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HomeMy WebLinkAbout13-2110 Supreme Couf<Pennsylvania 4 ` ` For Prothonotary Use and Cour �of-Cornrnon,.Pleas ry y� G AI'CoverI�Sh&t Docket No; �� 1 S . Cum�berland' County -) �/ A/• 3f 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 by law or rules nfcourt. Commencement of Action: S !X Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction Q Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Fulton Bank N.A. Arthur Clark T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? 0 Yes ER No (check one) !x;outside arbitration limits 0 N Is this a Class Action Suit? Q Yes ES No Is this an MDJAppeal? [ Yes [@ No A Name of Plaintiff'/Appellant's Attorney: 0 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 PRI"Y 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 Intentional 17 Buyer Plaintiff Administrative Agencies Q Malicious Prosecution 0 Debt Collection:Credit Card 0 Board of Assessment Motor Vehicle 0 Debt Collection:Other [ Board of Elections Nuisance Dept.of Transportation Premises Liability H Statutory Appeal:Other S [ Product Liability(does not include mass tout) (� Employment Dispute: E+ Discrimination 0 Slander/Libel/Defamation Employment Dispute:Other 0 Zoning Board C [3 Other: T 0 Other: I 0 Other: U MASS TORT 0 Asbestos N [3 Tobacco M Toxic Tort-DES Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 171 Ejectment 0 Common Law/Statutory Arbitration 0 Other: Declaratory Judgment Eminent Domain/Condemnation 0 0 Ground Rent Q Mandamus 0 Landlord/Tenant Dispute ®Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 13 Quo Warranto 0 Dental 0 Partition 0 Replevin Legal 0 Quiet Title 0 Other: ® Medical 0 Other: 0 Other Professional: Updated Ill/2011 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN,ESQUIRE - ID#04302 STUART WINNEG,ESQUIRE -ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE - ID#34576 cam-:. SHERRI J.BRAUNSTEIN,ESQUIRE -ID#90675 SALVATORE CAROLLO,ESQUIRE- ID#311050 rn �. HARRY B. REESE,ESQUIRE - ID#310501 t ELIZABETH L.WASSALL,ESQUIRE- ID#77788 —, KATHERINE E.KNOWLTON, ESQUIRE - ID#311713 y< o JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 zo i E i5 E3 NICOLE B.LABLETTA,ESQUIIRE - ID#202194 DAVID NEEREN,ESQUIRE - ID#204252 ° JORDAN DAVID,ESQUIRE-ID#311968 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS C/O Fulton Bank-Direct Referred CIVIL DIVISION One Penn Square CUMBERLAND County Lancaster,PA 17602 I Plaintiff NO. V. ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND,PA 17070 Defendant(s) COMPLAINT IN 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 C� y� d3 t"cc u g a 8g3gs 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte 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 u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. 'If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify .us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt,and any information obtained will be used for that purpose. UDREN LAW OFFICES,F.C. /s/Mark J.Udren,Esquire Woodcrest Corporate Center 111 Woodcrest Road,Suite 200 Cherry Hill,NJ 08003.3620 (856) 669-5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems,Inc. Assignee: Fulton Bank,N.A. Date of Assignment: 11/29/2012 Recorded Date: 12/10/2012 Book/Instrument#: Instrument No: 201238201 Page: 2. Upon information and belief Defendant(s) and/or their predecessor: Arthur Clark (hereinafter"Defendants"),are the owners of property located at 220 Reno Avenue, New Cumberland,PA 17070,by virtue of Deed dated 06/14/2010 and recorded 06/16/2010 in Official Records Book Instrument#201015779 at Page n/a of the Public Records of Cumberland County, Pennsylvania(hereinafter the "Property"). 3. On 06/14/2010, Defendant(s) and/or their predecessor: ARTHUR CLARK promised to pay to the order of Fulton Bank,N.A. ,the principal sum of $70,320.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/14/2010 ,Defendant(s) and/or their predecessor: ARTHUR CLARK to secure the Note,mortgaged to Mortgage Electronic Registration Systems,Inc., acting solely as a nominee for Fulton Bank,N.A., the Property which is the subject of this action. The Mortgage was recorded on 06/16/2010 in Official Records Book Instrument No: 201015780 at Page n/a. .Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 08/01/2012, and all subsequent payments have not been made, and by its terms,upon breach and failure to cure said breach after notice, all sums secured by said Mortgage,together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand,the Defendant(s)continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; y (b) By failing or refusing to pay other charges,if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $68,238.26 Accumulated Interest $2,689.94 Accumulated Late Charges $191.40 Escrow Deficit/(Reserve) $1,213.05 Property Inspection fees $50.00 Unapplied Balance $-606.26 Grand Total $71,776.39 The above figures are calculated as of 04/08/13: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 5.12500 %. The per diem interest accruing on this debt is$9.5800 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms.of the note and mortgage charged monthly at$19.14. 7. Breach letters have been sent to Defendant(s)in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of$ 71,776.39 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW FFI.. ES, P.C. BY: JOHN ERIC nsHBAWH,Eswiw PA ID 33M VERIFICATION The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: )111111-5 /Name: Title: Company: Fulton Bank,N.A. MJU#: 12110529 CASE#: 12110529-1. 