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HomeMy WebLinkAbout13-1119'y e MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610)328-2887 Attorneys for Plaintiff °°,~ryFI*^ ~~ P~ i~ CO 31119CFC-BI ~t; ;~~.~ ~Lr:Nt~ CC~I~NTY ~~~P~SYLVAPiIA FEDERAL NATIONAL MORTGAGE ASSOCIATION 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff v. KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY _ ~ v i~ NO. ~ ~ I I CIVIL ACTION -MORTGAGE FORECLOSURE 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 this 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 claimed in the complaint or 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 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notification. Hate falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la cone toma ra medidas y puede cantinuar la demanda en contra suya sin previo aviso 0 notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARR CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCH)O O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 a~„~~Io3 n~aN~ e ~ ~-~~ ~~ a$~ia~ THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION 31119CFC-BI COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff v. KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 Defendant NO. CIVIL ACTION -MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Federal National Mortgage Association, organized and existing under the laws of the United States of America, with offices for the conduct of business at 3900 Wisconsin Avenue, NW, Washington, DC 20016-2892. 2. Defendant, Katherine E. Rynard is the mortgagor and real owner of premises 111 East Portland Street, Mechanicsburg, PA 17055, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Mortgage Electronic Registration, Inc. as nominee for First Horizon Home Loan Corporation on April 12, 2006, which mortgage is recorded on April 17, 2006 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1946 Page 4140, secured on premises 111 East Portland Street, Mechanicsburg, PA 17055 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to Federal National Mortgage Association by written assignment dated November 16, 2012 and recorded on December 7, 2012 in the Office of the Recorder of Deeds of Cumberland County as Instrument Number 201238031. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from June 2012 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 86,620.02 Interest from 5/1/2012 to 1/23/2013 at $11.87 per diem $ 3,168.16 Accrued Escrow deficit to 1/23/2013 $ 1,930.39 Attorney's Fee $ 1,650.00 Total Unpaid Charges $ 238.69 Total $ 93,607.26 9. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $93,607.26, plus per diem interest at $11.87 from January 24, 2013 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. B Martha E. Von Ros s i ,Esquire Heather Riloff, Esquire Attorneys for Plaintiff VERIFICATION R~ebeoca Graves hereby states that he/she is the Foreclosure Specialist of Seterus, Inc., Servicing Agent for Federal National Mortgage Association, plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Federal National Mortgage Association and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Association v. Katherine E. Rynard relating to the property located at 111 East Portland Street, Mechanicsburg, PA 17055 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 1 ,~, BY: Rabeoca Graves Title: Foreclosure Specialist Seterus, Inc. as servicer for Federal National Mortgage Association Dated: 01-/ ><-/3 EXHIBIT I DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Mechanicsburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pin on the building line of said East Portland Street, corner of Lot now or formerly of J. S. Rupp: thence westward along said building line, 18 feet 11 inches to a nail in the center line of double house; thence northward through the center line of said house and beyond, along the remaining portion of a larger tract of which this Lot now being conveyed was formerly a part, said portion being now or formerly the property of William C. Baum, et al, 146 feet, more or less, to a point on the line of 12 foot alley; thence eastward along the line of said alley, 18 feet 11 inches to a point, corner of the aforesaid Lot now or formerly of J. S. Rupp; thence southward along the same 146 feet, more or less, to an iron pin in the building line of East Portland Street, aforesaid, at the point and place of BEGINNING. HAVING THEREON ERECTED the eastern 1/2 of a double frame dwelling known and numbered as 111 East Portland Street, Mechanicsburg, Pennsylvania. BEING the same premises which J. A. Heinlein and Holley J. Heinlein, his wife, by deed dated September 22, 1993 and recorded in the Cumberland County Recorder of Deeds Office in Book 0-36, Page 586, granted and conveyed unto Chazles E. Smith, Jr. Lisa M. Smith enters into the within deed to grant and convey her interest in the premises by being the wife of Chazles E. Smith, Jr. PARCEL IDENTIFICATION