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Home My WebLink About13-2260 Supreme: Court-Hof Peiinsylvania , –� -� Lout = - Common Pleas t ' '� C� For Prothonotary Use 0n1r �(: vd.16 er, sheet. l} Cu�merlalnd'� °��" County- BO �` t V °: /� �,t 13 - 1 66 l.�iVl �1Errvl 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 of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR LAURIE A. HIGHAM C IN INTEREST TO NATIONAL CITY REAL ESTATE OWEN D. HIGHAM T SERVICES LLC SUCCESSOR BY MERGER TO I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJAppeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you 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 APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Employment dispute: ❑ Statutory Appeal: Other E mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑Employment Dispute: Other T ❑ Other: Q MASS TORT ❑Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non- Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order i ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHI LADELPHTA, PA 19106 (866) 413 -2311 wW W.KMLLA W GROi 1P.COM PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN THE COURT OF COMMON PLEAS IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO OF CUMBERLAND COUNTY NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION - LAW 3232 Newmark Drive Miamisburg, OH 45342 ACTION OF MORTGAGE FORECLOSURE Plaint vs. 1V i l ' exJ LAURIE A. HIGHAM No. OWEN D. HIGHAM Mortgagors and Record Owners 22 Courtland Road CIVIL ACTION: MORTGAGI Camp Hill, PA 17011 FORECLOSURE Defendants 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle PA 17013 m.z r pa - a cn -4 LEGAL SERVICES INC s =� 8 Irvine Row s CD Carlisle, PA 17013 717 - 243 -9400 -' 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 defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. S C � 73-51 q p 67ri 2 a8glp30 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 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. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hqp://www.phfa.org/consumers/homeowners/real.qMx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretention (2kmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 120547FC. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO., 3232 Newmark Drive, Miamisburg, OH 45342. 2. The names and addresses of the Defendants are LAURIE A. HIGHAM, 22 Courtland Road, Camp Hill, PA 17011 and OWEN D. HIGHAM, 22 Courtland Road, Camp Hill, PA 17011, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On December 06, 1993 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to SEARS MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on December 14, 1993 as Book 1185, Page 89. The mortgage has been assigned to: NATIONAL CITY MORTGAGE COMPANY by assignment of Mortgage recorded on January 31, 1995 as Book 490, Page 390. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June 01, 2012 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of 04/01/2013: Principal Balance ................................ ............................... .....................$60,762.26 Interest from 05/01/2012 to 04/01/2013 at 4.7500 % .......... ......................$2,645.72 Monthly interest $240.52 LateCharges ......................................... ............................... ........................$103.95 Escrow................................................... ............................... ........................$101.42 OtherFees .............................................. ............................... .........................$27.05 InspectionCosts ..................................... ............................... .........................$18.00 Appraisal............................................... ............................... ........... .............$175.00 $63,833.40 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such Notice attached and incorporated as Exhibit `B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $63,833.40, together with monthly interest of $240.52 and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: KML LAW GROUP, MC. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 drew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I, Bn= Tmwman , as a Authorized Signer , of PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: '�A -- \ PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION NAME: Sn=TMwman TITLE: Authorized Signer #120547FC - LAURIE A. HIGHAM and OWEN D. HIGHAM 22 Courtland Road Camp Hill, PA 17011 E�h i 6 i tA AU THAT CERTAIN trnct or pnrcel of land, aicunte In Lover Allen, Tovnahip, CucbcrlAnd County, r0000yivanin, ho.ntded and doseribed in nccardance vicai a aurvty aad plan thtrcaf, r do by D. r. Raffenspergef Asanefates, Eop.incsra a+yd Sx�rvelora, doted narewb" 21, 1573. na follows, to -snit. ONCIMUC at n point on tho Northerly line ci Caurciami llomt (50 f.cec vide) uhicsr point 1A $22 .57 feet in a veatorl.y dirretloo from the. rartlwts ttrly corotr of tilt incemeetiou of CutnLcrland end Courtlaad ttonds; illi,HCC alottC the northerly line of Courclnnd Road,in on art, harEnE ss ra.tlos of 180 fret to a e.terly diraetion 56,0 feet to n P.A.,; rin c£ Nvrth 10 desrpeo 26 uln.evs £ast 29.08 feet to a paiac; vowce Notch 06 4r 01 x.Inut*u Esut 126.40 feet to n point on the ronthem line of Lot No. 42 on the l:trainaltur rentlooed Plow of fauil 71WNCE alaog the douthtrn lint of Lots Noe. 42 41 south 18 derrtto 23 ;,fnaccs f.sse 101.07 foot to a poiot on the ves tiro line of tat No. 15F TIMUC;L 'Iang Co. vcatem 11— of fat No. 73 Sooth 22 dupttce 25 .rlautea Vt;nt 160 fist to n point on the nar;htrly line of C —cland rood, the plate of AWNRIN0. b nl= ;.art of fat Yo. A. Trott No. 3 on the rlon of Cut6crlaad rack, rctordcf in flan nook 6, pnCt 3. ' $f.IXr known as No. 22 Courtload P.oad. Ex �B *Exhibit has been redacted to remove allpersonally identifiable information or non-public information d'!