11-30-'12 12:39 FROM-ABLE ABSTRACTS T-694 P0013/0014 F-199 EDIT "A" ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County,Pennsylvania, more particularly hounded and descried according to a survey made by Gerrit J. Betz, R.S., dated 30 March, 1973,as follows,to wit: BEGINNING at a drill hole on the South side of Reno Avenue (60 feet wide) at corner of lands now or late of Clarie Brookie, being Rouse No. 222, said point being measured along the, said side of Reno Avenue, fifty-nine (59) feet to the southeast corner of Reno Avenue and Taylor Avenue; thence extending from said point of beginning and along Reno Avenue,South fifty-one(51)degrees thirty(30) minutes East, the distance of eighteen and zero hundredths (18) feet to a drill hole at the corner of lauds now or late of Derwin Salter, being House No. 216, thence along lands now or late of Derwin Salter, South thirty-eight (38) degrees thirty (30) minutes West, the distance of one hundred forty and zero hundredths (140.00) feet to a PK nail on the North side of Cherry Alley; thence along Cherry Alley, North fiiiy-one (51) degrees thirty (30) minutes 'West, the distance of eighteen and zero hundredths (18.00)feet to a hub at the corner of lands now or late of Clarie Eroolde,North thirty-eight(38)degrees thirty(30)minutes East,the distance of one hundred forty and zero hundredths (140.00) feet to the point and place of BEGINNING. BEING 3 feet of Lot No.35 and 15 Feet of Lot No.36, Block B on the George W. ButterfPs Addition to New Cumberland and recorded in the Cumberland County Recorder's Office in Deed Book M,'Volume 5 at Page 500. BEING I04QWN AND NUMBERED as 220 Reno Avenue,New Cumberland,PA 17070. BEING the same premises which Terry W. Brubaker, Sr., married man and Susan J. Brubaker, married woman. by Deed dated the 13th day of February, 2004,and recorded at Cumberland County in the Office of the Recorder of Deeds, in and for the County of Cumberland, on the 6th day of April, 2004, in Record Book 262, Page 1844, granted and conveyed unto Terry W. Brubaker, Sr., And the said Paula R.Brubaker is joining with her husband and are the GRANTORS herein. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. UPI NO.25-25-0006-239. 1057.5801027010 Fulton Bank ATTN: James:Dankers PO Box 432 East Petersburg,PA 17520 Arthur Clark 220 Reno Ave New Cumberind,PA 17070-2047 Page I of 7 Exhibit A (This page intentionally left blank) Page 2 of 7 October 1, 2012 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 foreclose. 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 save your home. This Notice explains how the program works. To see if HEMAP can help 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 Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housina Finance Agency toll free at 1 (800) 342-2397 (Persons with impaired hearing 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 V.IVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO (1-800- 342-2397). PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 3 HOMEOWNER'S NAME(S): Arthur Clark PROPERTY ADDRESS: 220 Reno Ave ,New Cumber1nd, PA 17070-2047 LOAN ACCT NO.: 5801027010 ORIGINAL LENDER: Fulton Bank,NA CURRENT LENDER/SERVICER: Fulton Bank,NA as servicing agent for Federal National,Mortgage 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 CURE 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 after the date of this meeting.The names.addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prope4 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 Emergency C, -, 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 (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCYWTTHIN 33 DAYS FO THE POSTMARK DATE OF THIS NOTICE AND FILE ANT APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING.THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR. PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANYTIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 4 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 IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL 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 up to date) NATURE OF THE DEFAULT—The MORTGAGE debt held by the above lender on your property located at: 220 Reno Ave.New Cumberind,PA 17070-2047 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS FROM 08/01/12 THROUGH 10/01/12 and are currently past due for the following amounts: Total Payment Amount: $1,285.51 Late/Other Charges: $76.56 Attorney Fees: $0.00 TOTAL AMOUNT PAST DUE: $1,362.07 HOW TO CURE THE DEFAULT.—You may cure the default Mthin THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS $1,362.07,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check.certified check or monev order made payable and sent to: ATTN:Jessica Kilby Fulton Bank,NA PO Box 4887,Lancaster,PA 17604-4887 IF YOU DO NOT CURE THE DEFAULT—If you do not cure the default within THIRTY(30)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 (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon 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(30)DAY period.you will not be required to pav attorney's fees. OTHER LENDER REMEDIES—The lender may also sue you personally for the unpaid principal balance and all other sums due tinder the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE—If you have not cured the default within the THIRTY(30) 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 Sheriff's Sale You may do so by paying the total amount then past due plus anv 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 by performing any other requirements under the mortgage. 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 Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of 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. 