NO: 18-22-0519.031., CONTROL #: 18000183 EXHIBIT II Seterus, Inc. 14523 SW Milliken Way, Suite 200 Beaverton, OR 97005 DATE: 11/27/12 31119-BP TO: Katherine E. Rynard 111 East Portland Street Mechanicsburg, PA 17055 and Katherine E. Rynard 103 Cambridge Street Mechanicsburg, Pa 17055 FOR PROPERTY ADDRESS: 111 East Portland Street Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can hela, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Atency. The name, address and phone number of Consumer Credit Counselin~Agencies servin~your County are listed at the end of this Notice. If you have any c,~uestions, ou may call the Pennsylvania Housing Finance A ency toll free at 1-800-342-2397. (Persons with impaired hearin can call ,717) 780-1869 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S) Katherine E. Rvnard PROPERTY ADDRESS: 111 East Portland Street, Mechanicsbure. PA 17055 LOAN ACCOUNT NO: #: 7825696 ORIGINAL LENDER/SERVICER: Federal National Mortgaee Association CURRENT LENDER/SERVICER: Seterus. Inc. SERVICER FOR: Federal National Mortgaee Association HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. •IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, •IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND •IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO URE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days plus three (3) additional days for mailing after the date of this meeting. The names. addresses and telephone numbers of desi ated consumer credit counseline agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty three (33) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATIONAS SOONAS POSSIBLE. IF YOUHA VE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMAR%DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 33 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROMSTARTINGA FORECLOSUREAGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE': YOUHAVE THE RIGHT TO FILER HEMAPAPPLICATIONEVENBEYOND THESE TI1iEfE PERIOD, A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS ET'ENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION lIN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it uD to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at 111 East Portland Street, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments 6/1/2012 to 11/30/2012 @ $424.57 per month $2,547.42 Late Charges $ 63.69 Corporate Advance $ 135.00 NSF Fees $ 25.00 Escrow Advance $1,930.39 TOTAL AMOUNT PAST DUE $4,701.50 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,701.50 PL US ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME D UE D URING THE THIRTY THREE (33) DAYPERIOD. Payments must be made either by cash cashier's check certified check or money order made nayable and sent to: Seterus Inc 14523 SW Millikan Way Suite 200 Beaverton OR 97005 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose anon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY THREE (33) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheriff's Sale. You may do sob n~ axing the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and b~nerforming anv other requirements under the mortsaee. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 8 months from the date set forth in this Notice. A notice of the actual date of the Sheriff s 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: 5eterus, Inc. Address: 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005 Phone Number: 866-570-5277 Contact Person: LOAN RESOLUTION DEPARTMENT EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney" fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: •TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTEHR LENDING INSTITUTION TO PAY OFF THIS DEBT. •TO HAVE THIS MORTGAGE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF •TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). •TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. •TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. •TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717-232-9757 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888-511-2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg, PA 17110 717-780-3940 800-342-2397 FEDERAL NATIONAL MORTGAGE ASSOCIATION 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 VS. KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 FORM 1 Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ ~o~3-IUA -, /~Jj c / I~f~r ~f 1 il//i r .,i v~ ~~ .. ~~ •:. . , c--:r =:W:> .:,<~~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE `"` DIVERSION PROGRAM You have been served with. a fareclasyre complaint that could cause you to lose your home, n.,7 ~~ c.~_~ -.