor engaged in any way which would bring him within the Servicemembers' Civil Relief Act. A copy of the search through the Defense Manpower Data Center website is attached. Sworn to and subscribed before me this J51 day of 20,,�3 )✓ N P. HALLER, ESQUIRE Not ry u lic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARYLAND K.FERRETTI,Notary Public Lower Paxton Twp.,Dauphin County My Commission Expires Aug.S,2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW AT NO. 12-6040 U.S. BANK NATIONAL ASSOCIATION,AS Total Judgment Amount TRUSTEE FOR THE PENNSYLVANIA HOUSING $185,795.92 FINANCE AGENCY, Interest $7,102 82 Per diem of$21.47 to sale PLAINTIFF date 9/4/2013 Late Charges $491.93 VS. $44.73 per month to sale date 9/4/2013 WALI T.THOMAS, Escrow Deficit $2,650.51 DEFENDANT(S) TOTAL WRIT $196,041.18 *Plus additional interest,late charges and other costs to date of sheriffs 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 FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. ro a--z 4 co t-- s-rl-- Date: May 31, 2013 v �0 Cea' T� t-t Attorney for Plaintiff �- 1719 North Front Street P. Haller �' C Harrisburg, PA ]7102 �� c'a °r� PA I.D. #15700 (717)234-4178 WRIT OF EXECUTION-MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLV NIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND C LINTY: - To satisfy the judgment, interest and co sin the ab a captioned case,you are directed to levy upon and sell the property described in the attached descript n kno as 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 Date: P HONOTARY/CLERK CIVIL DIVISION BY lOq..©O CEF DEPUTY S7.bo 09F 11.75 r, L4 3.0(> a " /10. S4 5o ri <<� � ` 3. 56 Ib3. 75 0 S n<<�N 1.k_4-a-160w/ � a9 14I`� r► d pe I)Foed ALL THAT CERTAIN UNIT,being Unit No. 18 (the "Unit") of Quigley Cove, A Planned Community (the"Community") , such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove, A Planned Community (the"Declaration") and Declaration Plats and Plans recorded in Cumberland County Instrument No. 200744632, together with any and all amendments thereto. TOGETHER with the undivided Allocated Interest appurtenant to the Unit as more particularly set forth in the aforesaid Declaration, as last amended. TOGETHER with the right to use any Limited Common Elements appurtenant to the Unit being conveyed,pursuant to the Declaration and Declaration Plats and Plans, as last amended, UNDER AND SUBJECT to the Declaration; to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record in the aforesaid Office; and to matters which a physical inspection or survey of the Unit and any Common Elements would disclose. THE CONDOMINIUM UNIT erected thereon is common known as 2284 Gleim Drive, Enola, PA 17025. PARCEL NO. 10-13-0997-040 BEING THE SAME premises which Creek Valley Associates, L.P. by deed dated 07/06/10 and recorded 07/22/10 in Cumberland County Instrument No. 201019710, granted and conveyed unto Wali T. Thomas. TO BE SOLD AS THE PROPERTY OF WALI T. THOMAS ON JUDGMENT NO. 12-6040 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. 12-6040 WALI T.THOMAS, 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 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025: 1. - Name and address of the Owner(s) or Reputed Owner(s): WALI T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE c= .-O-r . ZZ ENOLA, PA 17025 Mw C- WALI T. THOMAS r,> c-In ICJ C:; ic:D 6344 GALLEON DRIVE MECHANICSBURG, PA 17050 )>C--) I CD C= Cn WALI T. THOMAS 3151 CAPE HORN ROAD #144 RED LION, PA 17356-9071 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: Arnerichoice Federal Credit Union 2175 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Americhoice Federal Credit Union 20 Sporting Green Drive Mechanicsburg, PA 17050 Darrell C. Dethlefs, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Fulton Bank, N.A. c/o Eugene E. Pepinsky, Jr., Esquire 210 Walnut Street P. O. Box 11963 Harrisburg, PA 17108-1963 Fulton Bank, N.A. 200 N. Third Street Harrisburg, PA 17101 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 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 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 Lawrence V. Young, Esquire CGA Law Firm 135 North George Street York, PA 17401 (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 unworn falsification to authorities. L-e- alter PA 1.