5 HOW TO CONTACT THE LENDER: Name of Lender: Fulton Bank,NA Address: PO Box 4887,Lancaster..PA 17604-4887 Phone Number: (800)521-8617 x1859 Fax Number: (717)391-2908 Contact Person: Jessica Kilby Residential Mortgage Collector EFFECT OF SHERIFF'S SALE—You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and you 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. C ASSUMPTION OF MORTGAGE—If permitted by your mortgage documents. . you may be able to 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's 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 ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT, TO HAVE THIS 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 ANY 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. Sincerely, James L.Dankers Authorized Representative Fulton Bank,NA Certified and Regular Mail 6 Consumer Credit Counseling Agencies Cumberland County Community Action Commission of Capital Region Maranatha 1514 Derry Street 43 Philadelphia Avenue Harrisburg,PA 17104 Waynesboro,PA 17268 717-232-9757 717-762-3285 PHFA CCCS of Western PA 211 North Front Street 2000 Linglesto Am Road Harrisburg,PA 17110 Harrisburg,.PA 1.7102 717-780-3940 800-342-2397 888-511-2227 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 The Pennsylvania housing Finance Agency can be reached TOLL FREE at 1-800-342-2397. 7 FORM 1 IN THE COURT OF COMMON PLEAS 1 tt4{l �I CVO r CUMBERLAND COUNTY, PENNSYLV; -V'—J t 7X3(I�til 8 C:> vs. . Defendant(s) -1�#C> 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.(7)7)243-9400 extension 2510 or(800) 822-5288 extension 25 10 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 that 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 MidP.enn 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 wort: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 TI3.E STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date [Si na " of Counsel for Plaintiff] FORM Z Cumberland Counts Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: Citv: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied.? Yes ❑ No ❑ Mailing Address (if different): Citv: 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 people in household: How long? FINANCIAL INFORMATION 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& Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ .............................. ...... ............. ........... If yes,provide names., location of court, case number & attorney: Assets Amount Owed: Value: Rome: Other Real Estate: Retirement Funds: $ Investments: $ $ Checking: S $ Savings: $ $ Other: Automobile#1: Model: Year:— Amount owed: Value: Automobile 92:-Model: Year: Amount owed: Value: Other transportation (automobiles,boats, motorcycles): Model: Year:— Amount owed: Value Monthly'Income Name of Employers: 1. Additional Income Description(not wages): I monthly amount: monthly amount. Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortcraue Food 2"'0 Mortgage Utilities Car Payment(s)._ Condo/Neiah. Fees Auto Insurance 774M.ed.(not covered) Auto fuel/re2airs Other pro p. payment Install.Loan Pa.,ment Cable TV I Child SupportiAlim. Spending Money DayIChild Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income& Expenses: Have you been working with a Housing Counseling Agency? Yes F-1 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❑ -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? Yes F-1 No If yes,please indicate the status of those negotiations: Please,provide the I following information, if know,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company (Name): Contact: Phone: -AUTHORIZATION 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 possiblemortgage options. 1/We understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(if property is currently on the market) 3 FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY_ PENNSYLVANIA 7 L i.nff�) i k Yv,,r a. Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program.the undersigned hereby certifies i as follows: I. 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; ;. 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 false statements are made subject to the penalties of 1.8 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 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY­ MARK J. UDREN, ESQUIRE -ID#04302 STUART WINNEG,ESQUIRE -ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE -,ID#34576 SHERRI J.BRAUNSTEIN, ESQUIRE -ID#90675 Cp SALVATORE CAROLLO,ESQUIRE -ID#311050 M;Mi HARRY B. REESE,ESQUIRE - ID#310501 -0 ELIZABETH L.WASSALL,ESQUIRE -ID#77788 M CD KATHERINE E. KNOWLTON,ESQUIRE -ID#311713 4 C�� r .Z= =­1 JOHN ERIC KISHBAUGH, ESQUIRE -ID#33078 C:)_"�_T NICOLE B.LABLETTA, ESQUIRE -ID#202194 C) DAVID NEEREN, ESQUIRE -ID#204252 D 5>1 JORDAN DAVID,ESQUIRE -ID#311968 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Pleadings@udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS One Penn Square,Lancaster,PA 17602 CIVIL DIVISION Plaintiff CUMBERLAND County V. 4 Arthur Clark 1 220 Reno Avenue NO.1 / ?