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HomeMy WebLinkAbout12-7115U.S. BANK NATIONAL ASSCOIATION AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY plaintiff(s) vs. JACQUELINE WOLF AND STANLEY WOLF Defendant(s) c-~ rv ~) r. i iN THE COURT OF COMMON PLEAS OF -~:,~ rv -a CUMBERLAND COUNTY, PENNSYLVANIA Zm ~ rim ~ ~ ~~ `.` -t~ ~ r- ~ ~ c~ .~ ~ ~ ~-rr ~ ~ w ~ ~ 1,,, i // S / Civil "'~ . 1P ~ ~ Y: -e: 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 MidPenn Legal Services at (717)243-9400 extension 2510 or {800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you t0 contact MidPenn Legai Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROQRAM IS FREE. Respectfuliy}~ittgA7 11/19/12 Date Leon P . Haller / ill M. Wineka Attorney_ .for Plainttiff Purcell, Krug and Haller 1719 North Front Street Harrisbur PA 17101 PA ID 1570a / 58802 U . S . BANK NATIONAL ASSOCIATION AS ; IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOIISING FINANCE AGENCY Plaintiff(s) vs. JACQUELINE WOLF AND STANLEY WOLF Defendant(s) REQUEST FOR CONC/L/AT/ON 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 Defendants Counsel/Appointed Date Legal Representative Signature of Defendant Signature of Defendant Date Date Cumberland County Resldentla/ 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? Yes ^ No ^ Realtor Name: Borrower Occupied: Yes ^ No ^ Mailing Address (if different) City: Phone Numbers: Home: Cell: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: Listing date: Home: Cell: State• Zip: _ Price: $ Realtor Phone: State• Zip: _ Office: Other: How IOnA? State: Office: Other: Zip: # 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 & attorney: Assets Amount Owed: Home: $ Other Real Estate: $ Retirement Funds: $ Investments: $ Checking: $ Savings: $ 0th er: $ Automobile #1: Model: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles. boats, motorcvclesl• Model: _ Year: Amount owed: Value: Year: Year: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. 2. Borrower Pay Days: Monthly Gross Monthly Gross Monthly Gross Monthly Amount: _ Monthly Amount: _ Co-Borrower Pay Days: _. __ -__ ____ _ _ EXPENSE ~... ...~.-. ~.. ....rw vv ~.~. AMOUNT • • P 111 EXPENSE AMOUNT Mort age Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Payment Cable TV Child Su ort/Alim. S ndin Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Email: Value: Monthly Net Monthly Net Monthly Net Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: I/We, _ named purpose of evaluating understand that I/we named Phone: authorize the above to use/refer this information to my lender/servicer for the sole my financial situation for possible mortgage options. I/we am/are under no obligation to use the services provided by the above Borrower Signatu re Borrower Signature Date Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff vs. JACQUELINE WOLF AND STANLEY WOLF Defendants r~. :3~ .,.' "'~' f Tl C"~ ...-. ~ •7~ .:i ~ c- .._ <~' _~. _.. , - - r' f'S ~ ~ car r z ' "' .1_G C- ~:~ ~ i"i ~~ c~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C]VIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE l~ - 7/lS ~~v ~L ~~~~ THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth. in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be' entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE 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 ~/03, 7S ~C/ CARLISLE, PA 17013 717-249-3166 ~ ~~c~~s" p~ ~ 80 4~5 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. JACQUELINE WOLF AND STANLEY WOLF, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff vs. JACQUELINE WOLF AND STANLEY WOLF, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 and as amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through the Pennsylvania Housing Finance Agency ("Agency"), its appointed Limited Power of Attorney, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. The Limited Power of Attorney executed October 4, 2006 between the Plaintiff and the Agency is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 11, 2006 in Book 731, Page 421. The Limited Power of Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 2. Defendants, JACQUELINE WOLF and STANLEY WOLF, are adult individuals whose last known address is 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055. 3. On or about, July 17, 2008, the said Defendants executed and delivered a Mortgage Note in the sum of $160,700.00 payable to PENNSYLVANIA HOUSING FINANCE AGENCY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on July 24, 2008 as Instrument Number 200825230 conveying to original Mortgagee the subject premises. 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 is incorporated herein by reference. 