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:May 31, 2013 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 NO. 12-6040 vs. IN MORTGAGE FORECLOSURE WALI T.THOMAS, DEFENDANT(S) NOTICF, OF SHERIFF'S SALE OF REAL ESTATE -0 PURSUANT TO r PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate)will be held: CD ­ 7-- DATE: Wednesday, September 04,2013 r ) 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: 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-6040 JUDGMENT AMOUNT$185,795.92 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: WALT T. THOMAS 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 UNIT,being Unit No. 18 (the"Unit") of Quigley Cove, A Planned Community (the"Community") , such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove,A Planned Community(the"Declaration") and Declaration Plats and Plans recorded in Cumberland County Instrument No. 200744632, together with any and all amendments thereto. TOGETHER with the undivided Allocated Interest appurtenant to the Unit as more particularly set forth in the aforesaid Declaration, as last amended. TOGETHER with the right to use any Limited Common Elements appurtenant to the Unit being conveyed, pursuant to the Declaration and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to the Declaration; to any and all covenants, conditions, restrictions, rights of way,easements and agreements of record in the aforesaid Office; and to matters which a physical inspection or survey of the Unit and any Common Elements would disclose. THE CONDOMINIUM UNIT erected thereon is common known as 2284 Gleim Drive, Enola, PA 17025. PARCEL NO. 10-13-0997-040 BEING THE SAME premises which Creek Valley Associates, L.P. by deed dated 07/06/10 and recorded 07/22/10 in Cumberland County Instrument No. 201019710, granted and conveyed unto Wali T. Thomas. TO BE SOLD AS THE PROPERTY OF WALI T. THOMAS ON JUDGMENT NO. 12-6040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-6040 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 WALI T.THOMAS (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: $185,795.92 L.L.:$.50 Interest PER DIEM OF$21.47 TO SALE DATE 9/4/2013-$7,102.82 Atty's Comm: Due Prothy:$2.25 Atty Paid: $.1163.S0 Other Costs:LATE CHARGES-$44.73 PER MONTH TO SALE DATE 9/4/2013-$491.93 ESCROW DEFICIT-$2,650.51 Plaintiff Paid: Date: 6/5/13 6a 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. 12-6040 WALI T.THOMAS, IN MORTGAGE FORECLOSURE DEFENDANT SUPPPLEMENTAL RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on (, [A0 ►3 , 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 snail (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: � r QUIGLEY COVE HOMEOWNERS c m; ASSOCIATION rrnco 2961 SPANGLER ROAD MANHEIM, PA 17545 `" T C:)r'; HAMPDEN TOWNSHIP =C3 _ Z r` 230 SOUTH SPORTIN HILL ROAD n c:' '� MECHANICSBURG, PA 17050 By PURC1 !XRUG &DIALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES AG/u� d' 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 HERSHEY LEON P.HALLER TELEPHONE(717)234-4178 (717)533-3836 JOHN W.PURCELL JR. FAX(717)234-1206 JILL M.WINEKA LISA RYNARD QUIGLEY COVE HOMEOWNERS ASSOCIATION 2961 SPANGLER ROAD MANHEIM, PA 17545 HAMPDEN TOWNSHIP 230 SOUTH SPORTIN HILL ROAD MECHANICSBURG, PA 17050 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, b 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. 