% PNC Attention: Co3lection Department e _ • " MORTGAGE" (B6- Mw7 -01 -5) 3232 Newark Drive q11� 8682 5755 Miamisburg, OR 45342 7y 96 900 LAURIE A HIGHAM 22 COURTLM'D RD CAMP HILL, PA 17011 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: -0708 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA002 A Dnnsion of PNC Bank. Natty al Assoctabin T1 937 -910 -1200 T2 BC"22.5626 3232 Newmark Or Miamisburg OH 45342 P.O Bov 1820 Dayton OH 45001 -1820 Date: 2/15/2013 Re: Loan No.�708 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 22 COURTLAND RD, CAMP HILL, PA 17011, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $519.85 for the months of 61 112012 through 21 112013. Late charges and other charges have also accrued to this date in the amount of $80.42. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $4,759.07. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,759.07, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at PNC Mortgage /Collections Center, Mall Code B6- YM09 -01 -01, 3232 Newmark Drive, Miamisburg, 01145342. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt if we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorneys fees will be added to whatever you owe us, which may also include our reasonable costs. If you care the default within the thirty day period, you will not be required to pay attomey's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could beheld would be approximately nine - ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1 -800- 523 -8654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it If you continue to live in the property after the 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 DEIST, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHTTO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. a� 1 v> P1 C Attention collection Department MORTGAGE" (B67Y 7 -o1 -5) 3232 Nark Drive Miamisburg, OH 45342 AM MUM; 7196 9008 9111 8682 5748 SENDERS RECORD OTIN D HICHAM 22 COURTLAN) RD CAMP HILL, PA 17011 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: 0008320708 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA001 A Dnrsron of PNC Bank. National Assoc abon T1 937 - 910 -1200 T2 Bc0- 822 -5626 3232 Newmark or 41—burg OH 45342 P 0 Bo. 1820 Dayton OH 45401 - 1820 a Date: 2/15/2013 Re: Loan No. 0008320708 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 22 COURTLAND RD, CAMP HILL, PA 17011, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $519.85 for the months of 61112012 through 21112013. Late charges and other charges have also accrued to this date in the amount of $80.42. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $4,759.07. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,759.07, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at PNC Mortgage /Collections Center, Mail Code B6- YM09 -01 -01, 3232 Newmark Drive, Miamisburg, OH 45342. if you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attomey's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale /and perform any other requirements under the mortgage /. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately nine - ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. 1 -800- 523 -8654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property alter 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 THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHTTO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. 1f you cure the default', the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. L ' a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO Case No. 13 --c9a(D NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. r*1-- Plaintiff vs. �+� m> o LAURIE A. HIGHAM O WEN D. HIGHAM a Defendant(s) 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 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 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 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 IS FREE. Respeaf ill submitted: (Signature of Couns for Plaintiff) D to Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete -your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Ct.I.STON-IEIZ/PIZI.,NIAIZV.:APPLI CAN]' Borrower name(s): Property Address: City: - - State: Zip Is the property for sale? Yes No ❑ Listing date: _ _ _ Price: $ Realtor Name: RmItor Phone: Borrower Occupied? Yes No Mailing Address (if different): City: State :Zip: Phone Numbers: Home: O£i'ice: _ Cell: Other: Email: # of people in household: How long? Mailing Address; City: State: Zip: Phone plumbers: Home: Office: Cell: Other: Email: # of people in household: How long? ,.,FINANCIAL INFORMATION First. Mortgage Lender: Type of Loan: Loa Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes Q No El If yes, provide names, location of court, case number & attorney: Assets Aniount Owed: Value :_ Horne; $ $ Other Real Estate: $ $ - Retirement Funds; $ $ _ Investments: $ -- Checking: $ $ Savings: $ $ Other: $ $ Automobile #l: Model: Year: Amount owed: Value: Aptotnobile #2 : Model: Year:� Amou vt owed: Value: Other transportation (automobiles, boats, mgtorcyeles)- Model year Amount owed: Value - Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages); 1, monthly amount: 2. monthly amount: Borrower Pay Days: - - -- ---- ..