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HomeMy WebLinkAbout13-1937 Supreme Co " nnsylvania COu . leas For Prothonotary Use Only: • # t Docket No: C LAN County 13-1 C 37 The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required bylaw or rules of court. Commencement of Action: S 13 Complaint [3 Writ of Summons Petition 0 Transfer from Another Jurisdiction Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: C T MIDFIRST BANK MICHAEL E. WATSON I Are money damages requested? 0 Yes 0 No Dollar Amount Requested: Owithin arbitration limits (check one) i3outside arbitration limits N Is this a Class Action Suit? 0 Yes 13 No Is this an MDJAppeal? [3 Yes ® No A Name of Plaintiff/Appellant's Attorney: Leon P. Haller / Jill M Wineka El Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution Debt Collection: Credit Card El Board of Assessment Motor Vehicle Debt Collection: Other 0 Board of Elections Nuisance Dept. of Transportation S Premises Liability Statutory Appeal: Other Product Liability (does not include E mass tort) [3 Employment Dispute: 13 Slander/LibeU Defamation Discrimination C El Other: [3 Employment Dispute: Other E3 Zoning Board T E3 Other: I Q Other: MASS TORT Asbestos N" 0 Tobacco l3 Toxic Tort - DES lj Toxic Tort - Implant REAL, PROPERTY El Toxic Waste MISCELLANEOUS © Other: 0 Ejectment ® Common Law /Statutory Arbitration B Eminent Domain/Condemnation 0 Declaratory Judgment E3 Ground Rent ® Mandamus ll Landlord/Tenant Dispute Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial ® Quo Warranto 0 Dental ® Partition 0 13 Replevin Legal Quiet Title 13 Other: Medical E3 Other: Q Other Professional: Updated 1/1/2011 }w HE F'F {C`I , " Jrr.J Leon P. Haller, Esquire t Purcell, Krug &Haller 2 f3 APR I2 At�# IC C3 1719 North Front Street CUMBERLAND Lit Harrisburg, PA 17102 PENN3YLYYAY1 717.234.4178 mtg @pkh.com MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW MICHAEL E. WATSON ACTION OF MORTGAGE FORECLOSURE Defendant , >3- /93 - 7 THIS 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. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717- 249 -3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238 -6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717- 249 -3166 4Y7 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW MICHAEL E. WATSON, ACTION OF MORTGAGE FORECLOSURE Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW MICHAEL E. WATSON, ACTION OF MORTGAGE FORECLOSURE Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff is MIDFIRST BANK, a corporation, whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. The Defendant, MICHAEL E. WATSON, is an adult individual whose last known address is 31 LIBERTY COURT, CARLISLE, PA 17015. 3. On or about, September 23, 2008, the Defendant executed and delivered a Mortgage Note in the sum of $163,922.00 payable to CITIMORTGAGE, INC., which Note is attached hereto and marked Exhibit " 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, the Defendant made, executed, and delivered to Mortgage Electronic Registration Systems, Inc. as Nominee for CitiMortgage, Inc., a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 14, 2008 as Instrument Number 200833971 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MIDFIRST BANK and will be sent for recording, which Assignment is attached hereto and marked Exhibit B ". The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 36 WEST COOVER STREET, MECHANICSBURG, PA 17055 and is more particularly described in Exhibit "C" attached hereto. 6. The Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on October 01, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $156,677.77 Interest at $30.05 per day $7,271.55 From 09/01/2012 To 05/01/2013 ( based on contract rate of 7.0000 %) Accumulated Late Charges $261.72 Good through 03/25/2013 Escrow Deficit $17.42 Corporate Advance $50.00 Attorney's Fee at 5% of Principal Balance $7,833.89 TOTAL $172,112.35 "Together with interest at the per diem rate noted above after May 01, 2013 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated February 11, 2013 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the February 11, 2013 Act 6 Notice is attached hereto and marked Exhibit "D ". 9. The within Mortgage is insured by the Federal Housing Administration under Title Il of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non - active military duty is attached as Exhibit "E ". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.0000% ($30.05 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: PU11rCELL, 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) Multistate NOTE FHA Case tV0. --- 441- 8526545 703 September 23, 2008 [mi] 36 W COOVER ST, MECHANICSBURG, PA 17055 -6436 [Property Ad b=) 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means CitiMortgage, Inc. and its successors and assigns. 