12-6040 WALI T.THOMAS, 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, 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: 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-6040 JUDGMENT AMOUNT $185,795.92 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: WALI T. THOMAS 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 UNIT, being Unit No. 18 (the "Unit") of Quigley Cove, A Planned Community (the"Community") , such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove, A Planned Community (the "Declaration") and Declaration Plats and Plans recorded in Cumberland County Instrument No. 200744632, together with any and all amendments thereto. TOGETHER with the undivided Allocated Interest appurtenant to the Unit as more particularly set forth in the aforesaid Declaration, as last amended. TOGETHER with the right to use any Limited Common Elements appurtenant to the Unit being conveyed, pursuant to the Declaration and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to the Declaration; to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record in the aforesaid Office; and to matters which a physical inspection or survey of the Unit and any Common Elements would disclose. THE CONDOMINIUM UNIT erected thereon is common known as 2284 Gleim Drive, Enola, PA 17025. PARCEL NO. 10-13-0997-040 BEING THE SAME premises which Creek Valley Associates, L.P. by deed dated 07/06/10 and recorded 07/22/10 in Cumberland County Instrument No. 201019710, granted and conveyed unto Wali T. Thomas. TO BE SOLD AS THE PROPERTY OF WALI T. THOMAS ON JUDGMENT NO. 12-6040 PENNSYLVANIA HOUSING FINANCE AGENCY v. WALI 1'. THOMAS Cumberland County Sale 9/4/2013 U. S. POSTAL SERVICE ry 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: QUIGLEY COVE HOMEOWNERS ASSOCIATION 2961 SPANGLER ROAD MANHEIM, PA 17545 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug&Haller Postage: 1719 North Front Street Han-isburg,PA 17102 One piece of ordinary mail addressed to: Postmark: HAMPDEN TOWNSHIP 230 SOUTH SPORTIN HILL ROAD MECHANICSBURG, PA 17050 r F F 02 1M $ 02.4 • 0004284324 AUG06 20 MAILED FROM ZIPCODE 1 71 A 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. 12-6040 WALI T.THOMAS, IN MORTGAGE FORECLOSURE DEFENDANT(S) RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on J 1 a 1 a(3)3 , 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: WALI T. THOMAS 2284 GLEIM DRIVE c QUIGLEY COVE ENOLA, PA 17025 irrn z;o WALI T. THOMAS 6344 GALLEON DRIVEj''" - T" MECHANICSBURG, PA 17050 WALI T. THOMAS 3151 CAPE HORN ROAD #144 RED LION, PA 17356-9071 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street c �' Carlisle, PA 17013r3 rn co c,y TENANT/OCCUPANT �A 2284 GLEIM DRIVE QUIGLEY COVE 4 ENOLA, PA 17025 t>° Lawrence V. Young, Esquire CGA Law Firm 135 North George Street York, PA 17401 Americhoice Federal Credit Union 2175 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Americhoice Federal Credit Union 20 Sporting Green Drive Mechanicsburg, PA 17050 Darrell C. Dethlefs, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Fulton Bank, N.A. c/o Eugene E. Pepinsky, Jr., Esquire 210 Walnut Street P. O. Box 11963 Harrisburg, PA 17108-1963 Fulton Bank, N.A. 200 N. Third Street Harrisburg, PA 17101 By PU RUG & HALLER A rneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 LEON P.HALLER TELEPHONE(717)234-4178 HERSHEY JOHN W.PURCELL JR. FAX(717)234-1206 (717)533-3836 JILL M.WINEKA LISA RYNARD WALI T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 WALI T. THOMAS 6344 GALLEON DRIVE MECHANICSBURG, PA 17050 WALI T. THOMAS 3151 CAPE HORN ROAD #144 RED LION, PA 17356-9071 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 Lawrence V. Young, Esquire CGA Law Firm 135 North George Street York, PA 17401 Americhoice Federal Credit Union 2175 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Americhoice Federal Credit Union 20 Sporting Green Drive Mechanicsburg, PA 17050 Darrell C. Dethlefs, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Fulton Bank,N.A. c/o Eugene E. Pepinsky, Jr., Esquire 210 Walnut Street P. Q. Box 11963 Harrisburg,PA 17108-1963 Fulton Bank,N.A. 200 N. Third Street Harrisburg, PA 17101 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 being notified of said Sheriffs Sale. By: Haller PA H 15700 --�-'-Xttomey 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. 