__ -- Co- Borrower Pay Days: Monthly Expenses, (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortg Food _ 2' M2qSaL Utilities Carp ens Condo/Nei Fees t Auto Insurance Med. not covered Auto fuel /re irs Other pro . payment Install: Loan Pay ment Cable TV Child Su rt/Alirn. Spe nding Mone Da /Child Csre/Tuit. Other Ex uses Amount Available for Monthly ]Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes El No if yes, please provide the following information: Counseling Agency: Counselor: Plorte (Qllce }: Fax: . . Entail: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [j No E] 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? 'ices ❑ No If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (N Iame): - _ - Phone; Servicing Company (Name): Contact: Phone: we, authorize the above named to use /refer this information to nay lender /servieer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that I/we 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 V Past 2 bank statements Proof of any expected income for the last 45 days V Copy of a current utility hilt Y Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ICE Sheriff AF�r�E P,MTHONOTARY «� � � , -*� Jody SSmith 7.913 MAY —3 PM :2- 06 Chief Deputy Richard VVStewart -� CM' ----- COUNTY Solicitor O�'^Ev^THE c»smp~ PENNSYLVANIA | PNC Bank National Association Case Number | 2O13-2�8U Laurma�/� H�ham �t al.) | SHERIFF'S RETURN OF SERVICE 04/3O/3O13 08:01 PM-Deputy Shawn Gutshall, 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 Defendant, to wit: Owen D. Highomat22Coud|ond Road, Lower Allen Township, Camp Hill, PA 170 1. STO*4-61-ITS-HALL, DEPUTY 04/30/2013 08:01 PM- Deputy Shawn Gutshall, being duly sworn according to law, attempted service to the Defendant,to wit: Laurie A. Higham at 22 Courtland Road, Lower Allen Township, Camp Hill, PA 17011. The Defendant was found tobodeceased. --S�t�GUTSHALL, DEPUTY ' SHERIFF COST: $60.95 SO ANSWERS, May O1. 2D13 RDNNYR ANDERSON, SHERIFF � | fc,CountySuito Shedtf,Toleosoll,inc, KML Law Group, P.C. t r E ':i t 3i-101;k;,, By: Michael T. McKeever Attorney I.D. #56129 21113 JUL —3 3 AM 10 4,e. Suite 5000—BNY Independence Center r, 3AND COOP: 701 Market Street PCPdSYLVIA Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL IN THE COURT OF COMMON CITY REAL ESTATE SERVICES, LLC, PLEAS OF SUCCESSOR BY MERGER TO NATIONAL Cumberland COUNTY CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE LAURIE A. HIGHAM and OWEN D. HIGHAM Term Mortgagor(s) and Record Owner(s) No. 13-2260 22 Courtland Road Camp Hill, PA 17011 Defendant(s) SUGGESTION OF DEATH It is respectfully suggested that Defendant Laurie A. Higham is deceased, having departed this life on February 18th 2012. Accordingly, as Defendants owned the property which is the subject of this Action of Mortgage Foreclosure as husband and wife, by operation of law, title vests solely in Owen D. Higham. By: t, KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 30658 4lyk Oflazian Pa. ID 312912 Attorneys for Plaintiff . In the Court of Common Pleas of Cumberland County PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, ~ � LLC, SUCCESSOR BY MERGER TO NATIONAL CITY rp MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL No. 13-22PT c-- CITY MORTGAGE CO. :z r- 00 � )c~ 3232 Newmark Drive 3- � 4 'CD Miamisburg,OH 45342 , �� Plaintiff vs. = C)C-, OWEN D.HIGHAM X—. _ ? (Mortgagor(s)and Record Owner(s)) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT 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. Enter the Judgment in favor of Plaintiff and against OWEN D.HIGHAM by default for want of an Answer. Assess damages as follows: $64,554.96 Debt Interest from 8/1/2013 to Date of Sale per diem at$240.52 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.237.1 By: I % . .1 6&�� KML LAW GROU , .C. _Michael McKeever a 56129 _Jay E.Kivitz Pa.ID 26769 _Lisa Lee Pa.ID 78020 _Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 lJ► ^1 uy 3�[3 _Thomas Puleo Pa.ID 27615 I _Joshua I.Goldman Pa.205047 C� QC14 0.5 y _Jill P.Jenkins Pa.ID 306588 F _Andrew F.Gornall Pa.ID 92382 �e�,-,-e n�au�e Attorneys for Plaintf�` Caw'' AND NOW �[2 �l - ,Judgment is entered in favor of PNC BANK,NATIONAL ASSOCIATI , SUCCESSOR IN iNTERE7r TO NATIONAL CITY REAL ESTATE SERVICES, LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., Y KNOWN AS NATION CITY MORTGAGE CO. and against OWEN D.HIGHAM by default for want of Answer d a s assessed"sum of$64,554.96 as per the above certification. � '' � yrnq ProiMnotary Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg,OH 45342 Plaintiff No. 13-2260 vs. O WEN D.HIGHAM (Mortgagors and Record Owner(s)) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) 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. . NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith o;�ictp