2. BORROWER'S PROMISE -TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of One Hundred Sixty Three Thousand Nine Hundred Twenty Two Dollars (U.S. $ 163,922.00 }, plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Seven percent ( 7.000 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument" The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on November 1, 2008 Any principal and interest remaining on the first day of October, 2038 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 1000 Technology Drive, O' Fallon, MO 63368 -2240 by notice to Borrower. or at such place as Lender may designate in writing (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 1, will be part of a larger monthly payment required by the Security Instrument that sh090. ed to principal, to r es and o ther items in the order described in the Security Instrument. , all bep (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shalt be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑Graduated Payment Allonge ❑Growing Equity Allonge ❑ether [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the pe nalty, mount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 002005659449 FHA Multistate Fixed Rate note - g -1R (020 ).02 Pape 1 of 2 VMP MORTGAGE FORMS - (800)521.7291 CitiMortgage 3.2.17.03 VI bl'I Init(t �' 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as Para Four percent ( 4.000 e in th de. cribed in graph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge amount of (B) Default %) of the overdue amount of each payment. If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above. Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a differe Borrower has given Lender a notice of Borrower's different address. nt address if Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and c it fined in this Noce. (Seal) R W"AST BANK Michael E. Watson orrower without rccourte on s tti nc. Janet i for fee PresI nt lNortgage,. inc. 002005659449 4 0 -IR 40210).02 Page 2 of 2 CiriMottgage 3.2.17.03 V 1 Prepared by and Return to: Latisha Henderson MidFirst Bank 2730 North Portland Avenue Oklahoma City, OK 73107 Loan # 54413395 MIN No. 100011520056594494 MERS Phone: (888) 679 -6377 i ASSIGNMENT OF MORTGAGE FOR VALUE RECEIVED, Mortgage Electronic Registration Systems, Inc., acting solely as nominee for CitiMortgage, Inc., its successors and assigns, 1901 E. Voorhees Street, Suite C, Danville, IL 61834, (hereinafter called the "Assignor"), ), does hereby grant, convey, assign, transfer and set over to MidFirst Bank, A Federally Chartered Savings Association, 999 NW Grand Blvd., Suite 100 Oklahoma City, OK 73118, (hereinafter called the "Assignee "), its successors and assign's, all to the Assignor's rights, title and interest in and to: The Mortgage dated 09/73/08, executed by Michael E. Watson, Individual, to Mortgage Electronic Registration Systems, Inc., acting solely as nominee for CitiMortgage, Inc., recorded on 10/14/08, as Instrument No. 200833971, in the Office of the Recorder, Cumberland County, State of Pennsylvania, j and covers the following real property and all improvements: Mortgage Amount: $163,922.00 j Property Address: 36 W Coover St, Mechanicsburg, PA 17055 -6436 Parcel Number: 16240787053 Legal Description: See Attached for Legal Description. In Witness Whereof', the undersigned corporation has caused this instrument to be executed v 2013. day of March, j ATTEST: Mortgage Electronic Registration Systems, Inc., ac ' nominee for Cit ortgage, Inc., its su ors and signs i tte Ga er Vice President f i �br STATE OF OKLAHOMA COUNTY OF OKLAHOMA On this 21! } day of March, 2013, before me, a Notary Public, in and for said county, personally appeared Bette Garver, to me personally known, who being by me duly sworn did say that she is the Vice President of Mortgage Electronic Registration Systems, Inc., acting solely as nominee for CitWortgage, Inc., its successors and assigns, and that the within instrument was signed on behalf of said corporation by authority of its Board of Directors, and that they acknowledged the execution of said instrument to be the voluntary act and deed of said corporation, executed for the uses and purposes set forth. In testim whereof, I have hereunto set my hand and official seal this ' S + day of March, 2013. y Ca arber Notary Public E ..7 GAROI L. HARBERYVMW 1 My Commission Expires: 03/11/2014 w Notary Pubk State of Okla mia ; Commissoor►# 10002089 Eupires Outili4 I do hereby certify that the address of the assignee is: MidFirst Bank, 999 NW Grand Blvd., Suite 100 Oklahoma City, OK 73118 Latisha Henderson i ALL that tarts it lot of 9MUM situate on the north she of West Cower Street pjnt WardN In t' l orongb, of MedtanksbuM Coax ty of Cau*eriand, :wtd State of PORRSYlvania, bowded and descrOmd as follows, #o -wit: BEGIN NTNO at sn iron pits on the building Hoe of said Coover Street and at corntr of lost f0 medy of Viola B. Lucas, ttow or foratedy of Aga