12-6040 WALI T.THOMAS, fN 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, 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: 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-6040 JUDGMENT AMOUNT$185,795.92 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: WALI T. THOMAS 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: L 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 UNIT,being Unit No. 18 (the "Unit")of Quigley Cove, A Planned Community (the "Community") , such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove, A Planned Community (the "Declaration") and Declaration Plats and Plans recorded in Cumberland County Instrument No. 200744632, together with any and all amendments thereto. TOGETHER with the undivided Allocated Interest appurtenant to the Unit as more particularly set forth in the aforesaid Declaration, as last amended. TOGETHER with the right to use any Limited Common Elements appurtenant to the Unit being conveyed,pursuant to the Declaration and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to the Declaration; to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record in the aforesaid Office; and to matters which a physical inspection or survey of the Unit and any Common Elements would disclose. THE CONDOMINIUM UNIT erected thereon is common known as 2284 Gleirn Drive, Enola, PA 17025. PARCEL NO. 10-13-0997-040 BEING THE SAME premises which Creek Valley Associates, L.P. by deed dated 07/06/10 and recorded 07/22/10 in Cumberland County Instrument No. 201019710, granted and conveyed unto Wali T. Thomas. TO BE SOLD AS THE PROPERTY OF WALI T. THOMAS ON JUDGMENT NO. 12-6040 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. 12-6040 CIVIL -TJ VS. IN MORTGAGE FORECLOSURE WALI T. THOMAS Defendant t , ORDER FOR SERVICE 7V AND NOW, to wit, this S''� day of ,I 2013,4 upon' consideration of the within Affidavit, is appearing that a good faith investigation and effort to locate the Defendant, Wali T. Thomas, 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 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed by mailing) , to Defendant, Wali. T. Thomas, at his last known addresses of 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and 6344 Galleon Drive, Mechanicsburg, Pennsylvania 17050, AND FURTHER, that in the event this case should be reduced to judgment and execution shall be issued, service upon the Defendant, Wali T. Thomas, 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, Wali T. Thomas, at his last known addresses of 2284 Gleim Drive, Quigley Cove, Enola, Pennsylvania 17025 and 6344 Galleon Drive, Mechanicsburg, Pennsylvania 17050. BY THE COURT J. 7196 9008 9111 8545 1948_ — ���— ----- — — 7196 9008 9111 8545 1924_ TO: WALI T. THOMAS 3151 CAPE HORN ROAD#144 TO: WALI T. THOMAS RED LION,PA 17356-9071 ' 6344 GALLEON DRIVE MECHANICSBURG,pA 17050 f� is SENDER: P01455/38975 SENDER: REFERENCE: NOS 09/04/13 P01455/38975 REFERENCE: NOS 09/04/13 . k I I PS Form 3800 Janua 2005 PS Form 3800 2005 RETURN Postage Janua RECEIPT RETURN Postage SERVICE Certified Fee !(� RECEIPT Return Receipt Fee > I SERVICE Certified Fee Restricted Delivery Return Receipt Fee I Delivery Total Postage$Fees Restricted I V Total Postage$Fees 4 75 j USPS• P Receipt.for ``< < '� usPS• 9 ARK pia Receipt for �� �= j Certified Mail'" Certified Mail - Do co No Insurance Coverage Provided I Do Not Use for Intemat,'onat Map No Insurance Do Not Use Coverage t Pro O a +���\ for International Map !