>-Djj0 C-- V11 New Cumberland,PA 17070 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY. Kindly enter the appearance of the following counsel: Mark J.Udren,Esquire;Stuart Winneg,Esquire;Lorraine Gazzara Doyle,Esquire; Sherri J.Braunstein,Esquire; Harry B.Reese,Esquire;Salvatore Carollo,Esquire; Elizabeth L.Wassall,Esquire;Katherine E Knowlton,Esquire;and John Eric Kishbaugh,Esquire;Nicole B. LaBletta,Esquire;David Neeren,Esquire;Jordan David,Esquire on behalf of the Plaintiff, in the above- captioned matter. UDREN LAW OFFICES,P.C. BY. IOHN ERIC PGSHaAWH,L94099 PA 10 33M SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson : _ _ }:#°Lj Sheriff E' 1 �;#E P�R0 f l-}0Hf} Afn �titrifP�}Cf��€i Jody S Smith s � 2 13 rfAY 29 PM Chief Deputy � 19 Richard W Stewart CUMBERLAti@ C UB I Y Solicitor 0 FF4E C F Tic;,KRJPn PENNSYLVANIA Fulton Bank, N.A. vs. Case Number Arthur Clark 2013-2110 SHERIFF'S RETURN OF SERVICE 05124/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Arthur Clark, 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 Served"at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070. Several attempts at service were made but deputies were unable to make contact with anyone at the address provided. Per the neighbors this is still a good address for the defendant. SHERIFF COST: $$5.63 SO ANSWERS, May 24, 2013 RONNR ANDERSON, SHERIFF {c}CountySulte Sheriff,7eleosolt,Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Fulton Bank,N.A. COURT OF COMMON PLEAS ., Plaintiff CIVIL DIVISION CUMBERLAND County 171 rrl rr,.._ v. Arthur Clark r- i =) NO. 13-2110 ,— Defendant(s) v o t. rc C) r,.. --I t`') MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure upon Defendant(s): ARTHUR CLARK, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND, PA 17070 A copy of the Return of Service is attached hereto as Exhibit"A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit"B". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: e ff, torneys for Plaintiff J: Eric Kishbaugh, Esquire PA ID 33078 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff ��ygtr ni LmntLrp1 Jody S Smith Chief Deputy , Richard W Stewart - Solicitor cccICE 1,)i,*Fr sl.iRc� Fulton Bank, N.A. Case Number vs. Arthur Clark 2013-2110 SHERIFF'S RETURN OF SERVICE 05/24/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Arthur Clark, 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 Served"at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070.Several attempts at service were made but deputies were unable to make contact with anyone at the address provided. Per the neighbors this is still a good address for the defendant. SHERIFF COST: $85.63 SO ANSWERS, May 24,2013 RONNY R ANDERSON, SHERIFF EXHIBIT A (c)CauntySuile Sheet,Tel:.osof Inc Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiff(s) Fulton Bank-Direct Referred vs Defendant(s) Arthur Clark AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I, Randy Sheppard II, do hereby swear and affirm that I made the following diligent search and inquiry on defendant,Arthur Clark: 1. On May 20, 2013, I conducted a Skip Trace, the results of which indicated the defendant's current residence is 220 Reno Avenue, New Cumberland, PA, 17070. 2. On May 20, 2013, I conducted an Internet search for the Death Records of the Defendant, the results of which indicated that the defendant is not deceased. 3. On May 20, 2013, I conducted an Internet search for the Voter Registration Records of the Defendant,the results of which indicated that the defendant is a registered voter at the address of 220 Reno Avenue, New Cumberland, PA, 17070. 4. On May 20, 2013, I conducted an Internet search for the Motor Vehicle Records of the Defendant,with no results obtained from the search. 5. On May 20, 2013, I conducted an Internet search of Facebook,Twitter, Yahoo!, Google and Bing with no results obtained from the search. 6. On May 20, 2013 at 6:48pm I placed a phone call to the defendant's neighbor, Dennis Bates (717-695-0i97), of 219 Reno Avenue, New Cuuberland, PA, 17070 to inquire about the defendant's last known address. There was no answer. 7. On May 20, 2013 at 6:49pm I placed a phone call to the defendant's neighbor, Brian Killer(717-774-13o3), of 218 Reno Avenue, New Cumberland, PA, 17070 to inquire about the defendant's last known address. There was no answer. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unworn falsification to authorities. May 20. 2013 /1.4144 Date Randy Sheppard II Skip Trace Manager De Novo Attorney Services, Inc. P.O. Box 20215 Baltimore, MD 21284 Our Job Serial Number: NOV-2013003444 Ref 12110529-1 EXHIBIT B UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Arthur Clark NO. 13-2110 Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A", the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: r`4 Attorneys for Plaintiff J Eric Kishbaugh, Esquire PA ID 33078 VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C. S . Sec 4904 relating to unsworn falsification to authorities . Date : 06 D) j UDREN LAW OFFICES, P .C. BY: At or eys for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Fulton Bank, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Arthur Clark NO. 13-2110 Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 5TH day of June, 2013. Udren Law Offices, P.C. Attorney for Plaintiff By: �. ,� ✓� Y J. Eric Kishbaugh, Esquire PA ID 33078 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP.No. Docket Number: 13-2110 NAME: ARTHUR CLARK MAILING ADDRESS: 220 RENO AVENUE NEW CUMBERLAND, PA 17070 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Fulton Bank,N.A. "� A Plaintiff c CO V. NO. 13-2110 i1-TI 10 A za� rthur Clarke, Defendant(s) ORDER '� r AND NOW, this /O' day of ��...