Haller; tbeaee by the Ilse Of loot Of satd A na$ Nailor, Northward 139.00 feet,, more or less, to ass inn * at FIB] ey; thence by idd alley, Eastward 50.00 feet to an iron pia atj said FRU ARey, acrd at comer of lot tow or forn►trly of Mn. &V. Sin; tit ece by the line of said lot, Saatht+zrid 139.00 feet; more or less, to an Iron pia[ at the building line of sold. Cowyer Ste# thence by the buBaiag fte of Bald Coower Street, Westvvwt so.00 feet to an iron pin on said building Hone, at the phm of b e e njo t 2g . BEING designated as Tax Patel 016 -24- 0787 -053 Npuln 112E 112 B 11` I W2 M • idland Mortgage A Division of MidFirst Bank AW P.O. Box 268806 • Oklahoma City, OK 73126 Tel: 800.552.3000 • Fax: 405.767.581S • MyMidlandMortgage.com 02/11/13 sal MD441R112E1128 1 Plof2 MICHAEL E WATSON 36 W COOVER ST MECHANICSBURG PA 17055.6436 NOTICE OF INTENTION TO FORECLOSE AND ACCE gRATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO.6 OF 1974 RE: 36 W COOVER ST MECHANICSBURG PA 17055 -6436 Loan Number 0054413395 Dear Mortgagor: The MORTGAGE held by MidFirst Bank (Lender), serviced by Midland Mortgage, on your property located at the address above IS IN SERIOUS DEFAULT because you have not made monthly payments totaling $7,656.08 for the months of 10/01/12 through 02101/13. Late charges and other charges have also accrued to this date in the amount of $35.00. The total amount now required to cure the default (or in other words, to get caught up on your payments), as of the date of this letter, is $7,621.08. You may cure this default within THIRTY -FIVE (351 DAYS f the d tt of this leer, by Ravin to Midland Mortgage the above payment of 17.621.08, plus any additional monthly payments and late charges which may fall due du dna this period. Such payment must be made either by cashier's check, certified check or money order, and made to Midland Mortgage at P.O Box 268888, Oklahoma City, OK 73126 -8888. If you do not cure the default within THIRTY -FIVE (35) DAYS, the Lender intends to exam se its right to accelerate the mortaeae 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 -FIVE (35) DAYS, the Lender also intends to instruct its attomevs to start a !MMit to foredose Your Mgdgagtpmetty. If the mortaaae is &LI&Ied your mortaaaed property will be sold by the SbwW to pay off the mgne debt If the Lender refers your case to its attorneys, but you cure the default before before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe, which may also include reasonable costs. If you cure the default within the thirty -five day period you will not be required to Day attorneys fees The Lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. `ff you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently In bankruptcy under the protection of the automatic stay, this War is not an attempt to ooka the debt, but any default MN need to be cured to avoid foreclosure. If your loan was in default at the time MidFb* Bank acquired the servicing of your loan and you have not fled bankruptcy or received a discharge of the debt secured by the Mortgage/Deed of Trust, we are required to advise you that this communication is from a debt collector, this is an attempt to coliect a debt, and any information obtained wNl be used for that purpose. Np41 R 11= = "2 1' =.I = Midland Mortgage A Division of MidFirst Bank P.O. Box 268806 • Oklahoma City, OK 73126 Tel: 800.SS2.3000 • Fax: 40S.767.581S • MyMidlandMortgage.com If you have not cured the default within the thirty -five 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 Sheriffs foreclosure sale You may do so by paving tie total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable att -DIMVs fees and costs cormected Eft the foreclosure sale and by performina any other reauirements if any, under the mortaaae It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six months from the date of this letter. 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 Midland Mortgage at the following number: 1- 800 - 552 -3000. This payment must be made by cashier's check, certified check or money order and made payable to Midland Mortgage at the address stated above. You should realize that a Sheriffs 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 Sheriffs 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 THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND ANY OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED, CONTACT MIDLAND MORTGAGE 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 some position as if no default had occurred„ However, you are not entitled to this right to cure your default more than three times in any calendar year. It is important that you call our office as soon as possible to discuss the options available to you. Our Loan Counselors may be reached toll -free at 1- 800 -552 -3000, Monday through Friday, 8:00 a.m. to 9:00 p.m. (Central Time). Sincerely, Delinquency