(� '4 7196 9008 9111 8545 1931_ `- - TO: WALI T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 SENDER: I P01455/38975 1 REFERENCE: -NOS 09/04/13 I PS Form 3800 Janua 2005 RETURN Postage RECEIPT Certified Fee f SERVICE � Return Receipt Fee Restricted Delivery 4 S � Total Postage$Fees -U(o USPS• POSTMAR p jReceipt for Certified Mail- � No Insurance Coverage Prbvided 4 r Do Not Use for International Mail / PENNSYLVANIA HOUSING FINANCE AGENCY v. WALI T.THOMAS Cumberland County Sale 9/4/2013 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 38771 Received from: Purcell,Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: WALI T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 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: WALI T. THOMAS 6344 GALLEON DRIVE MECHANICSBURG, PA 17050 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: WALI T. THOMAS 3151 CAPE HORN ROAD #144 RED LION, PA 17356-9071 yc l r. ®Ems 02 IM $ 01.200 ` 0004284324 JUL 12 2013 MAILED FROM ZIP CODE 1710 2• U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: Lawrence V. Young, Esquire CGA Law Firm 135 North George Street York, PA 17401 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: Americhoice Federal Credit Union 2175 Bumble Bee Hollow Road Mechanicsburg, PA 17055 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: Americhoice Federal Credit Union 20 Sporting Green Drive Mechanicsburg, PA 17050 H,y N w c PN' a L 02 1M 15 01.20° 0004284324 JUL 12 2013 MAILED FROM ZIP CODE 1710 2 U.S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: Darrell C. Dethlefs, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: Fulton Bank, N.A. c/o Eugene E. Pepinsky, Jr., Esquire 210 Walnut Street P. O. Box 11963 Harrisburg, PA 17108-1963. 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: Fulton Bank, N.A. 200 N. Third Street -AR9�.s Harrisburg, PA 17101 G Qn c� 'o w o P PM"SOMPES 02 1M $ 01.200 0004284324 JUL 12 2013 MAILED FROM ZIP CODE 1710 2 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: 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 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025 � s c ' w: � a 02 1M $ 02.40° 0004284324 JUL12 2013 • MAILED FROM ZIP CODE 1 710 2 U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLANDCOUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF CIVIL ACTION- LAW VS. NO. 12-6040 WALI T. THOMAS, DEFENDANT IN MORTGAGE FORECLOSURE SUPPLEMENTAL 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 2284 GLEIM DRIVE QUIGLEY COVE ENOLA,PA 17025: 1. Name and address of the Owner(s)or Reputed Owner(s): WALI T. THOMAS 2284 GLEIM DRIVE QUIGLEY COVE ENOLA, PA 17025 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: QUIGLEY COVE HOMEOWNERS t-) ASSOCIATION ~' w 2961 SPANGLER ROAD rn= cn ZE_- MANHEIM, PA 17545 =:� t� :z HAMPDEN TOWNSHIP -C> 230 SOUTH SPORTIN HILL ROAD Vic' ,. =rte MECHANICSBURG, PA 17050 _ r 3�C= cp 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 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: Tenants if any . . . DOMESTIC RELATIONS OFFICE (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. 1 understand that false statements herein are �e ma t to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authoritie %7 Leon P.Valler.PA T.D. #15700 Purcell, Krug& Haller 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 DATED: August 6, 2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r, - FIT EI 'aFf�iCL- THE Jody S Smith Chief Deputy ° 13 tffl 22 AP1 8: Richard W Stewart CUMBERLAND Solicitor OFFICE OF THE SHERIFF COUy f Y PENNSYLVA141A US Bank National Association Case Number vs. Wali T. Thomas . 2012-6040 SHERIFF'S RETURN OF SERVICE 06/25/2013 07:47 PM - Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 2284 Gleim Drive-Quigley Cove, Hampden Township, Enola, PA 17025, Cumberland County. 06/25/2013 07:47 PM - Deputy Noah Cline, 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: Wali T. Thomas, pursuant to Order of Court by"Posting"the premises located at 2284 Gleim Drive, Hampden Township, Enola, PA 17025, Cumberland County with a true and correct copy according to law. 09/03/2013 As directed by Leon P. Haller,Attorney for the Plaintiff, Sheriffs Sale Continued to 10/2/2013 10/02/2013 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, Cumberland County, PA on October 2, 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: $988.85 SO ANSWERS, November 20, 2013 RbNW R ANDERSON, SHERIFF W ,Ole pol• - �6 a9�s'ss (c)CountySuite Sheriff,Teleosoft.Inc. On June 10, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 2284 Gleim