� , 2013,upon consideration of Plaintiffs Motion aiitl the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Arthur Clark, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 220 RENO AVENUE NEW CUMBERLAND, PA 17070 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND, PA 17070 BY THE COURT: J. (26 4 . r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County Cn V. G 1 ARTHUR CLARK � NO. 13-2110 Defendant(s) y, Z- PRAECIPE TO REINSTATE COMPLAINT , TO THE PROTHONOTARY: w Kindly reinstate the Complaint on the above-captioned matter. DATE: C7�1 31-l3 UDREN LAW OFFICES, P.C. B Attorneys for Plaintiff I Eric Kishbaugh, Esquire PA ID 33078 aM� p Ck$ �93 2cl 10/08 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com Fulton Bank, N.A. = COURT OF COMMON PLEAS - c = CIVIL DIVISION ' Plaintiff € Cumberland County � PI V. Arthur Clark C:) NO. 13-21100 Defendant (s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter ay true and correct copy of the Complaint in Mortgage Foreclosure was mailed to Defendant (s) , by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED: 6/24/13 Arthur Clark 220 Reno Avenue New Cumberland, PA 17070 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 67 lo. 13 UDREN LAW OFFICES, P.C. BY: Valio Attokm,dy for Plaintiff I Eric Kishbaugh, Esquire PA ID 33078 t UDREN LAW OFFICES,P.C.ti ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 : Ieadin s @udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS rnCo' "in One Penn Square CIVIL DIVISION ' Lancaster,PA 17602 Cumberland County ; Plaintiff'a c3 V. MORTGAGE FORECLOSURE © t- ARTHUR CLARK 220 RENO AVENUE NO. 13-2110 NEW CUMBERLAND,PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s),ARTHUR CLARK; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises,and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $68,238.26 Interest Per Complaint $2,689.94 Additional Interest 04/09/2013 09/03/2013 $1,417.84 Late Charges Per Complaint $191.40 Additional Late Charges 04/09/2013 09/03/2013 $95.70 Escrow Per Complaint -- $1,213.05 Property Inspection Fees $50.00 Unapplied Balance $-606.26" Grand Total $73,289.93 I hereby certify that(1)the addresses of the Plaintiff and Defendant are as shown above, and(2)that notice has been given in accordance with Rule 237.1,a copy of which is attached hereto. UDRE OFFICES,P.C. AttgWX4 NR8[[O, ESQUIRE A Y 050 DAMAGES ARE,HVREBY ASSESSED AS INDICATED DATE: PRO MJU#: 12110529 CASE#: 12110529-1 �- a asap oJ-)q, M4�t UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY: MARK J.UDREN,ESQUIRE-ID#04302 STUART WINNEG,ESQUIRE-ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE-ID#90675 SALVATORE'CAROLLO,ESQUIRE-ID#311050 HARRY B.REESE,ESQUIRE-ID#310501 ^� ELIZABETH L.WASSALL,ESQUIRE-ID#77788 KATHERINE E.KNOWLTON,ESQUIRE-ID#311713 JOHN ERIC KISHBAUGH,ESQUIRE-ID#33078 NICOLE B.LABLETTA,ESQUIRE-ID#202194 rr> ° n DAVID NEEREN,ESQUIRE-ID#204252 � xp G,- JORDAN DAVID,ESQUIRE-ID#311968 zo � o� Cyrn WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 �� xD CHERRY HILL,NJ 08003-3620 856.669-5400 pleadings @udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS C/O Fulton Bank-Direct Referred CIVIL.DIVISION One Penn Square - CUMBERLAND County Lancaster,PA 17602 1i Plaintiff NO. V. ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND,PA 17070 Defendant(s) COMPLAINT IN 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 dFfenses 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff atr 01 Comb f1�d Jody S Smith co Chief Deputy .& i4- N , Richard W Stewart '�..-, .�= Solicitor GFFiGS OF THE SWERIFF Fulton Bank, N.A. vs. Case Number Arthur Clark 2013-2110 SHERIFF'S RETURN OF SERVICE 06/17/2013 07:27 PM-Deputy Tim Black, being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Arthur Clark,pursuant to Order of Court by"Posting"the premises located at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070 with a true and correct copy according to law. 71M&A ,DEPUTY SHERIFF COST;$53.67 SO ANSWERS, June 18,2013 kONW R ANDERSON,SHERIFF ic1 CmrOSLAO ShOMI.Teleowk It. UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Arthur Clark MORTGAGE FORECLOSURE Defendant(s) NO. 13-2110 TO: Arthur Clark 220 Reno Avenue New Cumberland,PA 17070 Date of Notice: July 16,2013 IlVIPORTANT 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 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO-LA ACCION REQUIRMA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ(10)DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPAR.ARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,HVIPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDRREN LAW OFFICES,PC. BY: 1177 t1-T n eCL is /O knorney for Plaintiff Nicole LaBlefla, Esquire woodcr `f 111 Wooderest oad, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12110529 CASE#: 12110529-1 Pennsylvania Office UDRENLA W OFFICES, r C Florida Office 100 W. 3rd Ave. 2101 W.Commercial Blvd Suite 200 New Jersey Office Suite 5100 Conshohocken,PA 19428 Woodcrest Corporate Center Fort Lauderdale,FL 33309 (PH) 215-568-9500 111 Woodcrest Rd (PH) 954-378-1757 M"r" Udren ., (FX) 954-378-1758 !r'censed.PA,N,fZ Suite 200 Cherry Hill 2 M 08003 ( )856-669-5400 (FX)856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle,PA 17013 Re: Fulton Bank,N.A. VS. ARTHUR CLARK, Cumberland County C.C.P.No. 13-2110 MJU#: 12110529 CASE#: 12110529-1 Dear Sir or Madam: Enclosed please find Affidavit of Non-Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non-Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincer yours, Ale r Forec osure Specialist MJU/ Enclosures MJU#: 12110529 CASE#: 12110529-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com COURT OF COMMON PLEAS Fulton Bank,N.A. CIVIL DIVISION Plaintiff Cumberland County V. MORTGAGE FORECLOSURE ARTHUR CLARK, Defendant(s) NO. 13-2110 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s),that the Defendant(s),ARTHUR CLARK,who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s)is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s)of birth and/or Social Security number(s) for said Defendant(s)to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: September 3,2013 ttomey for Plaintiff SALVATORE CAROLLO, ESQUIRE PA iD 311050 MJU#: 12110529 CASE#: 12110529-1 Department of Defense Manpower Data Center Results as of:Sep-03-2013 07:08:57 SCRA 3.0 k Status Report Pursuant to Serv%cemembers;Ctivfl Relief Act. Last Name: CLARK First Name: ARTHUR Middle Name: Active Duty Status As Of: Sep-03-2013 On Active Duty On Active Duty Status Date - Active Duty Start Date Active Duty End Date Status service Component NA NA ��yt 'S4_r+��^' Y gr} tJ�o,'�y NA c id s alive dy status basn Dty,Status Data response refletsjh-.IiAiW Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Dale .Active Duty End Date i Status .