Assistance Center Midland Mortgage, a Division of MldFirstBank Loan Number 0054413395 1 'If you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently in bankruptcy under the protedbn of the automatic stay, this letter is not an attempt to collect the debt, but any default wilt need to be cured to avoid foreclosure. If your loan was in default at the time MldFirst Bank acquired the servicing of your ban and you have not filed bankruptcy or received a discharge of the debt secured by the MortgageMeed of Trust, we are required to advise you that this communication is from a debt collector, this is an attempt to collect a debt, and any Information obtained ON be used for that purpose. Cumberland County CCCS of Western PA — York Mary Loftus 55 Clover HUI Road Dallastown PA 17313 888.511.2227 mio#tuagbeccsoa.orn www.carsDa.oro Pre.Purchase and Pre.Closing Educational Seminars i a i i i i i i Department of Defense Manpower Data Center Results as or: Feb•25.2D13 07 :45:32 SCRA 2.3 St•>ato R e P==rt to Semicemmb= Civil Relief Act. Last Name: WATSON First Name: MICHAEL Middle Name: Active Duty Status As Of: Feb -25 -2013 a �� .$lair �x AC1iri _, Y.^'{ - -:�. - .. `' i N:e, h_c tf •.i^ � _ � W X NA NA.. - Thisrapm a _' �riYv� !�` oiitli%i1 . Qtit) Adw Date NA_ IOWA: _ s. �:. : Active WtY.iaalt [iaM :, :, t r �� � rP ; M •. a Y r . z , This tesporw reMds r � indlydlM NR'ao11Ji , ' t akys prsos tlt� , Sh" Des k ioAsilw�9:t. tjt r .OMs ;. ondsrNolNfoMbnSlMDau. O�daf.NgYleWer�End�IS d" mo rw " NA NA reapohte tellscb aAlMhst lu,')lidJidi y.pf MAM{ !auP!!d.. b MW la active duo' upon searching the data banks of the Department of Defense DatA.. '. -bated 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 (Amty, Navy, Marine Corps, Air Force, NOAH, Public Health, and . Coast Guard). This status includes information on a Servicemernber or his/her unit receiving notification of future orders to report for Active Duty. i Mary M. Snavely - Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 I T 1 COMPANY NAME: MIDFIRST BANK 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. Dated `( 19 / 1 - 5 Kyle Brown saaiorFae Title Litigation specialist IN THE COURT OF COMMON PLEAS OF r C7 C c MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) M UD ,. rn `v m ';�o � 7D VS. to > N 0 C? MICHAEL E. WATSON Defendants) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM /S FREE. Respectfully fitted: 4/11/13 Date Leon . If.aller / Jill M. Wineka Attorney for Plaintiff' Purcell, Krug and Haller 1719 North Front Street Harrisbu PA 17101 PA ID 1576 / 58802 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowl , e: Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of p eople in household: Haw 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: Asset Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles boats motorcycles) Model: Year: Amount owed: Value: Monthly income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co- Borrower Pay Days: M R OMN Expen (Please only include expenses you are curr nrly na. EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other ;Expenses p. Payment Install. Loan Payment Cable Child Sup ort/Alim. S endMoney Day /Child Care/Tuit. Other 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): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes F� No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I /We, authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed IN THE COURT OF COMMON PLEAS OF MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. MICHAEL E. WATSON Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date SHERIFF'S OFFICE OF CUMBERLAND COUN�i.W' Ronny R Anderson °?1 E -OHi Sheriff D F T H C PRA i I110+Nt0 1A Jody S Smith r Chief Deputy 2013 A Y ^'8 PPI 3: 14 °' Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Midfirst Bank Case Number vs. 2013-1937 Michael E Watson SHERIFF'S RETURN OF SERVICE 05/01/2013 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 Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 36 West Coover Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant. 05/02/2013 08:21 PM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the 2E, dant,to wit: Michael E Watson at 31 Liberty Court, South Middleton, Carlisle, PA 17013 LIAM CLI SHERIFF COST: $61.08 SO ANSWERS, May 03,2013 RON R ANDERSON, SHERIFF tc}CountySuite Shontf,Toleoso7t.Inc. 1719 NORTH FRONT STREET PENNSYLVANIA HARRISBURG, PA 17102-2392 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW VS . NO. 13 - 1937 CIVIL MICHAEL E. WATSON IN MORTGAGE FORECLOSURE Defendant MOTION TO LIFT STAY IMPOSED BY THE MORTGAGE FORECLOSURE DIVERSION PROGRAM AND NOW comes Plaintiff, MidFirst Bank, through it ' s counsel, Leon P. Haller, and in accordance with Paragraph (k) of the order of February 28, 2012 , establishing the Mortgage Foreclosure Diversion Program, represents as 1 . The within foreclosure action was filed April 12 , 2013 . 