Drive- Quigley Cove, Enola, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: June 10, 2013 By: Real Estate Coordinator L h Z a 9 LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012-6040 Civil Term TO BE SOLD AS THE PROPERTY OF WALI T.THOMAS ON JUDGMENT US BANK NATIONAL ASSOCIATION NO. 12-6040. vs. WALI T.THOMAS Atty.: Leon P.Haller ALL THAT CERTAIN UNIT, being Unit No. 18 (the "Unit") of Quigley Cove, A Planned Community (the "Community") , such Community being located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Dec- laration of Covenants and Restric- tions for Quigley Cove, A Planned Community (the "Declaration") and Declaration Plats and Plans recorded in Cumberland County Instrument No. 200744632, together with any and all amendments thereto. TOGETHER with the undivided Allocated Interest appurtenant to the Unit as more particularly set forth in the aforesaid Declaration, as last amended. TOGETHER with the right to use any Limited Common Elements ap- purtenant to the Unit being conveyed, pursuant to the Declaration and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to the Declaration;to any and all covenants, conditions,restrictions,rights of way, easements and agreements of record in the aforesaid Office; and to mat- ters which a physical inspection or survey of the Unit and any Common Elements would disclose. THE CONDOMINIUM UNIT erect- ed thereon is common known as 2284 Gleim Drive,Enola,PA 17025. PARCEL NO. 10-13-0997-040. BEING THE SAME premises which Creek Valley Associates, L.P. by deed dated 07/06/10 and record- ed 07/22/10 in Cumberland County Instrument No.201019710,granted and conveyed unto Wali T.Thomas. 116 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 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. VLisa Marie Co/he, Editor SWORN TO AND SUBSCRIBED before me this 9 dav of August, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY my Commission Expires Apr 28,2014 The Patriot-News Co. • _, 1900 Patriot Drive i4e atr10t1WX(W5 6, Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller 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 1900 Patriot Drive, 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 he 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 he 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. 2012-6040 Cl vll Term This ad ran on the date(s)shown below: ' US NK NATIONAL 07/28/13 ASSOCIATIO 08/04/13 VS. WALI T.THOMAS 08/11/13 Atty: Leon P.Haller 5p ALL THAT CERTAIN UNIT,being Unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . No. 18 (the "Unit') of Quigley Cove, A Via' Planned Community (the "Community") PL, such Community being located in ad` Sw 1�nj subscribed before me thi 3 of August, 2913 A.D. Hampden Township, Cumberland County> Pennsylvania,which Unit is designated in the Declaration of Covenants and Restrictions for Quigley Cove, A Planned Community (the"Declaration') and Declaration Plats ` dry b Ic and Plans recorded in Cumberland County Inswment No.200744632,together with any d and all amendments thereto. TOGETHER with the undivided Allocated COMMONWEALTH OF PENNSYLVANIA Interest appurtenant to the Unit as more Nota.. Seel particularly set forth in the aforesaid Holly Lynn Warfel,Notary Public Declaration,as last amended. TOGETHER with t't6 Wasitington Twp.,Dauphin County "'+ use any Limited Common Elements appurtenant My Cbtflmisslon Expires Dec.12,2016 to the Unit being conveyed,pursuant to the c MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 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 2nd day of October A.D., 2013, under and by virtue of a writ Execution issued on the 5th day of June, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 6040, at the suit of U.S. Bank, N.A. as Trustee for the Pennsylvania Housing Finance Agency against Wali T. Thomas is duly recorded as Instrument Number 201337499. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c2 ""� day of A.D. M1 C Recorder of Deeds Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2014