~ rTl t E`V Ct7 -c~ _. c~ If qou own and live. in the residential property which is the subject of this foreclosure actin, 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 yota, must take the following steps to be eligible for a COncillatl4n Conference. First, wthin twenty (20j days of your receipt of this notice, you must contact MidPenn Legal Services at {7i7j243-9400 extension 2510 or{g00j 822-5?88 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a Iegal represents#ive, you must promptFy .meet with the legal representative within twenty (20j days of the appointment date. Durir-g 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 comp{etc 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 (C,oj days of the service upon you of the foreclosure complaint. IFyau do so and a canaliation 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 b8 eligible far a concill~tion conference. It is not necessary for you to contact MidPenn legal Service far the appointment of a legal representative. Mawever, you mpst provide your lawyer with all requested financial information so that a loan resolution proposal can tee prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer w'rU prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty {60j 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 representat"rve of your lender in an attempt to work out reasonable arrangements wish your lender before the mortgage foreclosure suit proceeds forvrard. 1F YOU WISH TO SAYE YOtlR HOME, YOU MUST ACT Qt!/CKLY AND TAKE THE STEPS REQUIRED 8Y TH/S N4T/CE. T/#IS PROQRAM IS FRED Respectfully submitted: January 11, 2013 Date lgnature of Counsel or lal tiff <.Y,l .--a ~~ i."" F'~ r~^^i ^~' r_3 C::j ~~ cwt -; y ~r~~ :, _. FORM 2 Cumberland County Residential Mortgage Foreclosure iElfv~ersion Pragnm Financial Worksheet Date Cumberland County Court of Common. Please Docket #k BURROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your eircurnstancesto determine possible options while working with your Please. provide the fal[owing Information to the best of your knowledge: Harrower name (s): Property Address: City: State: Zip: ~sthe property for.sale? Yes ^ No ^ Listing date: Price: $ Realtor Name: Realtor Phones Borrower Ocxupled: Yes ~ No Mailing Address (if different} City: State:. .Zip; Phone Numbers: Home: Office: Cell; Other.. Email: # of people in household:.. Malting Address: City: Phone Numbers: :Home: Cell: Email: How State: Zip: Office: Other: #- of people in household: Horn 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 ofi court., case number & attorney: Assets Amount Owed: Value:. Nome: $ $ 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, motorcycles}: Model: Year: Amount owed: Value: Monthht Income Name of Employers: 1. 2. 3. Additional Income Description {not wages}: 1. 2. Harrower Pay Days: Monthly Gross Monthly Net Monthly Gross Monthly Net :Monthly Gross Monthly Net :Monthly Amount: _ Monthly Amount: _ Co-Borrower Pay Days: Mo~thht Expenses: (Please orriv include expenses vau are currently pavinet EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment{s} CondaJNeigh. Fees Auto insurance Med. {not covered} Auto fuel/repairs Other Prod. Payment install. Loan Payment Cable TV Child SupportJAlim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for NFonthiy 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}: Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program {REHAB) assistance? Yes ^ No ^ If yes, please indicate the status of`tftie 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/1A/e, ,authorize the above named to use/refer this information to my lender/services for the sole purpose of evaluating. my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following inf©rmation to lender and lender counsel: J Proof on income J Past 2 bank statements y Proof of any expected income for the last 45 days d Copy of a current utility biH J Letter explaining reason fordelinquency and any supporting documentation d (hardship letter) Listing agreement (if property is currently on the market] y Copy of 2 years of federal income tax returns d Capy of deed FEDERAL NATIONAL MORTGAGE ASSOCIATION 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 vs. KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant iREQUEST FOR CONC~LlAT/OiN CONFEREiNCE Pursuant to the Administrative Order dated 2012 .governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies. as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a °Notice of Residential Mortgage Foreclosure Diversion Program: and has taken alt 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. t understand that statements are made sub}ect to the.. penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's CounseiJAppointed t.egal Representative Signature of Defendant Signature of Defendant Plaintiff FORM 3 Date Date Date FEDERAL NATIONAL MORTGAGE ASSOCIATION 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 vs. KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 AND NCtW,this dayof 20 ,the defendantjborrower in the above-captioned residential mortgage foredosure action having. filed a Request for Conciliation Conference verifying that the defendantjborrower has complied vwith the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: i. The parties and their counsel .are directed to participate: in acourt-supervised conciliation Conference on at .M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At .least twenty-one (21j days prior to the date of the Conciliation Conference, the defendantjborrower must serve upon the Ptaintif#/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2j which. has been. completed by the defendantjborrower.. Upon agreement of the parties in writing or at 'the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date andjor the date upon which service of the completed Form Z is to be made may be extended. Upon notice to the Plaintiff FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Defendant CASE MANAGEMENT ORDER Court of the defendant/barrower's failure to serve the completed Forrn 2 with the time frame set forth. herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall. be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the. plaintiffjlender must. either attend the Conciliation Conference in .person ar be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a .mutually acceptable resolution, and counsel far the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference,. If the duly authorized representative of the plaintiff/lender is not available. by telephone during, the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiffJlender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties. and their counsel shall be prepared to discuss and explore all available resolution options which shall include: .bringing the mortgage current through a reinstatement; paying off the mortgage;. proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the tender a deed in lieu of foreclosure; entering into a loan. modification or a reverse mortgage; paying the mortgage default: over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY TH E GOU FtT, !. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson j. FILED-OFFICE THE PRDTNONO TA FR,, Sheriff °"�ti, aturbbrrr Jody S Smith 2013 MAR 26 AM 9: 34 Chief Deputy � �`� Richard W Stewart CUMBERLAND COI3N:TY Solicitor OFFiCEOFFNES RIFF PENNSYLVANIA Federal National Mortgage Association Case Number vs. 2013-1119 Katherine Elizabeth Rynard SHERIFF'S RETURN OF SERVICE 03/20/2013 09:00 AM-William Cline, Deputy Sheriff served the requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure by"personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Katherine Elizabeth Rynard at the Cumberland County Sheriffs Office, One Courthouse Square, Carlis7Z;0O[Z,_ LLIAM CLINE, DEPUTY 03/21/2013 07:52 PM-Deputy Tim Black, being duly swom according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Thomas White, friend of tenant,who accepted as"Adult Person in Charge"for the tenant at 111 E Portland Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. '''�� fz , TIM LACK, DEPUTY SHERIFF COST: $48.00 SO ANSWERS, March 25, 2013 RON R ANDERSON,SHERIFF ic)CountySuite Sheriff,Teleosoft.Irc. #31119CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff V. NO. 13-1119 Civil m F KATHERINE E. RYNARD �v cn CD r Defendant(s) ' PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Katherine E. Rynard for want of an answer. (X) Assess Damages as Follows Debt $ 93,607.26 Interest from 01/24/2013 to 4/24/13 At $11.87 per diem $ 1,080.17 Total $ 94,687.43 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least(10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. B Martha E. Von o nsti Esquire Heather Riloff, squire qqI/ Attorneys for Plaintiff This c/o day of alpe 1 , 2013 judgment is entered in favor of the Plaintiff and against Defendant(s), Katherine E. Rynard by default fo ant o n anand damag ssessed at the sum of$94,687.43 as per the above certification. Prothonota6, Cumberland County auv&W.SD 1"d a` Cut S 6C(Iq V-4.a8J 7-1q MARTHA E. VON ROSENSTIEL,P.C. #31119CTD-MS Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff,Esquire/No. 309906 649 South Avenue, Suite 7 Secane,PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue,NW Washington, DC 20016-2892 Plaintiff V. Case No: 13-1119 Civil KATHERINE E.RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 Defendant TO: Katherine Rynard I I I East Portland Street Mechanicsburg, PA 17055 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 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 NOTICE TO A 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL,,.'P.C. BY: M ha E. Von Rosenstiel,Esquire Heather Riloff,Esquire Attorneys for Plaintiff Dated: April 10,2013 MARTHA E. VON ROSENSTIEL,P.C. #31119CTD-MS Martha E. Von Rosenstiel, Esquire/No, 52634 Heather Riloff,Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610)328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue,NW Washington, DC 20016-2892 Plaintiff V. Case No:,13-1119 Civil KATHERINE E. RYNARD 103 Cambridge Street Mechanicsburg, Pa 17055 Defendant TO: Katherine Rynard 103 Cambridge Street Mechanicsburg,PA 17055 