2 . Service of the Complaint and Notice of Residential Mortgage Foreclosure Diversion Program was made on May 2 , 2013 . 3 . DEFENDANT DOES NOT RESIDE IN THE WITHIN PROPERTY. 4 . Defendant has not opted to participate in the Mortgage Foreclosure Diversion Program. 5 . Plaintiff, in accordance with the provisions of the Mortgage Foreclosure Diversion Program, requests that the stay be lifted. WHEREFORE, Plaintiff requests that the stay imposed by the Cumberland County Mortgage Foreclosure Diversion Program be lifted to allow Plaintiff to proceed with the foreclosure action. PURCELL, KRUG & HALLER By eon P. Haller 1719 North Front Street Harrisburg, PA 17102 -2392 (717) 234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: May 31, 2013 VERIFICATION I verify that the statements made in the foregoing Petition to Lift Stay, are true and correct . I understand that false statements herein are made subject to the penalties of 18 Pa . C . S . Section 4904 relating to unsworn falsification to authorities . Le n P . Haller Dated : May 31 , 2013 N- LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs . CIVIL ACTION - LAW NO. 13 -1937 CIVIL MICHAEL E. WATSON IN MORTGAGE FORECLOSURE Defendant CERTIFICATE OF SERVICE I. Leon P. Haller, the undersigned, Attorney for Plaintiff, hereby certify that I served on the 31st da of the Petition to Lift Stay Imposed by Mort y of May' 2013, a copy Mortgage Foreclosure Diversion Program upon each of the following person at the addresses shown below: Michael E. Watson 31 Liberty Court Carlisle, PA 17013 Dated: May 31, 2013 Leon P. Hall r Attorney for Plaintiff 7 MIDFIRST BANK 1N 'iHE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW Vs . NO. 13 - 1937 CIVIL MICHAEL E . WATSON IN MORTGAGE: FORECLOSURE Defendant ORDER AND NOW, this /0• day of 94m- , 2013 , upon , consideration of Plaintiff Petition to Lift Stay, Notice of the Residential Mortgage Foreclosure Diversion Program having been served on April 2, 2013 , and Defendant having not opted to participate in the Mortgage Foreclosure Diversion Program, IT IS HEREBY ORDERED that the stay imposed by the Mortgage Foreclosure Diversion Program be lifted and Plaintiff may proceed with its mortgage foreclosure action. BY THE COURT : J. �!3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW AT NO, 13-1937 MIDFIRST BANK, Total Judgment Amount $1$6,112.3 5 PLAINTIFF Interest $6,520.35 Per diem of$30.05 to sale VS. date 12/4/2013 Late Charges $130.86 MICHAEL E. WATSON, per month to sale date DEFENDANT(S) 12/4/2013 Escrow Deficit $2,630.40 TOTAL WRIT $181,393.96 *Plus additional interest,late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday,December 04,2013 (PROTHONOTARY'S USE) Pltf.Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION-MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: July 26,2013 =- z Attorney for Plaintiff ZZ 1719 North Front Street L Haller �n ' ! . Harrisburg,PA 17102 A I-D. #15700 vii (717)234-4178 i = ' WRIT OF EXECUTION-MORTGAGE FORECLOSURE o Z -.Ti r 4 -3 COMMONWEALTH OF PENNSYLVAN -+ - � SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND CO TY: To satisfy the judgment, interest and cos in a above captioned case,you are directed to levy upon and sell the property described in the attached descrip 'o known as 36 WEST COOVER STREET MECHANICSBURG,PA 17055 Date: ® ROT HON OTARY/CLERK CIVIL,DIVISION BY 014D. SU pal Q (� 1 ok I'VP DEPUTY /o /��S fr--� <+ ALL THAT CERTAIN lot of ground situate on the north side of West Coover Street(First Ward) in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at an iron pin on the building line of said Coover Street and at comer of lot formerly of Viola B. Lucas,now or formerly of Anna Nailor;thence by the line of lot of said Anna Nailor,Northward 139.00 feet,more or less,to an iron pin at Hill Alley;thence by said alley,Eastward 50.00 feet to an iron pin on said Hill Alley,and at comer of lot now or formerly of Mrs.B.F. Senseman;thence by the line of said lot Southward 139.00 feet,more or less,to an iron pin at the building line of said Coover Street;thence by the building line of said Coover Street, Westward 50.00 feet to an iron pin on said building line,at the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 WEST COOVER STREET MECHANICSBURG, PA 17055 TAX PARCEL: 16-24-0787-053. BEING THE SAME PREMISES WHICH Michael E. Watson and Beth A. Watson,husband and wife by deed dated 09/28/08 and recorded 10/14/08 in Cumberland County Instrument No. 200833970, granted and conveyed unto Michael E. Watson. Subject to building lines,rights of way, easements,mining and mineral rights,restrictions,reservations and exceptions as set forth on the recorded plan and as may appear in prior instruments of record. TO BE SOLD AS THE PROPERTY OF MICHAEL E. WATSON ON JUDGMENT NO. 13-1937 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E.WATSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE 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 36 WEST COOVER STREET MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): `. MICHAEL E. WATSON 31 LIBERTY COURT CARLISLE, PA 17013 > r" � MICHAEL E. WATSON c-, n' :Z CD 36 WEST COOVER STREET 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: NONE 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: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 WEST COOVER STREET MECHANICSBURG, PA 17055 (In the preceding information, where addresses I could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities Leon t,446111er PA I.D. #15100 Purcell, Krug& Haller 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 DATE:July 26, 2013 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E.WATSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: C cS That the Sheriffs Sale of Real Property (real estate) will be held: c r- DATE: Wednesday,December 04,2013 c TIME: 10:00 O'clock A.M. =o C):z-5 �? o C7," LOCATION: Cumberland County Courthouse w 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: 36 WEST COOVER STREET 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. 13-1937 JUDGMENT AMOUNT $172,112.35 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MICHAEL E. WATSON f 1 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 awn A lawyer can you more specifically of these rights. If you wish to exercise your rights YOU MUST advise PROMPTLY. f YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL,KRUG &HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 ALL THAT CERTAIN lot of ground situate on the north side of West Coover Street(First Ward)in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at an iron pin on the building line of said Coover Street, and at comer of lot formerly of Viola B. Lucas,now or formerly of Anna Nailor;thence by the line of lot of said Anna Nailor,Northward 139.00 feet,more or less,to an iron pin at Hill Alley;thence by said alley,Eastward 50.00 feet to an iron pin on said Hill Alley,and at comer of lot now or formerly of Mrs. B. F. Senseman;thence by the line of said lot Southward 139.00 feet more or less,to an iron pin at the building line of said Coover Street;thence by the building line of said Coover Street,Westward 50.00 feet to an iron pin on said building line,at the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 WEST COOVER STREET MECHANICSBURG, PA 17055 TAX PARCEL: 16-24-0787-053. BEING THE SAME PREMISES WHICH Michael E. Watson and Beth A. Watson,husband and wife by deed dated 09/28/08 and recorded 10/14/08 in Cumberland County Instrument No.200833970,granted and conveyed unto Michael E.Watson. Subject to building lines,rights of way,easements,mining and mineral rights,restrictions,reservations and exceptions as set forth on the recorded plan and as may appear in prior instruments of record. TO BE SOLD AS THE PROPERTY OF MICHAEL E. WATSON ON JUDGMENT NO. 13-1937 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1.937 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK Plaintiff(s) From MICHAEL E.WATSON (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: $172,112.35 L.L.: $.50 Interest PER DIEM OF$30.05 TO SALE DATE 12/4/2013-$6,520.35 Atty's Comm: Due Prothy:$2.25 Atty Paid: $209.83 Other Costs: LATE CHARGES PER MONTH TO SALE DATE 12/4/201.3-$130.86 ESCROW DEFICIT-$2,630.40 Plaintiff Paid: Date: 8/2/13 r LBy:id D. B ell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: LEON P. HALLER,ESQUIRE Address: PURCELL,KRUG&HALLER 1719 NORTH FRONT STREET HARRISBURG,PA 17102 Attorney for:PLAINTIFF Telephone: 717-243-4178 Supreme Court ID No. 15700 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW MICHAEL E. WATSON, NO. 13-1937 DEFENDANT(S) r.n E= MORTGAGE FORECLOSURE --;t 73 C5 PRAECIPE :< ::x C TO THE PROTHONOTARY OF THE WITHIN COUNTY: CD Z3 (-- Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant} MICHAEL E. WATSON for failure to plead to the above action within twenty (20)days from date of service of the Complaint, and assess Plaintiffs damages as follows: Unpaid Principal Balance $156,677.77 Interest $7,271.55 Per them of$30.05 From 09/01/2012 To 05/01/2013 Accumulated Late Charges $261.72 Corporate Advance $50.00 Escrow Deficit $17.42 5%Attorney's Commission $7,833.89 TOTAL $172,112.35 "Together with additional interest at the per them rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG&HAL By Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 s „ r MIDFIRST BANK, IN T14E COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 13-1937 MICHAEL E. WATSON Defendant CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: June 26,2013 TO: MICHAEL E. WATSON 31 LIBERTY COURT CARLISLE, PA 17015 MICHAEL E. WATSON 36 WEST COOVER STREET 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, KRUG ALLER By LEON P. HALLER, Att orney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717)234-4178 