5. The land subject to the Mortgage is: 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055 and is more particularly described in Exhibit "C" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July O 1, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $154,864.68 Interest at $34.20 per day $6,258.60 From 06/01 /2012 To 12/01 /2012 ( based on contract rate of 7.9500%) Accumulated Late Charges $2,515.24 Late Charges $58.68 $293.40 From 07/01 /2012 to 12/01 /2012 Escrow Deficit $1,774.55 Attorney's Fee at 5% of Principal Balance $7,743.23 TOTAL $173,449.70 **Together with interest at the per diem rate noted above after December O1, 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 September 24, 2012 is attached hereto as Exhibit "D". 9. The Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Service Members Civil Relief Act, as amended. Copies of the website reports from the Department of Defense Manpower Data Center, confirming non-active military duty are attached as Exhibit "E". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.9500% ($34.20 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. sy: 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) FIXED RATE NOTE ,} DATE Zcr~~ Camp Hill Pennsylvania ~ 506 Mount Allen Drive, Mechanicsburg, Pa 17055 (PROPERTY ADDRESS) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay One Hundred Sixty Thousand Seven Hundred ($160,700.00) Dollars (this amount is called "Principal") plus interest, to the order of the Lender. The Lender is: PENNSYLVANIA HOUSING FINANCE AGENCY I will make all 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." 2. 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 7.95%. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 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 first day of each month beginning on September 1, 2008. 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 August 1, 2038, I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at: PENNSYLVANIA HOUSING FINANCE AGENCY, 211 NORTH FRONT STREET, HARRISBURG, PA 17111 (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $1173.56 Note: Single Family-FNMA/FHLMC Page 1 of 3 ~/~~I 1, ~ / J l ~ << f~ l t 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they aze due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, [will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not [Wade all the monthly payments due under this note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use all of 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. If 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 to those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan chazges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the pernutted limits, then: (a) any such loan charge shall be reduced by the amount Necessary to reduce the charge to the pernritted limit; and (b) any sums already collected from me which exceed permitted limiu 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 rtx. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE 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 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the chazge will be 5.00% of my overdue payment of principal and interest. [will pay this late chazge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will 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 date, the Note Holder may require me to pay immediately the full amount of Principal which as not been paid and all the interest that I owe on that mount. That date must be at Lease 30 days after 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 mt to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (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 applicablc law. Those expenses include, for example, reasonable attorney's fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Notc will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by fast 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. Note Single Family FNMA/FHLMC Page 2 of 3 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the pmmise to pay the full aawunt owed. Any person who is a guarantor, surety or endorser of ibis Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This rneans that any one of us may be requircd to pay all of the amounts owed under this Note. 9. WAIVERS [ 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 paymnt 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 (the "Security Instrument"), dated the same date as this Note, 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 irnnxdiate payment in full of all amounts that 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 Property is sold or transferred (or if Borrower is not a naturat person 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 Instrument. 