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 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 NOTICE TO A 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 717-249-3166 800-990-9108 MARTHA E.VON ROSENSTIEL,PC. BY: /Z Martha E. Von Rosenstiel,Esquire Heather Riloff, Esquire Dated: April 10, 203 Attorneys for Plaintiff #31119CFJ-DN MARTHA E. VON ROSENSTIEL, P.C. Martha,E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff vs. No: 13-1119 Civil KATHERINE E. RYNARD Defendant(S) NON MILITARY AFFIDAVIT Heather RHO Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E.Von Rosenstiel,P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief,named mortgagor(s) and real owner(s)is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL,P.C. BY:C4 Martha E. Von Ros tiel, Es uire Heather Riloff,Esq ' Attorneys for Plaintiff Dated: April 24, 2013 i OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Katherine E. Rynard 103 Cambridge Street Mechanicsburg, Pa17055 FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY PLAINTIFF VS. KATHERINE E. RYNARD NO: 13-1.119 CIVIL DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $94,687.43 on April 24, 2013. David D. Buell Prothonotary ❑ n Judgme t by Default Money Judgment y���r►3 Judgment in Replevin Judgment for Possession ❑ Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Heather Rifoff , Esquire at this telephone number:610-328- 2887. r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, I Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Katherine E. Rynard 111 East Portland Street Mechanicsburg, PA 17055 FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY PLAINTIFF VS. KATHERINE E. RYNARD NO: 13-1119 CIVIL DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $94,687.43 on April 24, 2013. David D. Buell Prothonotary F Judgment by Default Iq Ia11 J!3 0 Money Judgment Judgment in Replevin Judgment for Possession F1Judgment on Award of Arbitration Judgment on Court Findings If ou have.an ME cp g this notice, please call: Attorney y y n � ef ���� , Esquire at this telephone number:610-328-2887. 1 t {f 31119CWE-DN Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION COURT OF COMMON PLEAS V. DOCKET NO. 13-1119 Civil KATHERINE E. RYNARD ATTORNEY I.D. # O 9 U Co C-) ^ C= Praecipe for Writ of ExecutioWrn � r- r TO THE PROTHONOTARY: ice-. °N y O -p C:)-r. Issue Writ of Execution in the above matter: =C) N C>rri cry AMOUNT DUE $ 94,687.43< INTEREST from 4/25/2013 to 9/4/2013 At 6 % $ 2,070.81 TOTAL* $ 96,758.24 *Plus costs to be endorsed Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: artha E. Von Roaetiel, Es uire Heather Riloff, Es Attorneys for Plaintiff PREM: 111 East Portland Street, Mechanicsburg, PA 17055 Q,w a o C"31 1 o. so . s6Z4- C" s41S COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 13-1119 Civil FEDERAL NATIONAL MORTGAGE ASSOCIATION V. KATHERINE E. RYNARD Praecipe for Writ of Execution (Mortgage Foreclosure) AMOUNT DUE $ 94,687.43 INTEREST from 4/25/2013 to 9/4/2013 At 6 % $ 2,070.81 TOTAL* $ 96,758.24 *Plus costs to be endorsed Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 Attorneys for Plaintiff 649 South Avenue, Unit#6 Secane, PA 19018 (610) 328-2887 #31119-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff VS. NO: 13-1119 CIVIL KATHERINE E. RYNARD Defendant(s) LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel-of land and premises, situate, lying and being in the Borough of Mechanicsburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pin on the building line of said East Portland Street, comer of Lot now or formerly of J. S. Rupp: thence westward along said building line, 18 feet 11 inches to a nail in the center line of double house; thence northward through the center line of said house and beyond, along the remaining portion of a larger tract of which this Lot now being conveyed was formerly a part, said portion being now or formerly the property of William C. Baum, et al, 146 feet, more or less, to a point on the line of 12 foot alley; thence eastward along the line of said alley, 18 feet I I inches to a point, comer of the aforesaid Lot now or formerly of J. S. Rupp; thence southward along the same 146 feet,more or less, to an iron pin in the building line of East Portland Street, aforesaid, at the point and place of BEGINNING. HAVING THEREON ERECTED the eastern 1/2 of a double frame dwelling known and numbered as 111 East Portland Street, Mechanicsburg, Pennsylvania. IMPROVEMENTS: Residential dwelling Tax Parcel # 18-22-0519.031 TITLE TO SAID PREMISES IS VESTED IN Katherine E. Raynard,adult individual,by Deed from Charles E. Smith,Jr. and Lisa M. Smith,his wife, dated 04/12/2006,recorded 04/17/2006 in Book 274, Page 65. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/No. 52634 OF T11E PROT116,NOI-AR,� Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 2013 APR 26 PM 2: S3 Secane, PA 19018 (610) 328-2887 CUMBERLA PENNS NDCOUNTY Attorneys for Plaintiff YLVANIA Federal National Mortgage Association COURT OF COMMON PLEAS 3900 Wisconsin Avenue,NW CUMBERLANDCOUNTY Washington DC 20016-2892 Plaintiff VS. Katherine E. Rynard No: 13-1119 Civil 103 Cambridge Street Mechanicsburg, Pa 17055 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: Ss COUNTY OF DELAWARE Heather RHO attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Katherine Rynard 103 Cambridge Street Mechanicsburg,Pa 17055 1 verify that the statements made in this affidavit are true and correct 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rase r tie LEsquire t e Heather Riloff, E squi Attorneys for Plaintiff #31119CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 ,; +- (610) 328-2887r Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS -0 C:)-T1 ASSOCIATION CUMBERLAND COUNTY _ on Plaintiff p un r� `j W VS. NO: 13-1119 CIVIL KATHERINE E. RYNARD Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 Heather Riloff , ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 111 East Portland Street, Mechanicsburg, PA 17055: 1. Name and address of owners(s) or reputed owner(s) Katherine Rynard .103 Cambridge Street Mechanicsburg, Pa 17055 2. Name and address of defendant(s) in the judgment: Katherine Rynard 103 Cambridge Street Mechanicsburg, Pa 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mechanicsburg Borough West Strawberry @ North Market Street Mechanicsburg , PA 17055 Mechanicsburg Borough 36 West Allen Street Mechanicsburg , PA 17055 Discover Bank 6500 New Albany Road New Albany, OH 43054 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Occupant 111 East Portland Street Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY:C�I�' 40 / Martha E. Von Ro e stiel, quire Heather Riloff, Es Attorneys for Plaintiff Dated: April 23, 2013 31119CAM-DN MARTHA E. VON ROSENSTIEL, P.C. Or" THELPROTHIONOTAi,', .Martha E. Von Rosenstiel, Esquire/No. 52634 2013 APR 26 PH 2: 53 Heather Riloff, Esquire /No. 309906 CUMBERLAND COUNTY 649 South Avenue, Suite 7 . PENNSYLVA141 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff : vs. : No: 13-1119 Civil KATHERINE E. RYNARD Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 111 East Portland Street Mechanicsburg, PA 17055 will be sold by the Sheriff of Cumberland County on r Date of Sale: September 04, 2013 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 13-1119 Civil in the Court of Common Pleas of Cumberland County by Federal National Mortgage Association, Plaintiff against Katherine E. Rynard, Defendant(s). Judgment was entered on April 24, 2013 in the amount of$94,687.43. The property was seized and taken in execution as the property of Katherine E. Rynard. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Mechanicsburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at an iron pin on the building line of said East Portland Street, corner of Lot now or formerly of J. S. Rupp: thence westward along said building line, 18 feet 11 inches to a nail in the center line of double house; thence northward through the center line of said house and beyond, along the remaining portion of a larger tract of which this Lot now being conveyed was formerly a part, said portion being now or formerly the property of William C. Baum, et al, 146 feet, more or less, to a point on the line of 12 foot alley; thence eastward along the line of said alley, 18 feet 11 inches to a point, comer of the aforesaid Lot now or formerly of J. S. Rupp; thence southward along the same 146 feet, more or less, to an iron pin in the building line of East Portland Street, aforesaid, at the point and place of BEGINNING. HAVING THEREON ERECTED the eastern 1/2 of a double frame dwelling known and numbered as 1 1 1 East Portland Street, Mechanicsburg, Pennsylvania. Tax ID #18-22-0519.031 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 13-1119 Civil. You should check with the Sheriff's Office by calling (717) 240- 6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL,, P.C. Martha E. Von Ro.senstiel, Esquire /No. 52634 Heather Riloff, Esquire /No. 309906 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 #31119-CWE-DN MARTHA E. VON ROSENSTIEL, P.C. FILE D-OfFF!GE Martha E. Von Rosenstiel, Esquire/No. 52634 OF THE PRO THONOTARy Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 2013 APR 26 -PM 2: 53 Secane, PA 19018 (610) 328-2887 CUMBERLAND COUNTY Attorneys for Plaintiff PENNSYLVANIA FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff vs. KATHERINE E. RYNARD No: 13-1119 Civil Defendant(s) CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA—Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including,but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosen ti IjEsq ire Heather Riloff, Esqui Attorneys for 'la WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1119 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff(s) From KATHERINE E.RYNARD (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 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: $94,687.43 