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E.WATSON, DEFENDANT IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendants above named is not on active duty in the Military Service nor engaged in any way which would bring them within the Servicemembers' Civil Relief Act. A copy of the search through the Defense Manpower Data Center website is attached. Sworn to and subscribed before me this day of 20/3 LEO P. HALLER, ESQUIRE of y ublic OOMMONI WEALTH G PEIN "YLVANIA NOTARIAL SEAL. MARYLAND l:.FERRET TI,Notary Public Lower Paxton TuvP.,Daupiin County My Commission Expires Aug.8,2014 Results as of:Jul-29-2013 06:46:34 Department of Defense Manpower Data Center SCRA 3.0 s Statm Report li pursuant to Sere cememben Civil Relief Act Last Name: WATSON First Name: MICHAEL Middle Name: .E Active Duty Status As Of: Jul-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No- NA This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA 'tt -_ a°. t �> -�No' NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date 1 4 J The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .NA. -' _ a — No NA This response reflects whether the Individual or hislher unit has received early notification to report for active duty r 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 9F A � Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink,mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 2367276E6OC7FOO MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E.WATSON, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN I, LEON P. HALLER, Attorney for the Plaintiff in the above matter,being duly sworn according to law,hereby certify that the Mortgage in the above case is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 1715zl 1) and therefore does not fall within the provisions of PA Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program). Sworn to and subscribed before me this yday of 20a ON P. HALLER,ESQUIRE No , blic ,WINIONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARYLAND K.FERRETTI,Notary Public Lower Paxton Twp.,Dauphin County My�ominiooio��xpir®�AuB 0, 2014 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E. WATSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on ao I x,013 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: MICHAEL E. WATSON 31 LIBERTY COURT CARLISLE, PA 17013 MICHAEL E. WATSON 36 WEST COOVER STREET - MECHANICSBURG, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse a' 13 North Hanover Street -c Carlisle, PA 17013 TENANT/OCCUPANT 36 WEST COOVER STREET MECHANICSBURG, PA 17055 PURC UG& HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 1 LAW OFFICES 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 HERSHEY LEON P.HALLER TELEPHONE(717)2344178 (717)533-3836 JOHN W.PURCELL JR. FAX(717)234-1206 JILL M.WINEKA LISA RYNARD MICHAEL E. WATSON 31 LIBERTY COURT CARLISLE, PA 17013 MICHAEL E. WATSON 36 WEST COOVER STREET MECHANICSBURG, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 WEST COOVER STREET MECHANICSBURG, PA 17055 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. By: Leo aller PA I.D.15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION LAW NO. 13-1937 MICHAEL E. WATSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE 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,December 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: 36 WEST COOVER STREET 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. 13-1937 JUDGMENT AMOUNT $172,112.35 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MICHAEL E. WATSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 ALL THAT CERTAIN lot of ground situate on the north side of West Coover Street(First Ward)in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at an iron pin on the building line of said Coover Street, and at corner of lot formerly of Viola B. Lucas,now or formerly of Anna Nailor;thence by the line of lot of said Anna Nailor,Northward 139.00 feet,more or less,to an iron pin at Hill Alley; thence by said alley, Eastward 50.00 feet to an iron pin on said Hill Alley,and at corner of lot now or formerly of Mrs. B. F. Senseman;thence by the line of said lot Southward 139.00 feet,more or less,to an iron pin at the building line of said Coover Street;thence by the building line of said Coover Street, Westward 50.00 feet to an iron pin on said building line, at the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 WEST COOVER STREET MECHANICSBURG, PA 17055 TAX PARCEL: 16-24-0787-053. BEING THE SAME PREMISES WHICH Michael E. Watson and Beth A. Watson,husband and wife by deed dated 09/28/08 and recorded 10/14/08 in Cumberland County Instrument No. 200833970, granted and conveyed unto Michael E. Watson. Subject to building lines,rights of way, easements,mining and mineral rights,restrictions,reservations and exceptions as set forth on the recorded plan and as may appear in prior instruments of record. TO BE SOLD AS THE PROPERTY OF MICHAEL E. WATSON ON JUDGMENT NO. 13-1937 7 7196 9009 9111 9610 4642 196 9008 9111 9610 4659 'i TO: MICHAEL E.WATSON TO: MICHAEL E.WATSON 31 LIBERTY COURT i 36 WEST COOVER STREET CARLISLE,PA 17013 MECHANICSBURG,PA 17055 E I E f SENDER: M02090/39787 SENDER: M02090/39787 1 REFERENCE: NOS 12/04/13 ' REFERENCE: NOS 12/04/13 PS Form 3800 January 2005 _ _ PS Form 5800 J. anuaro 2005 - — RETURN _Postage V(�(� RETURN Postage 66 RECEIPT Certified Fee -3.10 RECEIPT Certified Fee 3.10 _ SERVICE SERVICE Return Receipt Fee 155 Return Receipt Fee 2,._55 __. _ .