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 15 within which Borsower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender tray invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. ~ (SEAL) BORROWER ~w.4+-*~-- ~~'~ (SEAL) AC ELINE WOLF, BORROWER NOTE-SINGLE FAMII.Y FNMA/FHLMC Page 3 of 3 Prepared by: U.S. Bank National Association c/o PHFA-Legal Division 211 North Front Street, P.O. Box 8029 Harrisburg, Pennsylvania 17105-8029 717-780-3845 or 1-800-346-3597 ext. 3845 Return to: same as above Property Parcel Number: 42282423144 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): JACQUELINE WOLF STANLEY WOLF Secured by the real property located at: 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055-6 i i l Municipality: MECHANICSBURG County Recorded in: CUMBERLAND Original Mortgagee: PENNSYLVANIA HOUSING FINANCE AGENCY Original Principal Amount: $160,700.00 Mortgage recorded: JULY 24, 2008, Mortgage Assignment #200825230. IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of Mortgage to be executed by its duly authorized officer. Dated: OCTOBER 22, 2012 PENNSYLVANIA HOUSING FINANCE AGENCY Thomas F. Brzana, Jr., Director of Loan Servicing COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On the ~~ day of ~_~~~2012, before me, the undersigned, personally appeared Thomas F. Brzana, Jr., Director of Loan Servicing, authorized officer of 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. ~~c ~1~, Notary Public M ~yy~llt/-Liii OF pENi~LVAN NotaHe) Seal CERTIFICATE OF RESIDENCE OF ASSIGNEE ~ ~ AYE, Notary ~~ City of Hbrtistxrp, Uauphki County The below officer certifies that the principal business and mailing address for this as ' .15, 2015 U.S. Bank National Association, c/o PHFA, 211 North Front Street, Harrisb ox of riot Authorized Officer Julie F. IA aa~s ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the public road leading from U.S. Route 15 to Lisburn being 268 feet in a southerly direction by same from Bowmansdale Road and at corner of lands of Geroge Markel; thence by the center line of said road South 8 degrees 15 minutes East 100 feet to a point; thence by the dividing line between Lots Nos. 124 and 125 on the herienafter mentioned Plan of Lots South 84 degrees 53 minutes West 168 feet to a pin; thence by other lands now or formerly of Arthur L. Replogle North 8 degrees 15 minutes West 100 feet to a point at a pin at lands now or formerjy of Markle; thence by lands of said George Markle North 84 degres 53 minutes East 168 feet to the place of BEGINNING. Pennsylvania ~OUSIng Finance Agency _Accountin~ & Loan Servicin 211 North Front Street, P. U. Box 15057 Harrisburg, PA 1 71 05-505 7 (800) 346-3597 FAX (717) 780-3899 TTY (717) 780-1869 CERTIFIED MAIL -RETURN RECEIPT REQUESTED 9/24/2012 RE: Account No. 1753870 JACQUELINE WOLF STANLEY WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 1 7055-61 1 1 RE: 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 1 7055-61 1 1 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by (hereinafter We, Us or Ours) on your property located at 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 1 7055-61 1 1, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,719.00 for 7/2012 through 9/2012 for a total of $5,157.00. Late charges and NSF charges that have accrued to this date in the amounts of $2,691.28 and $.00 respectively, are also due. The total listed below includes all fees (including inspections and securing that needed to be .completed) less any funds we are holding in suspense. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $7,956.28. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $7,956.28, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash in our office, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgageed 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, 'rf legal proceedings are started against you, you will have to pay the reasonable attorney's fees, evenrf 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. f~ ~ ( FHAACT/dtmdocs/ALSV/ We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriffps foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-822-7375. This payment must be made payable in cash in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND AT'TORNEY'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 'rf no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualffy for replacement insurance 'rf you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Sincerely, ~~ TLG/ Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105-5057 FH AACTldtmdocs/ALSV/ ,Pennsylvania Housing Finance Agency Accounting & Loan serviiciin 211 North Front Street, P. U. Boz 1 SOS7 Harrisburg, PA 17105-5057 (800) 346-3597 FAX (717) 780-3899 TTY (717) 780-1869 NOTICE 9/24/2012 JACQUELINE WOLF STANLEY WOLF 506 MOUNT ALLEN DR MECHANICSBURG, PA 1 7055-61 1 1 RE: Account #1753870 TO: JACQUELINE WOLF