L.L.: .50 Interest FROM 4/25/13 TO 9/4/2013 AT 6%-$2,070.81 Atty's Comm: Due Prothy:$2.25 Atty Paid: $196.75 Other Costs: Plaintiff Paid: Date: 4/26/13 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: MARTHA E.VON ROSENSTIEL,ESQUIRE Address: MARTHA E.VON ROSENSTIEL,P.C. 649 SOUTH AVENUE,UNIT#6 SECANE,PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No.52634 1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, I Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Katherine E. Rynard I I 1 East Portland Street Mechanicsburg, PA 17055 T .r A TTFtAI^r AnnRrr<;AF COURT OF COMMON PLF.AC onotary canoes pos;g rthouse Square Z erlQnd County Courthouse �=PITNEY BOWE le,PA 17013-3387 02 1P $ 000,66 0001738253 APR 23 201 MAILED FROM ZIP CODE II 901 I I t11 j Katherine E. Rynard 1 111 East Portland Street Mechanicsb t i 7«5 =� e F #31119CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 c 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Mrl CD Attorneys for Plaintiff °" -', FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS >c:' ASSOCIATION CUMBERLAND COUNTY Co �t=a Ca Plaintiff VS. NO: 13-1119 CIVIL KATHERINE E. RYNARD Defendant(s) -AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Heather RHO ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on �� r , true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit 1. I verify that the statements made in this affidavit are true and correct 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Ros st'el, Es uire Heather Riloff, Esq Attorneys for Plaintiff I and — , --'' ----r Registe M- Address Attomey At Law for Merchandise red Mail: additional copies of th 649 South Avenue,Unit 7 ❑0 Insured 13 With Postal Insurance of Secane, PA. 19018 ❑Without Postal Insurance Sender ❑COD ❑Int'l Recorded Del. ❑Certified❑Express Mail P$XNfi3F SeW,9 2 IP $RIM —An - Act. 0 0173 253 MAY 03 2013 Line Article Name of Addresses,Street,and Handling Value Due MAIR Insured K.K . FROM ZIP CODE 19018 Number Postage Fee Sender Fee Fee Fee Post Office Address Charge (if Value If COD Remarks Regis.) Cumberland County Tax Claim 1 #31119 1 Courthouse Square 1 of 2 Carlisle,PA. 17013 Cumberland Register,of Wills a 2 County Courthouse Carlisle,PA. 17013 .2 Attorney General of the U.S. C/O Assistant Attorney General 3 Tax Division U.S.Department of Justice P.O. Box 227 Washington,DC.20044 PA Department of Revenue 4 Inheritance Tax Division, IL P.O.Box 280601 Hanisburg,PA 17128 Family Court/Domestic Relations 5 1 Courthouse Square Carlisle,PA. 17013 PA.Department of Revenue Bureau of Compliance 6 Attn:Sheriff Sale Section P.O.Box 218230 Harrisburg,PA. 17128-1230 Department of Public Welfare 7 P.O. Box 2675 Harrisburg,PA.17105 OccupantstTenants G 111 East Portland Street 'YOST Op,r Mechanicsburg,PA 17055 A PA. Department of Revenue cc Bureau of Individual Taxes Ln 9 P.O.Box 280603 0 Harrisbu PA. 17128 10 Discover Bank SECA, 6500 New Albany Road New Albany,OH 43054 Mechanicsburg Borough 36 West Allen Street Mechanicsbu!rg,PA 17055 _r Total Number of Pieces Total Postmaster,,Per( a i The full declaration of value is required on all domestic and international registered mail. The Listed by Sender Number maximum indemnity payable for the reconstruction of nonnegotiable documents under Express I s 1 T 1L11�1G �rx fee hem in damps CERTIFICATE OF N o►�cJer poslagc and U.S POSTAL SERVICE 11C^�THIERHATI Z ' MAY BE USED FOR DOMES pppVIDE FOR 4S11RANCE--POSTMASTER N Bowes f 7 fee Rcdcived From ,, 02 1 P $ 001.201 000173 253 MAY 03 2013 MARTHA VON ROSEN MAILED OM ZIP CODE 1901 8 649 SOUTH AVENUE UNIT 1 SECANE,PA 19018 OFFrcF One piece of ordinwy mail addressed 10: ey o . West Strawberry @ North Market e���'N 4 urg, w;bd S�cP PS Form 38 17.Mw-19'9 i x s� x .s-D AFFIDAVIT OF SERVICE � PLAINTIFF: Federal National Mortgage Association F'T'I m COURT OF COMMON PLEAS :z UEFEN'DANT Cumberland COUNTY tV L"T COURT NO. 13.1119 Civil <> C: ' Katherine E.Rynard =h SERVE UPON: 5:c= C�? Katherine E.Rynard TYPEOFACTION 103 Mechanicsburg,Street XX WRIT OF EXECUTION and Notice of Sheriff s Sale Gl3 Mechanicsburg,PA 17055 �. SPECIAL INSTRUCTIONS:please serve defendant personally or adult in charge of premises Sheriffs Sale Date:9! 2013 SERVED Sen_red and made known Co KATN6 41ke, G-X*444 Defendant, on the -4- day of $Ahj 2043 at QFClock, p M., at 10 C,5,Me tbiXF !_- Commonwealth of Penneylv"ia, in the manner described below: ant personally served. Manager/Clerk of place of lodging in which Adult fami2v member with whom Defendant resides. Defendant resides. j i Relationship i C Agent or person in charge of Defendant's office i Adult in charce of Defendant's residence who refused i or usual place of business: Other to give namelrelabonshi . ' / Descriippti ion.,:`Age Height Z Weight 1 � Race tAMf TZ- Sex _Other a competent adult,being duly sworn according to law,depose and state that I personally handed to C1C a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this da• Q"'� KIMBERLY G CURRY of MINv ,200. 