` Service Component # NA "•'`..:'�5:-: 1. P,.-�� No �rft,f��.i't. NA t 1 S +s..�� e i M This response reflects wt7htereihe Individual left active_duty�statuCs within 367rdays preceding theActWe'Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA This response reflects whether Me in d,vdual'orhisRer unit has_e_ r v ed ef ar n ptfico n t o report for active duty J , 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. 41 "" • Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 I I • 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 et 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:http://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: L4HAGD858050G70 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Arthur Clark MORTGAGE FORECLOSURE . -0 - Defendant(s) CD NO. 13-2110 r'ca ca = a PRAECIPE TO ISSUE WRIT OF EXECUTION C--, x� TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 73.289.93 Interest From 9/4/2013 $ 881.36 to Date of Sale December 4,2013 Ongoing Per Diem of$9.58 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN L OFFICES,P.C. Attorney for Plaintiff SALVATORE CAROLLO, ESQUIRE aJL3 PA lD 311050 MJU#: 12110529 CASE#: 12110529-1 65.(o3 CBF 53. j r03. �5 u Ito .50 " -*ago.So - P 0 a„y #a.aS 81AeGo 50 L-L t2� aq 5 aa°t UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS --� --� Plaintiff CIVIL DIVISION n rn V. Cumberland County r- Arthur Clark MORTGAGE FORECLOSURE Q .C,. Defendant(s) �= )T NO. 13-2110 ,,t CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: N Act 91 procedures have been fulfilled ❑ Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW FICES, P.C. BY• � Attorney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA 1D 311050 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER i-111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings(&,udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION --n '0 V. Cumberland County MM rn t— Arthur Clark Defendant(s) MORTGAGE FORECLOSURE NO. 13-2110 =CD C:) -C-- AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Fulton Bank,N.A.,Plaintiff in the above action,by its undersigned attorney,upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 220 Reno Avenue,New Cumberland,PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Arthur Clark 220 Reno Avenue New Cumberland, PA 17070 2.Name and address of Defendant(s)in the judgment: Arthur Clark 220 Reno Avenue New Cumberland, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4.Name and address of the last recorded holder of every mortgage of record: Fulton Bank,N.A. One Penn Square Lancaster, PA 17602 Sr Mortgage Holders-None Jr Mortgage Holders -None 5. Name and address of every other person who has any record.lien on the property: Sr lien Holders -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: Cumberland County Real Estate Tax Department I Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street t Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 220 Reno Avenue New Cumberland, PA 17070 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: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: 3• i3 UDREN LAW FICES, P.C. By At rney for Plaintiff SALVATORE CAROLLO, ESQUIRE MJU#: 12110529 CASE#: 12110529-1 PAM 311050 I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadinizs@udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS f-0 -'a Cn Plaintiff CIVIL DIVISION Mrr, rn r- V. Cumberland County ARTHUR CLARK MORTGAGE FORECLOSURE !zC5 Defendant(s) �'C7 =C CD C-- --4 C=) NO. 13-2110 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Arthur Clark 220 Reno Avenue New Cumberland, PA 17070 Your house(real estate) at 220 Reno Avenue,New Cumberland,PA 17070 is scheduled to be sold at the Sheriffs Sale on December 4,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013, to enforce the court judgment of$73,289.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed,the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on bow to obtain an attorney.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with,the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Fulton Bank,N.A. -a w -g Plaintiff = ,-r V. NO. 13-2110rx'- r Arthur Clark Defendant(s) =� cs ORDER AND NOW,this 164kday of �Lt�Q ,2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s),Arthur Clark,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 220 RENO AVENUE NEW CUMBERLAND,PA 17070 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND,PA 17070 BY THE COURT: (a J. P V WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2110 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FULTON BANK,N.A., Plaintiff(s) From ARTHUR CLARK (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: $73,289.93 L.L.: $30 Interest from 9/4/13 to Date of Sale 12/4/13 Ongoing per diem of$9.58 to actual date of sale including if sale is held at a later date-- $881.36 Atty's Comm: Due Prothy: $2.25 Atty Paid: $299.80 Other Costs: Plaintiff Paid: Date: 9/4/13 David D.Buell,Prothonota (Seal) By: Deputy REQUESTING PARTY: Name: SALVATORE CAROLLO,ESQUIRE Address: UDREN LAW OFFICES,PC WOODCREST CORPORATE CENTER I I I WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:Plaintiff Telephone: 856-669-5400 Supreme Court ID No.311050 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County ' C- ARTHUR CLARK, Defendant(s) MORTGAGE FORECLOSUREry NO. 13-2110 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff,by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached hereto as Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit'B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec.4904 relating to unsworn falsification to authorities. Dated: 10 -- UDREN LAW OFFICES, P.C. BY: p Attorney for Plaintiff Nicole LaBleftal Esquire PA ID 202194 MJU#: 12110529 CASE#: 12110529-1 `t R UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Fulton Bank,N.A. Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION Cumberland County ARTHUR CLARK; Defendant(s) MORTGAGE FORECLOSURE ]NO. 13-2110 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): ARTHUR CLARK; PROPERTY: 220 Reno Avenue,New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/04/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are . filed thereto within 10 days after the filing of the schedule. MJU#: 12110529 CASE#: 12110529-1 r;'��� , C/1 m CD CD' ti by Ci w � y 1 � < 7. O CT c w ] oYc� �oon�Wo ti G .r'O O< G O.0 G W V1 4 W . �v oil 0 tka coo 7y to �? r,.+ O. ��r p :j C o� C7 0 °w "� A+ fD CIO y `b ° C o nIt a Cl CD M N a ❑❑N❑ .1 CD w d CD K 8 Nod � d o O H ' vg ►�I '" o !'/I _ �� ❑❑ tl0 0 U, .y 0. S.PpSTAG °� � y�� o a E»pjrV EYSOVVES 5 g b a dywo� ZIP o ^. b E ` " c 02 X003 A y u c p �a 000138.7 00 " 5 o 090 uR� 20. ,� v� pCGyi �J R. CD H ".. ' wee f p aM Cn n ° cra a� �rnC�C• wm o� w w 0 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. CUMBERLAND County ARTHUR CLARK;- MORTGAGE FORECLOSURE Defendant(s) NO. 13-2110 VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: ARTHUR CLARK 220 RENO AVENUE, NEW CUMBERLAND,PA 17070. DATE MAILED: September 23,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: October ,2013 UDREN LAW OFFICES P.C. BY: ` M,U#: 12110529 CASE#: 12110529-1 19 4 b:y ra IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Fulton Bank,N.A. Plaintiff rn� =r" V.Arthur Clark N0. 13-2110 N rte. L Defendant(s) x c-) o� i;Ri OR—D E a AND NOW,this /6 kday of Juug, ,2013,upon consideration of Plaintiffs Motion an r d the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s),Arthur Clark,shall be complete when Plaintiff or its counsel or agent has served true and comeet copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 220 RENO AVENUE NEW CUMBERLAND,PA 17070 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND,PA 17070 BY THE COURT: J. 0 � Q x Cl) flf p OR C� Li I w w ---- w L Ln ru OON� C ON'p � Cp CD 00 0 1 O�W 0401 m N v O W � I Wo Gillijbit i _.194 If P. If 1 � � CD C r Io Iww g XL -J : A Ln p I� ': o. .o:o 11 oa. .: ao� Q y CroA H O fU A W N O 00 RIO n. N x ~ d � a oall > � fo o° A WNova y y ❑O= � rb �_ems A fnR0 n n Y� 0 Md M O �❑ s o U 2T o p py U.S.POj^TAGE1=PITNEY h "3u `49L Amon, BOWES ZIP 02 0 000100.3 $ 001-200 o /.3.67 Q�P .3 w IEV Ir � . ggv °ut 0 .Oct- 18. 2013 11 :41AM Cumberland County Sherrif No. 7807 P. 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Shetiff �odv of Jody S Smith 40 �ud�brPla�O Chief Deputy At . , e Richard W Stewart Solicitor WFIC 4F THfi SHERIFF Fulton Bank, N.A. vs. Case Number Arthur Clark 2013-2110 SHERIFF'S RETURN OF SERVICE 09/23/2013 08:40 PM-Deputy Stephen Sender,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 220 Reno Avenue, New Cumberland-Borough,New Cumberland, PA 17070,Cumberland County. 09/2312013 08:40 PM-Deputy Stephen Bender, being duly sworn according to law,served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant,to wit:Arthur Clark, pursuant to Order of Court by"Posting"the premises located at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070, Cumberland County with a true and correct copy according to law. SHERIFF COST:$974.42 SO ANSWERS, October 18, 2013 RONO R ANDERSON,SHERIFF �o� Q (C)CoLtMySuile S116M,7eleoeofl,Inc. e UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s('Oudren.com Fulton Bank,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. CUMBERLAND County ARTHUR CLARK, MORTGAGE FORECLOSURE Defendant(s) NO. 13-2110 VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: ARTHUR CLARK 220 RENO AVENUE, NEW CUMBERLAND, PA 17070 DATE MAILED: September 23,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: October ,2013 UDREN LAW OFFICES P.C. BY: ` Attorne r- laintiff---�- - _� MJU#: 12110529 CASE#: 12110529-1 Nicole .1 3sa� R + Pi 4 t7 zm ° M- -dr-:� ---; _-C)F..... C,r W -0 M ^C> O D C) C) D C o ra W a M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION C-) Fulton Bank,N.A. Plaintiff r"'Co r-- s_r :-�V. NO.NO. 13-2110 m. Arthur Clark X c� s 3>C, o Defendant(s) �w --q ° ORDER � AND NOW,this 164kday of r,, Ujoe_„ ,2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s),Arthur Clark,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 220 RENO AVENUE NEW CUMBERLAND,PA 17070 And by mailing by certified mail and regular mail to the last known address of Defendants 1� Defendant(s) as follows: ARTHUR CLARK 220 RENO AVENUE NEW CUMBERLAND,PA 17070 BY THE COURT: J. I� Q c (OF T i 1 � ZE J Q C cl MM scC0 ) D spa O y � - - om � N w Q C-)C� -j w i w ----- _ • _j L Ul ru P- :A4Si- 0,1--!E s. 0 0 o m v p N z j CO WM N o � m G1 O v) N ■ ■ Cna c 0 D 0 VD 01,5i93 m W ?wK Av Ow3 Z m g_g c �m �NCD � m � ° I tu (D _ c�a.�N {� < (EDP 3 5CL a o ° ° CL 0 CD g C ki j _0 co 3 „p a v m �( p • �O W o �� .PL CL i w � � p ' • ru 3 o 13 m o❑ ° { CL CD 1/ n•O U A W N O 00 J 01 cl� P W N O c9 C" C1" CD M a r�. c (D p' CA w N W CD 00 ~ R. A C a -� d CD co CD N 2 N � � a �O `t y ~ o `n z o p � a a a A a N ❑❑❑❑ CD CD CD a a y ~ � ❑❑. eD ITI C, CD C C CD .t CD m a 002 R c ❑ aq 0. d' S' �. o w_ a r ? U.S.POSTAGE���rtvEV ^a d; a BOWES =e^ o �0 F f.