Lmry�,rr�,46 Chief Deprriy r Richard W Stewart Solicitor aFf,cc ck T)�e s!Pa r PNC Bank National Association vs. Case Number Laude A Higham(et al.) 2013-2260 SHERIFF'S RETURN OF SERVICE 04130/2013 08:01 PM-Deputy Shawn Gutshall,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 Defendant,to wit Owen D.Higham at 22 Courdand Road,Lower Allen Township,Camp Hill,PA 17011. S IJTSHALL, DEPUTY 04130/2013 08:01 PM-Deputy Shawn Gutshall,being duly sworn according to law,attempted service to the Defendant,to wit:Laurie A Higham at 22 Courtland Road, Lower Allen Township,Camp Hill,PA 17011. The Defendant was found to be deceased. ) i —tHGUTS H AL L,DEPUTY SHERIFF COST:$60.95 SO ANSWERS, May 01,2013 ONW RANDERSON, SHERIFF icy CcM,*Cwto S.wff,iel=osoll.i:c. 120547FC 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. DATE OF THIS NOTICE: July 8,2013 TO: OWEN D.HIGHAM 22 Courtland Road Camp Hill,PA 17011 In the Court of PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN Common Pleas INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, of Cumberland County LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY CIVIL ACTION-LAW MORTGAGE CO. 3232 Newmark Drive Action of Miamisburg,OH 45342 Plaintiff Mortgage Foreclosure vs. OWEN D.HIGHAM No. 13-2260 (Mortgagor(s)and Record Owner(s)) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) TO: OWEN D.HIGHAM 22 Courtland Road Carnp Hill,PA 1701 t 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 TBE 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,60 TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE You WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO ME A LAWYER,THIS OFFICE.MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LFGAT.SFRVICFS INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By:_ KML LA 'GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.11)78020 Kristina Murtha Pa.TD 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 ---!��Alyk L.Oflazian Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. NO. 13-2260 Plaintiff vs. OWEN D.HIGHAM Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (bttps://www.dmde.osd.mil/appj/scra/scraHome.do) for the following individual(s): OWEN D. HIGHAM, has a last known residence of 22 Courtland Road, Camp Hill,PA 17011. The following information was used to search the DMDC(check all that apply): X_Last Name X First Name _X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date O h By: e�dr KML LAW GROUP,P. . Michael McKeever Pa. 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 923 82 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff ��m.*��xm,� Deom�nlentOf Defense K8anpoxverData Cen��r vCn^ou Pursuant to Smicemembers Civil Relief Act Last Name: HIGHAM First Name: OWEN Middle Name: D. Active Duty Status/\aOf: On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date status Service Component NA NA N o NA This response reflects the mdi�iiduals�active du�sta�s basetion the AcGe Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Servi Component NA NA J NA This response reflects where ihe individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HistHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA No NA This response reflects whether the individual or histher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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 oo NOT UNIQUELY IDENTIFY AWINDIVIDUAL. Az 441ft Mary m.enavely-cixon.Director Department m Defense'Manpower Data Center ^oou Mark Center Drive,Suite n^sco Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization mthe Department m Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the offiu source of data on eligibility for military medical care and other eligibility systems. The moostronol�ovnponxmeonm�emontovmoserwoemom»v�uiw|nano/my(snuoo App.Bon1�=on.o°amended)(SoRx)V»vneny known on mesomiem'^noaai|om'ovi/Relief Act m1swo). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual io currently oo active duty"responses,and has experienced only u small error rate. m the event the individual referenced above,u,any family member,Mend,or representative asserts in any manner that the individual was on active duty for the active duty status date,o,io otherwise entitled mthe 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 ^oofenmumx.wx^unL:http:m*ww.uefe^ooxnx.mimun/pigpc000Lonmm|, n 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 ooVsc App.Wsx1(c). This response reflects the following information: (1)The individual's Active Duty status vn the Active Duty Status Date(2)Whether the individual left Active Duty status within nsrdays preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report foractive duty no 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 moo,o only some m the active duty periods less than oo consecutive oaynm|enumwemavaoa»le. 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(o for purposes of responding to a national emergency declared by the President and supported ur 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(npAu). 