STANLEY WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055-6111 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended} directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. If these agencies are not near you, you 569-4287 for financially distressed mortgagors fo housing counseling agencies. Attachment: Housing Counseling List can call HUD's toll free number (800) r information concerning HUD-approved FH AACT/dtmdocs/ALSV/ "** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY *** CCCS OF WESTERN PA-HARRISBURG 2000 LINGLESTOWN RD. HARRISBURG, PA. 17110 Phone:888-599-2227 NACA 1341 N DELAWARE AVE; SUITE 312 PHILADELPHIA, PA. 19125 Phone:888-297-5568 HOUSING ALLIANCE OF YORK DEVELOPMENT 34 S. Duke St. York, PA 17401-1106 Phone: 800-864-4909 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608-1676 Phone:717-397-5182 PHILADELPHIA COUNCIL OF COMMINITY ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 PHILADELPHIA, PA. 19103-1828 Phone:800-930-4663 FHAACT/dtmdocs/ALSV/ u.s. Posr~, dice RM,tiwY Fgec ,~~ n ~ Pennsylvania Housin Financ v.: a o P.O. Box 15057 ~ N o STANLEY WOLF 5 0 6 MOIII~i' ALLEN MECHANICSP~~~~ 1753870 ~~ r ,O~^/.~~ r Y/ O~ •. ~ ~ '~ ~ . t ~p 2 4 2012 . __ ---- _ uan.~osr~ ceRrwcnrEt~w ~ . `~. :~..~. ~ ~~ o ~ o ~ Pennsylvania Housing Finance ~ _ Q r- r'~'i P.O. Box 15057 _ ~ a ^_ N~ 0 _ _ O~ prv d o~yry eri rIwN~010. • ^ JACQ~LI~ WOLF 506 MO IINT ~, MECHANI CSB ~~g~ ~ ~ ' . 1753870 5 ~~ ` SEL ~ ~ • SEP 2 4 2012 ,. .~_---- _. -- -- rY~ A ~~~~ ~~~~~ 7196 900b 9111 6973 90b6 X __ 3. 3~rvio~ C. ~ ~1 ~ddisM bN~ ~ 'ryP~ t~lEO W11L'~ ~. nrudsnaa~ssda: JACQUELINE WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG,PA 17055 1753870 FISSEL ,. ,_ ~, YM No trunbu ~' R i.u i 7196 900b 9111 6973 9093 ~ "°"* .'' ~` ~ ~.~.. '~R aw. ~. s«w~..~ c~rr~ wuEn+ ~ ~ 4. RMtr~c~W ~Y? (Exha Fss1. ^Y~r 1. /1Nd~ AcldrosMd b: STANLEY WOLF 506 .MOUNT ALLEN DRIVE MECHANICSBDRG,PA 17055 1753870 FISSEL i ~a rorraR 3s'tt. Jern+arY 2006. DompUo Rspun a.o.tp~ Department of Defense Manpower Data Center ,~ffifll~ ~~t1I'I Pursuant to Servicerne~b~rs Civil Rel~e~f Apt Last Name: WOLF First Name: JACQUELINE Middle Name: Active Duty Status As Of: Nov-08-2012 Results as of :Nov-06.2072 17:09:32 SCRA 2.3 on Acfive Dory On Actlve Dory sroh,a oaro Active Duty Start Dale Adhre Duty End Data Status Servke Comporxmt NA NA Nc NA Thin response rolrocro the irwivtduals' actlve duty sroa7a based on the Actlve Dury Sroh7s Dete LeR Actlve Duty WfINn 367 Days of Actlve Dury Srows Oaro Aetlve Duty Start Dero Acrrva Dury End Date Status Servks Component NA NA No NA This response re6ects whero the indhAdual IeR aciNe duly status wlthln 367 days preceding the Acute Duty Status Date The Member or HlaMer UnN Was Notified of a Futuro Cafi-Up ro Actlve Duty on Acdve Dury Status Date Order Notificatbn Srort Date Order NolHicatbn End Daro Status Servke Component NA NA No NA This response retrocro whether file IfWlNdual or his/her unR has roceivad vary notificat7on to roport for ae6ve duly 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 Department of Defense Manpower Data Center Pursuant to Servicememb~ers Civil Reln~f Act Last Name: WOLF First Name: STANLEY Middle Name: Active Duty Status As Of: Nov-08-2012 Results as of :Nov-OB-2072 11:10:02 SCRA 2.3 Dn Actlve Duty On Active Dury Status Date Active Dury Start Date Active Dury End Date Status Serviw Component NA NA No NA This response retbcb Me NMM1Aduals' actve duy sbtus based on the Aetlve Dury Status Date Leh AciNe Dury WIMin 367 Days of Active Duty Stall Date ActNe Dury Start Date ActNe Duly End Dell Stelus Servks Canponent NA NA NO NA TNS response reheeb Wham the IndlNdual left active dory sbtus vrNhin387 days precedirtp the Active Duty Status Deb The Member or HlsMer Unit Was NotMed of a Futuro CeN•Up b Aches Dury on Actlve Dury Statue Date Order NotNkatbn Start Dab Order NotlNcafion End Date Status Servks Component NA NA No NA This response rehects whether Ihs indWidual or Mefier unit has receNed eery notlNCalbn b report fa active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~ ~. ,rte-~._. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. PENNSYLVANIA HOUSING FINANCE AGENCY, Attorney-in-Fact for U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Dated ~~I~,3/~~ B ~~ Y Thomas F. Brzana, Jr., Director of Loan Servicing for the Pennsylvania Housing Finance Agency, Attorney-in- Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency WOLF 1753870 . SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,.. ; _ ~~~, -, ;_ Ronny RAnderson -~3 ~ ":' ~ Sheriff ~kt, ~i ~.ai~ia~t,l ~~ err? ~ ~ ,~ r n 4~ ,i,7G Jody S Smith ~ ~ ~ ~, ~~ ~; Chief Deputy --<~=~ o ~ ' -~,~, Richard W Stewart ~ ~' ~ .- ~~ ~.~ _ .. _ _, .