��`B,n �`' "err� CD. 5' c ° B ZIP 08003 02 1W .. ° $ 001.20° C � CD 00013$7` w 'm a s / Q06�EP, 23. 2013 w CD co x ��� R ( g ❑ cnD '9 ID cn R3" A ❑ onti o�•p m 8 m a��. � C7� o F w� 0 l� o �•n ° c�oS y'A b w.rn wB c� B e�'dg b o c w d 5.2 p o 0�_ X 5'0 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ? t1 Ct C '}J 'Ca t °'tx of CluriGep1.46,4 Jody S Smith Chief Deputy ' Zu 4 I Richard W Stewart CUMSLRL AND COUNT'Y' Solicitor OFFICE OF THE SHERIFF PENNS YLYANIA Fulton Bank, N.A. Case Number vs. 2013-2110 Arthur Clark SHERIFF'S RETURN OF SERVICE 09/23/2013 08:40 PM - Deputy Stephen Bender, 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 220 Reno Avenue, New Cumberland -Borough, New Cumberland, PA 17070, Cumberland County. 09/23/2013 08:40 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit:Arthur Clark, pursuant to Order of Court by"Posting"the premises located at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070, Cumberland County with a true and correct copy according to law. 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$1.00 to Attorney Mark Udren, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$. SHERIFF COST: $1,150.62 SO ANSWERS, January 17, 2014 RONNW ANDERSON, SHERIFF of-oo P�! • a-as P0/ , sa L� rol- 4 9g73s- 1 3o 6 CouiiySwte:Sheriff,T6..c,o`t:Irc. On September 6, 2013 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Known and numbered as, 220 Reno Avenue, New Cumberland, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: September 6, 2013 N Lu By: r_c to w c- w C.Aj . ■ CD Real Estate Coordinator • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-2110 Civil Term BEING KNOWN AND NUMBERED AS 220 Reno Avenue, New Cumber- FULTON BANK,N.A. land,PA 17070. BEING KNOWN AS: 220 Reno vs. Avenue,New Cumberland,PA 17070. ARTHUR CLARK PROPERTY D NO.: 25-25-0006- Atty.:Mark Udren 239. ALL THAT CERTAIN piece of par- TITLE TO SAD PREMISES IS cel of land situate in the Borough VESTED IN Arthur Clark by deed of New Cumberland, Cumberland from Terry W. Brubaker Sr. and County,Pennsylvania,more particu- Paula K. Brubaker„ husband and larly bounded and descried according wife dated 06/14/2010 recorded to a survey made by Gerrit J. Betz, 06/16/2010 in Deed Book Instru- R.S., dated 30 March, 1973, as fol- ment#201015779. lows,to wit: BEGINNING at a drill hole on the south sde of Reno Avenue (60 feet wide) at corner of lands now or late of Clarie Brookie, being House No. 222,sad pont being measured along the said side of Reno Avenue, fifty- nine(59)feet to the southeast corner of Reno Avenue and Taylor Avenue; thence extending from sad pont of beginning and along Reno Avenue, South fifty-one (51) degrees thirty (30) minutes East, the distance of eighteen and zero hundredths (18) feet to a drill hole at the corner of lands now or late of Derwin Salter, being House No. 216; thence along lands now or late of Derwin Salter, South thirty-eight(38)degrees thirty (30) minutes West, the distance of one hundred forty and zero hun- dredths(140.00)feet to a PK nail on the north side of Cherry Alley;thence along Cherry Alley,North fiftyone(51) degrees thirty (30) minutes West, the distance of eighteen and zero hundredths (18.00) feet to a hub at the corner of lands now or late of Clarie Brookie,North thirty-eight(38) degrees thirty(30)minutes East,the distance of one hundred forty and zero hundredths(140.00)feet to the point and place of BEGINNING. BEING 3 feet of Lot No.35 and 15 feet of Lot No. 36, Blqck B on the George W.Buttorff's Addition to New Cumberland and recorded in the Cumberland County Recorder's Office in Deed Book M,Volume 5,at Page 500. 35 • • 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. f L a Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 25 day 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. 4020 Technology Pkwy be patriotNews 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. 2e13s1fo Elva limn This ad ran on the date(s)shown below: RNZON BANK,N.A. 10/13/13 vs. • minim CLARK Z5-7.-, 10/20/13 M Mork Uth,n Z 7..� ALL ,THAT CERTAIN- PIECE OF / '% c r 10/27/13 PARCEL. OF LAND SITUATE IN THE BOROUGH OF / / 7 __ NEW . . . (/ 4�~ CUMBERLAND,: CUMBERLAND f+ COUNTY, PENNSYLVANIA, MORE!, PARPLCULARLY BOUNDED AND DESCRIED ACCORDING TO A SURVEY MADE BY GERRIT J.BET4 Sworn to and subscribed before this 11 day of November, 2013 A.D. RS, DATED 10 MARCH, 1973, AS I / I FOLLOWS,S TO AT A - ` ` I ,di&BEGINNING AT A DRILL HOLE ON ,� THE SOUTH SIDE OF RENO AVENUE C - �� � - - - _ (60 FEET-WIDE) AT CORNER OF o .ry'ublic LANDS NOW OR LATE SOF CLARIE( CO ONWEALTH OF PENNSYLVA ; BROORiI? BEING }LOUSE NO. 222, 1f t�lnt.�rial Seal SAID POINT BEING MEASURED ALONG THE SAID SIDE OF.RENO Holly Lynn Wed,d,Notary Public AVENUE, FIFTY-NINE (59) FEET TO Washington Twp.,Dauphin County THE SOUTHEAST CORNER OF RENO Fly Commission Expires Dec.12,2016 AVENUE AND TAYLOR AVENUE; MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES THENCE CE MIMING FROM SAID POINT OF BEGIMING AND ALONG RENO OWE, SOUTH FIFTY-ONE . . (51)DEGREES THIRTY (30) MINJfES EAS'T THE 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 Federal National Mortgage Association 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 4th day of September, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2110, at the suit of Fulton Bank, N.A. against Arthur Clark is duly recorded as Instrument Number 201401510. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a /`.D-" day of iL 1. , A.D. 02 D74 / , 1 / % r ,,,,; ,f, •ecorder of Deeds Recorder'r Deeds,Cumberland County,Ca fie,PA My Commission Expires the First Monday ofd n.2018