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 SCRAis Broader in Some Cases � o m�mooun o e,mo aom^/�u broader i nxomecameoanoiou/uueoumm^namoonovmpemvnunnamivouutym,purp0000nrmoSCm^wwuwmumnotuo | 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 m rely nn this wvoomy 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 m 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 w 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 un erroneous certificate uomeprovided. Certificate ID: Z8E0D95F000DP00 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 -Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY IN THE COURT OF COMMON PLEAS REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., of Cumberland County FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION LAW Miamisburg,OH 45342 Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE OWEN D.HIGHAM (Mortgagor(s)and Record owner(s)) No. 13-2260 22 Courtland Road Camp Hill,PA 17011 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,and against OWEN D.HIGHAM for failure to file an Answer in the above action within(20)days from the date of service of the Complaint, in the sum of$64,554.96. By: KML LAW GRff,—P.C. Michael McKee Pa.ID 56129 jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff 56itAirm f:7-1iloAdIco 1 hereby certify that the above Dames are correct and that the precise resiaenfladdress of the judgment creditor is PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.3232 Newmark Drive Miamisburg,OH 45342 and that the name(s)and last known address(es)of the Defendant(s)is/are OWEN D.HIGHAM,22 Courtland Road CampHill,PA 7011, By: KML-LAW GROUYI.C. Michael McKeever Pa.ID 56129 jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff I,fpkl 10 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $60,762.26 Monthly Interest from 05/01/2012 $3,367.28 through 07/01/2013 Late Charges $103.95 Escrow $101.42 Other Fees $27.05 Inspection Costs $18.00 Appraisal $175.00 $64,554.96 By: KML LAW GRO C. Michael McKeever a. ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff �j► AND NOW,this day of 2013 damages are assessed as Ike. AA 1 Pro Prothy 13-2260/120547FC PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY IN THE COURT OF COMMON PLEAS MERGER TO NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY of Cumberland County MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION—LAW Miamisburg,OH 45342 Plaintiff ACTION OF MORTGAGE FORECLOSURE., vs. " OWEN D.HIGHAM No. 13-2260 Fn Mortgagor(s)and Record Owner(s) 22 Courtland Road C ., Camp Hill,PA 17011 t— "=r C:) Defendant(s) C-) CDC, PRAECIPE FOR WRIT OF EXECUTION �� TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $64,554.96 Interest from 8/1/2013 to Date of Sale per Monthly diem at $240.52 (Costs to be added) D coo .�s C By: KML LAW GROt C. 1 b'j Michael McKeever 56129 t « < Jay E.Kivitz Pa.ID 26769 I ^I Lisa Lee Pa. ID 78020 Op ^�Q (/' Kristina Murtha Pa.ID 61858 11 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 AA Jill P.Jenkins Pa.ID 306588 ^ S >W W. Andrew F. Gornall Pa.ID 92382 a'a Attorneys for Plaintiff 7 CIL i I i i i I i i I I ,� . I i . i ,. f i { i f a i I� I. i .. ALL THAT CERTAIN TRACT OR PARCEL OF LAND, SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY AND PLAN THEREOF, MADE BY D.P. RAFFENSPERGER ASSOCIATES, ENGINEERS AND SURVEYORS, DATED NOVEMBER 21, 1973;AS FOLLOWS,TO WIT: BEGINNING AT A POINT ON THE NORTHERLY LINE OF COURTLAND ROAD(50 FEET WIDE)WHICH POINT IS 622.97 FEET IN A WESTERLY DIRECTION FROM THE NORTHWESTERLY CORNER OF THE INTERSECTION OF CUMBERLAND AND COURTLAND ROADS;THENCE ALONG THE NORTHERLY LINE OF COURTLAND ROAD IN AN ARC, HAVING A RADIUS OF 180 FEET IN A WESTERLY DIRECTION 54.0 FEET TO A POINT; THENCE NORTH 10 DEGREES 26 MINUTES EAST 29.08 FEET TO A POINT;THENCE NORTH 04 DEGREES 02 MINUTES EAST 126.90 FEET TO A POINT ON THE SOUTHERN LINE OF LOT NO.92 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE ALONG THE SOUTHERN LINE OF LOTS NOS.92 AND 93 SOUTH 78 DEGREES 23 MINUTES EAST 101.07 FEET TO A POINT ON THE WESTERN LINE OF LOT NO. 75;THENCE ALONG THE WESTERN LINE OF LOT NO.75 SOUTH 22 DEGREES 25 MINUTES WEST 160 FEET TO A POINT ON THE NORTHERLY LINE OF COURTLAND ROAD,THE PLACE OF BEGINNING. BEING PART OF LOT NO. 76,TRACT NO.3 ON THE PLAN OF CUMBERLAND PARK, RECORDED IN PLAN BOOK 6, PAGE 3. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY LOWER ALLEN TOWNSHIP BEING PREMISES: 22 Courtland Road,Camp Hill PA 17011 SOLD as the property of OWEN D. HIGHAM TAX PARCEL# 13-23-0557-031 BEING the same premises which SUSAN A. NELSON, SINGLE WOMAN by deed dated 5/10/1990 and recorded 5/16/1990 in Cumberland County in Deed Book Volume 0-34 at Page 363 granted and conveyed unto OWEN D. HIGHAM AND LAURIE A. HIGHAM, HIS WIFE and the said LAURIE A. HIGHAM departed this life on 2/18/2012, vesting title solely in OWEN D. HIGHAM KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106r 215-627-1322 r, Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, � �T� COUb T SUCCESSOR IN INTEREST TO NATIONAL CITY E;�) THE COURT OF COMMON PLEAS REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., of Cumberland County FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION-LAW Miamisburg, OH 45342 Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE OWEN D.HIGHAM (Mortgagor(s)and Record Owner(s)) 22 Courtland Road No. 13-2260 Camp Hill,PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,Plaintiff in the above action,by counsel,KML Law Group,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: 22 Courtland Road Camp Hill,PA 17011 LName and address of Owner(s)or Reputed Owner(s): OWEN