` `"~ rv - U.S. Bank National Association as Trustee for the Pennsylvania Housing Case Number vs. Jacqueline Wolf (et al.) 2012 -7115 SHERIFF'S RETURN OF SERVICE 11/26/2012 03:43 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Stanley Wolf, Husband of defendant, who accepted as "Adult Person in Charge" for Jacqueline Wolf at 506 Mount Allen Drive. Upper Allen, Mechanicsburg, PA 17055. .~- RYAN BURGETT, DEPO 11/26/2012 03:43 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Stanley Wolf at 506 Mount Allen Drive, Upper Allen, Mechanicsburg, PA 17055. ------~ RYAN BURGET Y 11/26/2012 03:44 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 506 Mount Allen Drive, Upper Allen, Mechanicsburg, PA 17055. No occupants other than defendants reside at this address. SHERIFF COST: $75.00 SO ANSWERS, November 27, 2012 RON yR ANDERSON, SHERIFF 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 o M W M;= VS. NO. 12-07115 =M s� -- JACQUELINE WOLF AND D �CD 4 CD STANLEY WOLF, MORTGAGE FORECLOSURE Xv. CD DEFENDANT(S) D 'i PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) JACQUELINE WOLF AND STANLEY WOLF 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 $154,864.68 Interest $6,258.60 Per diem of$34.20 From 06/01/2012 To 12/01/2012 Accumulated Late Charges $2,515.24 Late Charges $293.40 ($58.68 per month to 12/01/2012) Escrow Deficit $1,774.55 5%Attorney's Commission $7,743.23 TOTAL $173,449.70 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HALLE By Leon aller PA I.D. # 15 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 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 r.� Vs. NO. 12-07115 w IN MORTGAGE FORECLOSURE =mc'o rn JACQUELINE WOLF AND -<. STANLEY WOLF, -<> DEFENDANT(S) r" -.- < c-r, ." CC) 5 CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on February 28, 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 Leon P. Hallelaintiffff I.D. # 15700 Attorney for Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff NO. 12-07115 VS. CIVIL ACTION LAW JACQUELINE WOLF AND STANLEY WOLF IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: February 28,2013 TO: JACQUELINE WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG,PA 17055 STANLEY WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG,PA 17055 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL HALLER By LEON P. HALLE ttorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717)234-4178 U.S.BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW Vs. NO. 12-07115 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE � o STANLEY WOLF, DEFENDANT(S) MW `M �4 rn r7?_ :;a --t -u D z;; o r-"= - AFFIDAVIT ° 3:= ; $.p M 0 C'3 COMMONWEALTH OF PENNSYLVANIA : T"= cz 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-Z3 ON P. HALLER, ESQUIRE N t y Public COMMONWSAM QZ MN=LANIA NOTARIAL SEAL MARYLAND it.FERRETTI,Notary Public Lower Paxton TO.,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. 12-07115 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE STANLEY WOLF, DEFENDANT c. CD rncn - =rrl NON-MILITARY AFFIDAVIT Cn `cr x� COMMONWEALTH OF PENNSYLVANIA �� a�• K fir.. SS -{r-.. COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this�day --)jj Of 20 L . HALLER, ESQUIRE Notary Pu is 7WC6011-1P%1Ma v v I TARlt1 SZ L FEPRE 7? N,:zry Public itvp.,Couphin County n Expires Aug.8,2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION-LAW AT NO. 12-07115 U.S. BANK NATIONAL ASSOCIATION,AS Total Judgment Amount $173,449.70 TRUSTEE FOR THE PENNSYLVANIA HOUSING Interest $9,266.02 FINANCE AGENCY, Per diem of$34.20 to sale PLAINTIFF date 9/4/2013 Late Charges $528.12 VS. $58.68 per month to sale date 9/4/2013 JACQUELINE WOLF AND Escrow Deficit $1,925.64 STANLEY WOLF, DEFENDANT(S) TOTAL WRIT $185,169.48 *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 cases` r Date: April 8, 2013 un- r-z - Attorney for Plaintiff 3�>c�--, ��-��, 1719 North Front Street eon P. Haller Harrisburg, PA 17102 PA I.D. #15700 n (717)234-4178 �- WRIT OF EXECU ION-MORTGAGE FORE LOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above pti ned case,you are directed to levy upon and sell the property described in the attached description known as 5 OUNT ALLEN DRIVE MECHANICSBURG,PA 17055 Date:D!S: � / ,b A C PR HONOTAR CLERK CIVIL DIVISION a � B ` 7-S-6o DEP )b3 .-) S tI " �. soLL- 3.