- Restricted Delivery 4.75 Restricted Delivery 4.75 _ Total Postage&Fees 17106 Total Postage&Fees / uspr POSTMARK OR DATE usm POSTMARK OR DATE Receipt for Receipt for Certified Mail"' ' Certified Mail" No Insurance C:a++rtrge PmW*d "= No WdunVM Caws Provldsd h` 00 Not uw for InYm WAI Ma! 00 Not uM for kowne w and MIDLAND MORTGAGE v.MICHAEL E. WATSON Cumberland County Sale 12/4/2013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: MICHAEL E. WATSON 31 LIBERTY COURT CARLISLE,PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: MICHAEL E. WATSON 36 WEST COOVER STREET MECHANICSBURG, PA 17055 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 1 NINE HOlmS 0 2 1r1 $ 01.200 0004234324 AUG20 2013 MAILED FROM ZIP CODE 1 7102 MIDLAND MORTGAGE v. MICHAEL E. WATSON Cumberland County Sale 12/4/2013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 36 WEST COOVER STREET MECHANICSBURG,PA 17055 40S P%' z WfNEY BOWES 02 1 K $ 01-200 0004284324 AUG20 2013 M'AILED FROM ZIP GODE 1710 2 r SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �nx�5x�r otc�►rrr���,�,�� � �,... t �±� ��G�i f���' 'd 'F:';},�';' Jody S Smith Chief Deputy AM 10: F t Richard W Stewart �(�3 ESE F(L,=" ND Co!ftq Solicitor �,�� ��F���'�FtGRIFF P E NN S Y Midfirst Bank vs. Case Number Michael E Watson 2013-1937 SHERIFF'S RETURN OF SERVICE 09/20/2013 08:57 PM - Deputy Shawn Gutshall, 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 36 West Coover Street, Mechanicsburg -Borough, Mechanicsburg, PA 17055, Cumberland County. 09/27/2013 02:43 PM -Deputy Brian Grzyboski, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Elizabeth Brinley-Step Daughter, who accepted as"Adult Person in Charge"for Michael E Watson at 31 Liberty Court, South Middleton, Carlisle, PA 17013, Cumberland County. 12/04/2013 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, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Leon Haller, on behalf of MidFirst Bank, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $780.64 SO ANSWERS, January 10, 2014 RON R ANDERSON, SHERIFF -7ve) (c)CountySuite Sheri B,TeiecsoR,Inc. On August 23, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 36 West Coover Street, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 23, 2013 By: Real Estate Coordinator 0 JJIII LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-1937 Civil Term MIDFIRST BANK VS. MICHAEL E.WATSON Atty.: Leon P.Haller ALL THAT CERTAIN lot of ground situate on the north side of West Coover Street (First Ward) in the Borough of Mechanicsburg, County of Cumberland and State of Penn- sylvania,and having thereon erected a dwelling known as: 36 WEST COOVER STREET, MECHANICS- BURG,PA 17055. TAX PARCEL: 16-24-0787-053. Reference Cumberland County Instrument No.200833970. TO BE SOLD AS THE PROPERTY OF MICHAEL E.WATSON ON JUDG- MENT NO. 13-1937. 132 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: October 11, October 18 and October 25, 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 Coyne, ditor SWORN TO AND SUBSCRIBED before me this 25 da y of October, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. ,,?- 20 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 2013-1937 CMI Term_ 10/13113 MIDFIRST BANK Vs. 10/20/13 MICHAEL E wATSON Atty: Leon P.Haller ` 10/27/13 ALL THAT CERTAIN lot of ground situate on the north side of West CnOVCr Street(First Ward) in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, and having thereon erected a dwelling known as: 36 WEST COOVER STREET,MECHANICSBURG,PA 17055 Swor to n subscribed before met s day of November, 2013 A.D. TAX PARCEL: 16-24-0787-053. Reference Cumberland County Instrument No.200833910. TO BE SOLD AS THE PROPERTY OF U II MICHAEL E.WATSON ON JUDGMENT NO.13-1937 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel,Notary Public Washington Twp.,Dauphln County Ply Commission Expires Dec,12,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which MidFirst Bank is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 2nd day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1937, at the suit of MidFirst Bank against Michael E. Watson is duly recorded as Instrument Number 201401155. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this �� day of J G 0 , A.D. WJJ,& Af )i Recorder of Deeds Redder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018