D.HIGHAM 22 Courtland Road Camp Hill,PA 17011 2.Name and address of Defendant(s)in the judgment: OWEN D.HIGHAM 22 Courtland Road Camp Hill,PA 17011 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PNC BANK,NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG,OH 45342 PNC BANK,NATIONAL ASSOCIATION C/O LOIS M.VITTI,ESQ/VITTI AND VITTI AND ASSOCIATES PC 215 FOURTH AVENUE PITTSBURGH,PA 15222 r DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL,PA 17011 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O.Box 8486,Willow Oak Building Harrisburg,PA 17105-8486 COMMONWEALTH OF PENNSYLVANIA-DEPARTMENT OF REVENUE,INHERITANCE TAX DIVISION 1131 STRAWBERRY SQUARE 6TH FLOOR HARRISBURG,PA 17128 INTERNAL REVENUE SERVICE-SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH,PA 15222 TENANTS/OCCUPANTS 22 Courtland Road Camp Hill,PA 17011 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. Section 4904 relating to unswom falsification to authorities. DATED: . By: 104L LAW GROUP,P.0 _Michael McKeever Pa.ID 29 _Jay E.Kivitz Pa.ID 26769 _Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 _Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 _Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff 3I3-47 P 13-2260 KML Law Group,P.C. Suite 5000-BNY Independence Center ' 701 Market Street ; �� Philadelphia,PA 19106 @03 A UG _ � . (215)627-1322 2 Attorney for Plaintiff 1e E PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY IN THE COURT OF COMMON PLEAS REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE of Cumberland County INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION-LAW Miamisburg, OH 45342 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. OWEN D.HIGHAM Mortgagor(s) and Record Owner(s) Docket No. 13-2260 22 Courtland Road Camp Hill,PA 17011 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HIGHAM,OWEN D. OWEN D. HIGHAM 22 Courtland Road Camp Hill,PA 17011 Your house at 22 Courtland Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$64,554.96 obtained by PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-2260 1. The sale will be cancelled if you pay to PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. 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 below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty(30)days from the date of the Sheriffs 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 the schedule of distribution is Sled. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www. hin iladelphiafed.org/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-2260 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender)at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkkmllawgroo.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 120547FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group,P.C. p r `r 4-i_'_U t Suite 5000—BNY Independence Center 7��:- �, 701 Market Street ' ` -'F?0TH%160 dr 3 Philadelphia,PA 19106 ? 215-627-1322 6 A r 11: 2 Attorney for Plaintiff F't 1F PENN 3 Yt_VA��l��r PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO IN THE COURT OF NATIONAL CITY MORTGAGE INC.,FORMERLY COMMON PLEAS KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive of Cumberland County Miamisburg,OH 45342 Plaintiff CIVIL ACTION-LAW VS. ACTION OF OWEN D.HIGHAM MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) NO. 13-2260 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By. 4 KML LAW GROUP, Michael McKeever Pa. 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff I)O X Sac,wtt. rG nV�Lj r / WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 1.3-2260 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.Plaintiff(s) From OWEN D.HIGHAM (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: $64,554.96 L.L.: $.50 Interest FROM 8/1/2013 TO DATE OF SALE PER MONTHLY DIEM AT$240.52 Atty's Comm: Due Prothy: $2.25 Atty Paid: $209.70 Other Costs: Plaintiff Paid: Date: 8/6/13 David D.Buell,Prothonot (Seal) Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone:215-627-1322 Supreme Court ID.No. 313897 KML LAW GROUP,P.C. 120547FC Suite 5000 CF: 04/25/2013 BNY Mellon Independence Center n t ! SD: 12/04/2013 701 Market Street �, t; + tir,`, $64,554.96 Philadelphia,PA 19106-1532 `.r a ( � 215-627-1322 Attorrigy for Plaintiff " ' : r - t '; , PNC BANK,NATIONAL ASSOCIATION, P E N N S LVA N 1 HE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, of Cumberland County SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN CIVIL ACTION—LAW AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive ACTION OF MORTGAGE FORECLOSURE Miamisburg,OH 45342 Plaintiff Term vs. No. 13-2260 OWEN D. HIGHAM Mortgagor(s)and Record Owner(s) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c)f2} Veronica Cosme,an employee of KML Law Group,P.C.,counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult(copy of return attached). { } Certified mail by KML Law Group,P.C.(original green Postal return receipt attached). ( } Certified mail by Sheriffs Office. { } Ordinary mail by KML Law Group,P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( } Ordinary mail by Sheriffs Office to Attorney for Defendants)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. { } Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail &ordinary mail by Sheriffs Office(copy of return attached). { } Certified Mail&ordinary mail by KML Law Group,P.C.