�5 I�Sl ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen,County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point in the center of the public road leading from U. S. Route 15 to Lisburn being 268 feet in a southerly direction by same from Bowmansdale Road and at comer of lands of George Markel; thence by the center line of said road South 8 degrees 15 minutes East 100 feet to a point;thence by the dividing line between Lots Nos. 124 and 125 on the hereinafter mentioned Plan of Lots, South 84 degrees 53 minutes West 168 feet to a pin;thence by other lands now or formerly of Arthur L. Replogle,North 8 degrees 15 minutes West 100 feet to a point at a pin at lands now or formerly of Markle; thence by lands of said George Markle,North 84 degrees 53 minutes East 168 feet to the place of BEGINNING. Being Lot No. 124 in the Plan of Lots of Mt. Allen Heights,Plan"G"as recorded in Plan Book 10,page 10. HAVING THEREON ERECTED a one and one-half story frame and partly brick front dwelling known as 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055 Under and subject to all easements,reservations,restrictions and rights of way of record. BEING THE SAME PREMISES WHICH Eugene E. Kapp and Karen J. Kapp by deed dated 01/23/06 and recorded 02/01/06 in Cumberland County Record Book 272 Page 5006,granted and conveyed unto Stanley Wolf and Jacqueline Wolf,husband and wife. TO BE SOLD AS THE PROPERTY OF JACQUELINE WOLF AND STANLEY WOLF ON JUDGMENT NO. 12-07115 ASSESSMENT NO. 42-28-2423-144 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. 12-07115 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE STANLEY WOLF, 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 546 MOUNT ALLEN DRIVE MECHANICSBURG,PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): C.n JACQUELINE WOLF ' 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 -<> cst C) r— - STANLEY WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055a 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: North Star Capital Acquisition LLC 220 John Glenn Drive—Suite 100 Amherst,NY 14228 North Star Capital Acquisition LLC c/o Apothaker&Associates, PC Attorney David Apothaker 520 Fellowship Road C306 Mount Laurel,NJ 48054 Belco Community Credit Union P. O. Box 82 Harrisburg, PA 17108 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 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 (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 ma dq subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authornitti IAOF-Haller PA I.D. #15700 -'-�'rurcell, Krug& Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:April 8, 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 vs. NO. 12-07115 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE STANLEY WOLF, DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE C-, r--J PURSUANT TO 3 PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 M UJ � rn -< -o rr; TAKE NOTICE: > Cn C < a� CD- That the Sheriffs Sale of Real Property (real estate) will be held: p CD--n DATE: Wednesday, September 04,2013 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-07115 JUDGMENT AMOUNT$173,449.70 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JACQUELINE WOLF AND STANLEY WOLF 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 (34) 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(1 Q) 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 ti ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point in the center of the public road leading from U. S. Route 15 to Lisburn being 268 feet in a southerly direction by same from Bowmansdale Road and at corner of lands of George Markel; thence by the center line of said road South 8 degrees 15 minutes East 100 feet to a point;thence by the dividing line between Lots Nos. 124 and 125 on the hereinafter mentioned Plan of Lots, South 84 degrees 53 minutes West 168 feet to a pin;thence by other lands now or formerly of Arthur L. Replogle,North 8 degrees 15 minutes West 100 feet to a point at a pin at lands now or formerly of Markle; thence by lands of said George Markle,North 84 degrees 53 minutes East 168 feet to the place of BEGINNING. Being Lot No. 124 in the Plan of Lots of Mt. Allen Heights,Plan"G"as recorded in Plan Book 10,page 10. HAVING THEREON ERECTED a one and one-half story frame and partly brick front dwelling known as 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055 Under and subject to all easements,reservations, restrictions and rights of way of record. BEING THE SAME PREMISES WHICH Eugene E. Kapp and Karen J. Kapp by deed dated 01/23/06 and recorded 02/01/06 in Cumberland County Record Book 272 Page 5006, granted and conveyed unto Stanley Wolf and Jacqueline Wolf,husband and wife. TO BE SOLD AS THE PROPERTY OF JACQUELINE WOLF AND STANLEY WOLF ON JUDGMENT NO. 12-07115 ASSESSMENT NO. 42-28-2423-144 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7115 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 JACQUELINE WOLF AND STANLEY WOLF (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: $173,449.70 L.L.J.50 Interest PER DIEM OF$34.20 TO SALE DATE 9/4/13-$9,266.02 Atty's Comm: Due Prothy: $2.25 Atty Paid: $223.75 Other Costs: LATE CHARGES-$58.68 PER MONTH TO SALE DATE 9/4/13-$528.12 ESCROW DEFICIT-$1,925.64 Plaintiff Paid: Date: 5115113 David D.Buell,Prothonota (Seal) Y_ 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 s SHERIFF'S OFFICE OF CUMBERLAND COUNTY a Ronny R Anderson Sheriff �4t�,ttr dt t�:�rti��r�f��if� l,i€'- Tf1�. ���}� Jody S Smith f Chief Deputy $ p 17 PM 3: 25) Richard W Stewart OFFICE THE SHERIFF C,UMBtP1 LA14D I 01i y Solicitor PENN S Y LVA M A U S Bank, N.A. Case Number vs. Jacqueline Wolf(et al.) 2012-7115 SHERIFF'S RETURN OF SERVICE 06/24/2013 05:11 PM -Deputy Jason Kinsler, 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 506 Mount Allen Drive, Upper Allen, Mechanicsburg, PA 17055, Cumberland County. 