1�1�Iti 1 tP 0 # 2295304 Notary: r —J Sy: .F'" J NOTARY PUBLIC NOT SE STATE OF NEW JERSEY On the 20_ ai o'clock 1,1.;Defendant xpires March'?, 201 a Moved Unknown No Answer Vacant i Time of Attempt: i Result: ; Date of Attempt: } I Sworn to and subscribed before me this day of Notary: 3y: ATTORNEY Martha E.Von Rosenstiel,P.C. 649 South Avenue,Unit 6 Secane,PA 19018 510-328-2887 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f it Sheriffs ! + Jody S Smith �n Chief Deputys ,� Va`� Richard W Stewart �)t ��, Solicitor OFFICE OF THE SHERIFF PE iS Y � A � Federal National Mortgage Association Case Number vs. Katherine Elizabeth Rynard 2013-1119 SHERIFF'S RETURN OF SERVICE 06/24/2013 04:08 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 111 E Portland Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 09/04/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$20,000.00 to Attorney Nate Wolf on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ 10/03/2013 Proposed Schedule Of Distribution Posted on 10/3/13, all parties notified by mail. cab SHERIFF COST: $1,684.72 SO ANSWERS, October 04, 2013 RON W R ANDERSON, SHERIFF C1e, {cj CeuntySutte Sheriff,Teleosoft_Icy. On May 21, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 111 East Portland Street, Mechanicsburg, as, Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: May 21, 2013 e By: Real Estate Coordinator a LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2013-1119 Civil Term FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. KATHERINE ELIZABETH RYNARD Atty.: Martha E.Von Rosenstiel ALL THAT CERTAIN tract or parcel of land and premises, situ- ate, lying and being in the Borough of Mechanicsburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at aniron pin on the building line of said East Portland Street,corner of Lot now or formerly of J.S.Rupp:thence westward along said building line, 18 feet II inches to a nail in the center line of double house; thence northward through the center line of said house and beyond,along the remaining portion of a larger tract of which this Lot now being conveyed was formerly apart, said portion being now or formerly the property of William C. Baum, et al, 146 feet,more or less, to a point on the line of 12 foot alley; thence eastward along the line of said alley, 18 feet 11 inches to a point,corner of the aforesaid Lot now or formerly of J. S. Rupp;thence southward along the same 146 feet, more or less, to an iron pin in the building line of East Portland Street, aforesaid, at the point and place of BEGINNING. HAVING THEREON ERECTED the eastern 1/2 of a double frame dwelling known and numbered as III East Portland Street,Mechanicsburg, Pennsylvania. IMPROVEMENTS: Residential dwelling. Tax Parcel# 18-22-0519.031. TITLE TO SAID PREMISES IS VESTED IN Katherine E. Raynard, adult individual, by Deed from Charles E. Smith, Jr. and Lisa M. Smith,his wife, dated 04/12/2006, recorded 04/17/2006 in Book 274, Page 65. 94 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. isa Marie Coynel Editor SWORN TO AND SUBSCRIBED before me this da of Auizust 2013 Notary t A COL L1i 1;i RLi t.E 3 C,U:,'uAER!V1 CCi s�. Expi li?S Apr 28.20"A 1 1 � n , t,y The Patriot-News Co. 1900 Patriot Drive Zhe atr1*0t'WX(W5 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. PUBLICATION COPY This ad ran on the date(s)shown below: 3-1 i i9 Clvll Term 07/28/13 FEDERA NATIONAL MORTGAGE AssoclAnON 08/04/13 . KATNE NE ELImssZABETH RYNARD 08/11/13 Atty. Martha E.Von Rosenstlel 003, tl ` LLSg; IV/1 ALL THAT CERTAIN tract or parcel of WW • • • • • . • • . . . . . . . . . . . . . . . . . . . . . . . . . badd and premises,situate,lying and being in the Borough of Mechanicsburg in the o Sworn to and s b cribed re me th 23� y of August, 2013 A.D. County of Cumberland and Commonwealth ds of Pennsylvania,more particularly described ft as follows: V'Id BEGINNING at an iron pin on the building)GL) line of said East Portland Street,corner of q4 U C Lot now or formerly of J.S.Rupp:thence ON westward along said building line,18 feet II ag inches to a nail in the center line of double I V house;thence northward through the center'6) line of said houff7ffl9mod, along the y C M. s%!'Pjr LlH f?F PEF'01'iYLVANIA remaining portion of a larger tract of which I — Notarai Sea! this Lot now being conveyed was formerly f 110y LYrtrt W{-`,el,Notary Public apart,said portion being now or formerly the a t or o w, a '�eitpFtn{oi�3ty My ,';1 1 jl�r)r �r S tJ?.. A� x(716 Mir 1 rc,t=E d_i ✓Fti fI A5S 7C IATTOP�OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 26th day of April, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1119, at the suit of Federal National Mortgage Association against Katherine E. Rynard is duly recorded as Instrument Number 201336804. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /I/)— I day of A.D. A3 Recorder of Deeds er of ,Cumberland County,Carlisle,PA My Cotnrni Expires the First Monday of Jan.2014