{original receipt(s)for Certified Mail attached). { ) Published in accordance with court order(copy of publication attached). Pursuant to the Affidavit under Rule 3129(copy attached), service on all lienholders(if any)has been made by ordinary mail KML Law Group,P.C.(copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 1$ Pa. C.S.A. Section 4904. Respectfully submitted, ir/-�Veronica Cosine Legal Assistant i U fAVr t Ln U. C1., Q 1 INn c>cr ac c o c w E U ,, ! Z ¢ I w Z a' w {A?I N st w a Q LL r 3: Ch a c w> m 0 °-j N to W tt3 1° ;gds m� ZQQ F•-O a�f.' > U °.- to tar o Zda ZU� UJZZ 0 w T U�¢ i , °' ¢N ww �w0 wa �oC) O'Sa ao$`oo ao Tom' a, ;E cr-cv :E O� -1 watt _ C=J a ¢ �¢a La w -�wirj Q o Q. c of w T �a rz E Z)ccoo¢ waits Ow HQ QZ)r w�Uy CL v a (n c+>U D W a U U!— to S Z r- (n a F- L) c CD E a 2 c D O WS 4 Gl Z w at O t Z z> Q �. n O L7 m WNV) L) U 2 0 p C Dom❑❑ con a -r ° U fts O m e to m 4> J w v (1 (/7 4 q _ rn cats Z ar d� W 0 p pp �t3 CL o p I z OoT - w ~ F— C N w H F-Y0 �Q%" ZCO `y zQt'S >co2: w w ° 0 Q � C14 E 8 Y S�� _�w N U 0 U? a ? Q FZ x <� Z cn c m o ` Q - ca O a 3 CL z d ZN{C y OU) 000 a N . ca D- UQN raUa amT CL 0 {� . U E ° ° z' m` E o� `4 aci W z E 6 of a � try m (�< r. _ 0 W CL c,4 c W C)W W tC) a cu Z N m ¢[]'r j.Aw UO lC) Il� o p Z Q S p r=i:V- � r N cli d cti cfl h oD 6CQ2-d.— SHERIFF'S OFFICE OF CUMBERLAND COUNTY {� ; Ronny R Anderson Sheriff Jody S Smith cots'14,at clut1brrt��r� Chief Deputy , Richard W Stewart '_`*°° .` Solicitor OFFICE VF TK SHERIFF PNC Bank National Association VS. Case Number Laurie A. Higham-Deceased(et al.) 2013-2260 SHERIFF'S RETURN OF SERVICE 09/27/2013 03:25 PM -Deputy Jamie DiMartle, being duly swom 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 22 Courtland Road, Lower Allen-Township, Camp Hill, PA 17011, Cumberland County. 10/21/2013 03:42 PM-Deputy Ronald Hoover, 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 Britney Higham,who accepted as"Adult Person in Charge"for Owen D. Higham at 22 Courtland Road, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, Owen D.Higham is currently in Dauphin County Prison. SHERIFF COST: $988.11 SO ANSWERS, October 24, 2013 RbNIV R ANDERSON, SHERIFF ic}Coun?y5uite SteriEt.Tceasoft,Inc. KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, IN TI4E COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR of Cumberland County BY MERGER TO NATIONAL CITY MORTGAGE INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION-LAW 3232 Newmark Drive Miamisburg,OH 45342 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term No. 13-2260 OWEN D.HIGHAM Mortgagor(s)and Record Owner(s) 22 Courtland Road Camp Hill,PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,Plaintiff in the above action,by and through an authorized employee of its attorneys, KML Law Group, 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: 22 Courtland Road Camp Hill,PA 17011 1.Name and address of Owner(s)or Reputed Owner(s): OWEN D. HIGHAM 22 Courtland Road Camp Hill,PA 17011 2.Name and address of Defendant(s) in the judgment: OWEN D. HIGHAM 22 Courtland Road Camp Hill, PA 17011 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 PNC BANK,NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG,OH 45342 PNC BANK,NATIONAL ASSOCIATION C/O LOIS M.VITTI,ESQ/VITTI AND VITTI AND ASSOCIATES PC 215 FOURTH AVENUE PITTSBURGH,PA 15222 4.Name and address of the last recorded holder of every mortgage of record: SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL,PA 1701.1 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 22 Courtland Road Camp Hill,PA 17011 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486,Willow Oak Building Harrisburg, PA 17105-8486 COMMONWEALTH OF PENNSYLVANIA-DEPARTMENT OF REVENUE, INHERITANCE TAX DIVISION 1131 STRAWBERRY SQUARE 6TH FLOOR HARRISBURG,PA 17128 INTERNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH,PA 15222 1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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: November 12, 2013 Kfff, aw Group,P.C. BY: Veronica Cosine Legal Assistant PNC BANK, NATIONAL ASSOCIATION ▪ IN THE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO ▪ CUMBERLAND COUNTY, NATIONAL CITY REAL ESTATE ▪ PENNSYLVANIA c SERVICES, LLC,SUCCESSOR BY - 3 MERGER TO NATIONAL CITY 0 t" MORTGAGE INC., FORMERLY KNOWN • cnr' ry AS NATIONAL CITY MORTGAGE, ▪ NO. 13-2260 PLAINTIFF rx =a VS. • { -< f • • OWEN D. HIGHAM, DEFENDANT ▪ CIVIL ACTION - FORECLOSURE MOTION TO STRIKE PLAINTIFF'S EXCEPTIONS TO SHERIFF'S PROPOSED SCHEDULE OF DISTRIBUTION 1. Petitioner Susquehanna Valley Federal Credit Union was the successful bidder at the December 4, 2013 Sheriff's Sale and is the holder of a second mortgage recorded against the Defendant for the premises. 2. PNC Bank's Exceptions seek to double count expenses,which are part of the amount to be paid to it in the Sheriff's "Proposed Schedule of Distribution". 3. PNC Bank's Exceptions seek$4,663.30 above the"Assessment of Damages" it filed on April 6, 2013,which included interest up through July 1, 2013. 4. On December 30,2013 the Office of the Sheriff for Cumberland County filed a"Proposed Schedule of Distribution"that provided for the payment to PNC Bank of$65,726.74 allocated as follows: Amount Due on Judgment $64,554.96* Interest $ 962.08 (7/1/13-12/4/13) Attorney Paid $ 209.70 $65,726.74 * This figure comes from the"Assessment of Damages" filed by PNC Bank's attorney on April 6, 2013. 