07/16/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Stanley Wolf, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found" at 506 Mount Allen Drive, Mechanicsburg, PA 17055, property is vacant, mail is still delivered there per post office. 07/16/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jacqueline Wolf, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 506 Mount Allen Drive, Mechanicsburg, PA 1.7055, property is vacant, mail is still delivered there per post office. 07/30/2013 As directed by Leon P. Haller,Attorney for the Plaintiff, Sheriffs Sale Continued to 12/4/2013 09/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $3,173.78 SO ANSWERS, September 17, 2013 RbNW R ANDERSON, SHERIFF SD &L-/O�- z-*9.1-4W> (c)CountySuite Sheriff,Teleosoft,Inc. e COPY U.S. BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 12-07115 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE STANLEY WOLF, 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 506 MOUNT ALLEN DRIVE MECHANICSBURG,PA 17055; 1. Name and address of the Owner(s) or Reputed Owner(s): JACQUELINE WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 STANLEY WOLF 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 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: North Star Capital Acquisition LLC 220 John Glenn Drive—Suite 100 Amherst,NY 14228 North Star Capital Acquisition LLC c/o Apothaker&Associates, PC Attorney David Apothaker 520 Fellowship Road C306 Mount Laurel,NJ 08054 Belco Community Credit Union P. O. Box 82 Harrisburg, PA 17108 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 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 (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 ma subject to the falsification penalties of 18 PA C.S. Section 4904 relating to unsworn falsi Fon to authoritie . La-o*V"Haller PA I.D. #15700 urcell, Krug & Haller 1719 North Front Street Harrisburg,PA 17102 (717) 234-4178 DATE:April 8, 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 VS. NO. 12-071 15 JACQUELINE WOLF AND IN MORTGAGE FORECLOSURE STANLEY WOLF, 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: 506 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 12-07115 JUDGMENT AMOUNT$173,449.70 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JACQUELINE WOLF AND STANLEY WOLF A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD,TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open.the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL,KRUG &HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen,County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point in the center of the public road leading from U. S. Route 15 to Lisburn being 268 feet in a southerly direction by same from Bowmansdale Road and at comer of lands of George Markel; thence by the center line of said road South 8 degrees 15 minutes East 100 feet to a point;thence by the dividing line between Lots Nos. 124 and 125 on the hereinafter mentioned Plan of Lots, South 84 degrees 53 minutes West 168 feet to a pin;thence by other lands now or formerly of Arthur L. Replogle,North 8 degrees 15 minutes West 100 feet to a point at a pin at lands now or formerly of Markle; thence by lands of said George Markle,North 84 degrees 53 minutes East 168 feet to the place of BEGINNING. Being Lot No. 124 in the Plan of Lots of Mt. Allen Heights,Plan"G" as recorded in Plan Book 10,page 10. HAVING THEREON ERECTED a one and one-half story frame and partly brick front dwelling known as 506 MOUNT ALLEN DRIVE, MECHANICSBURG, PA 17055 Under and subject to all easements,reservations,restrictions and rights of way of record. BEING THE SAME PREMISES WHICH Eugene E. Kapp and Karen J.Kapp by deed dated 01/23/06 and recorded 02/01/06 in Cumberland County Record Book 272 Page 5006, granted and conveyed unto Stanley Wolf and Jacqueline Wolf,husband and wife. TO BE SOLD AS THE PROPERTY OF JACQUELINE WOLF AND STANLEY WOLF ON JUDGMENT NO. 12-07115 ASSESSMENT NO. 42-28-2423-144 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7115 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 JACQUELINE WOLF AND STANLEY WOLF (_1)You are directed to lev�upon the pro.pei-ty of the defendant(hand 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 gamishee(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: $173,449.70 L.L.$.50 Interest PER DIEM OF$34.20 TO SALE DATE 9/4/13-$9,266.02 Atty's Comm: Due Prothy: $2.25 Atty Paid: $223.75 Other Costs: LATE CHARGES-$58.68 PER MONTH TO SALE DATE 9/4/13-$528.12 ESCROW DEFICIT-$1,925.64 Plaintiff Paid: Date: 5/15/13 David D. Buell, Prothonota (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 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and these I of said Court at Carlisle,Pa. This day of Q ,20=s- Prothonotary On,May 20, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Uppeb.Allen Township, Cumberland County, PA, ICnow l and numbered as, 506 Mount Allen Drive, Mechanicsburg, as, Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: May 205 2013 By: CtL d Real Estate Coordinator OS .b L 1 ),`I Eidt U�'r> - I LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012-7115 Civil Term U S BANK,N.A. vs. JACQUELINE WOLF, Stanley Wolf Atty.:Leon P.Haller BEGINNING at a point in the cen- ter of the public road leading from U. S.Route 15 to Lisburn being 268 feet in a southerly direction by same from Bowmansdale Road and at corner of lands of George Markel; thence by the center line of said road South 8 degrees 15 minutes East 100 feet to a point; thence by the dividing line between Lots Nos. 124 and 125 on the hereinafter mentioned Plan of Lots, South 84 degrees 53 minutes West 168 feet to a pin; thence by other lands now or formerly of Ar- thur L. Replogle, North 8 degrees 15 minutes West 100 feet to a point at a pin at lands now or formerly of Markle; thence by lands of said George Markle,North 84 degrees 53 minutes East 168 feet to the place of BEGINNING. Being Lot No. 124 in the Plan of Lots of Mt.Allen Heights,Plan"G"as recorded in Plan Book 10,page 10. HAVING THEREON ERECTED a one and one-half story frame and partly brick front dwelling known as 506 MOUNT ALLEN DRIVE, ME- CHANICSBURG,PA 17055. Under and subject to all ease- ments,reservations,restrictions and rights of way of record. BEING THE SAME PREMISES WHICH Eugene E. Kapp and Karen J.Kapp by deed dated 01/23/06 and recorded 02/01/06 in Cumberland County Record Book 272 Page 5006, granted and conveyed unto Stanley Wolf and Jacqueline Wolf, husband and wife. TO BE SOLD AS THE PROPERTY OF JACQUELINE WOLF AND STAN- LEY WOLF ON JUDGMENT NO. 12-07115. ASSESSMENT NO. 42-28-2423- 144. 120 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. 'Lisa Marie Coyn/, Editor SWORN TO AND SUBSCRIBED before me this 9 dU of August,2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public FGARLISLE BOROUGH,CUMBERLAND COUNTY �]2014 commission My commission Expires Apr 28,2014 The Patriot-News Co. 1900 Patriot Drive a �� �'' �� Mppharficsbdrg, 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. 012-7116 Chril Terrn This ad ran on the date(s)shown below: U S BANK,N.A. VS. 07128/13 JACQUEUNE WOLF Stanley won 08104113 Atty- Leon P Haller 08111/13 BEGINNING at a point in the center of the public road leading from U.S.Route 15 to Lisburn being 268 feet in a southerly direction . . . . . . . . . . . . . . . . . . . . . . . . . . by same from Bowmansdale Road and at comer of lands of George market;thence by the center line©f said road South 8 degrees Sworn to nd subscribed b ore e thi 3 day August, 2013 A.D. 15 minutes East too feet to a point;thence 9-2 of Augi. by the dividing line between Lots Nos.124 and 125 on the hereinafter mentioned Plan of Lots,South 94 degrees 53 minutes West 168 feet to a pin;thence by other lands now -ITR or formerly of Arthur L Replogle,North 8 br!FPublic degrees 15 minutes West 100 feet to a Point at a pin at lands now or formerly of Markle; thence by lands of said George Markle,North U 84 degrees 53 minutes East 168 feet to the of BEGINNING. place COMMONWEALTH OF PENNSYLVANIA Being Lot No.124 in the Plan of Lots of ML Notarial Seal Allen Heights,Plan"G"as recorded in Plan Holly Lynn Warfel,Notary Public Book 10,page 10. Washington Up.,Dauphin County HAVING THEREON ERECTED a one and My Commission Expires Dec.12,2016 one-half story frame and partly brick front MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES dwelliap;k 506 MOL!NT.ALLQj --enTown�asm N p{ f HONO [Ai, 7n 13 OCT 16 PM 1: 4g CUMBERLAND COUNTY PENNSYLVANIA Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhallere?pkh.com U. S. BANK NATIONAL ASSOCIATION, AS • IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING • CUMBERLAND COUNTY, PENNA. FINANCE AGENCY, • CIVIL ACTION - LAW Plaintiff • vs. • No. 12-07115 • JACQUELINE WOLF AND • STANLEY WOLF, Defendants IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY: Please mark the judgment entered in the above captioned case satisfied of record. PURCELL, KRUG . . •LLER Leon P.Halle' ID #15700 Attorney for Plaintiff Date: October 15, 2013 q.SOMa C Of �8 51 7a7