5. The Sheriffs"Proposed Schedule of Distribution"was based upon the "Assessment of Damages" filed by PNC Bank on April 6,2013 that sought $64,554.96 as follows: Principal $60,762.26 Interest $ 3,367.28 (5/1/12-7/1/13)(14 months at$240.52) Late Charge $ 103.95 Escrow $ 101.42 Fees $ 27.05 Inspection $ 18.00 Appraisal $ 175.00 Total $64,554.96 6. PNC Bank now claims$2,963.48 in"escrow advances"when the "Assessment of Damages" filed April 6, 2013 shows$101.42 in escrow advances. Strict proof is demanded to show that$2,963.48 was paid towards escrow items recoverable under the mortgage between April 1,2013 and January 8,2014. 7. The Sheriffs "Proposed Schedule of Distribution" (because it was based upon the"Assessment of Damages") already included a late charge of$103.75 yet this same change appears on the Exceptions.PNC Bank's Exceptions are inflated by$103.95 in late fees. 8. The Sheriffs "Proposed Schedule of Distribution"already included $240.52 in monthly interest for the period 7/1/13-12/4/13 as well as the $3,367.28 in interest due from 5/1/12-7/1/13 on the"Assessment of Damages" filed April 6, 2013 for a total of$4,329.36 yet the Exceptions seek$4,593.60 in total interest.PNC Bank's Exceptions are inflated by$264.24 in interest. 9. PNC Bank tacks on $1,849.70 in something labeled "Recoverable Balance" but fails to provide any information regarding this alleged amount. Strict proof is demanded to show what this$1,849.70 represents. 10. An examination of the Disbursement Sheet by the Sheriff shows that a separate line item of$1,500.00 is being paid to "Atty Michael McKeever" who is with the KML Law Group (PNC Bank's attorney in this matter) so the$1,894.70 in"recoverable balance" is not legal fees. Respectfully submitted, BY: �i/� Ste -n Ho - 1, mss.-ire owell L. Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Petitioner CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the persons and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. David Fein, Esquire (Via Fax 215-825-6467 and US Mail) KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 Office of the Sheriff(Attn: Claudia) (Via Fax 240-6397 and US Mail) Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 —Art BY: St- en Howell, 'squire Date: January 24, 2014 L'i t PNC BANK, NATIONAL ASSOCIATION IN THE COURT OF COMMON2LEM_ _:. SUCCESSOR IN INTEREST TO CUMBERLAND COUNTY, -o r .a'�- NATIONAL CITY REAL ESTATE PENNSYLVANIA xW "` rr' SERVICES, LLC,SUCCESSOR BY �A MERGER TO NATIONAL CITY r `" ' MORTGAGE INC., FORMERLY KNOWN T>r) = .-__ AS NATIONAL CITY MORTGAGE, NO. 13-2260 n w c.) PLAINTIFF ....4 —< 4s, • VS. .• • OWEN D. HIGHAM, . DEFENDANT CIVIL ACTION - FORECLOSURE RULE TO SHOW CAUSE AND NOW,this 3 7‘ day of January 2014 a Rule is issued upon PNC Bank to show cause,if any it might have,why its Exceptions to the Sheriffs Proposed Schedule of Distribution should not be dismissed. Rule returnable within Zd days of service by 1st class,postage prepaid U.S. Mail upon PNC Bank's counsel of record in this matter. By the Court: A d'L Judge Certified Copies To: Steven Howell, Esquire (Attorney for Petitioner Susquehanna Valley Federal C.U.) Howell Law Firm 619 Bridge Street New Cumberland,PA 17070 David Fein, Esquire (Attorney for PNC Bank) KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 0-opl'es' 1,111.gc6, I I i9Ar _../-v 02/18/2014 14:51 7177701278 HOWELL LAW FIRM PAGE 03/04 PNC BANK, NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO CUMBERLAND COUNTY, NATIONAL CITY REAL ESTATE PENNSYLVANIA SERVICES, LLC, SUCCESSOR BY "� p .-.7C_ r..': MERGER TO NATIONAL CITY z �' MORTGAGE INC., FORMERLY KNOWN c`�nr` '�-L AS NATIONAL CITY MORTGAGE, NO. 13-2260 PLAINTIFF y r r VS. z r-1. OWEN D. HIGHAM, DEFENDANT CIVIL ACTION - FORECLOSURE JOINT STIPULATION 1. Susquehanna Valley Federal Credit Union is represented by Steven Howell, Esquire. 2. PNC Bank is represented by Jill P. Jenkins, Esquire 3. The parties are the second and first lienholders (respectively) for a property that was purchased by Susquehanna Valley Federal Credit Union ( SVFCU) at the Sheriff's Sale on December 4, 2013. 4. PNC Bank filed exceptions to the Sheriff's proposed distribution list and SVFCU file a motion to strike the exceptions. 5. Both parties have reached an agreement and stipulate to the following calculation to be used by the Sheriff of Cumberland County. Principal $60,726.26 (from Assessment of Damages on 4/6/13) Interest $ 3,367.28 (5/1/12 - 7/1/13 from Assessment of Damages) Interest $ 240.52 (7/1/13- 12/4/14) Late Charge $ 103.95 (from Assessment of Damages) Escrow $ 101.42 (from Assessment of Damages) Escrow $ 1,325.70 (school taxes paid by PNC) Escrow $ 729.33(city /county taxes paid by PNC) Fees $ 27.05 (from Assessment of Damages) Inspection $ 18.00 (from Assessment of Damages) Appraisal $ 175.00 (from Assessment of Damages) Legal Fees $ 1.850.00 TOTAL $68,664.51 02/18/2014 14:51 7177701278 HOWELL LAW FIRM PAGE 84/04 6. The parties request that the Sheriffs Proposed Schedule of Distribution be modified from the sum of $65,726.24 owed to PNC Bank to $68,664.51. 7. The parties request that the Sheriff proceed with the distribution of the sales proceeds and recording of the deed at his earliest opportunity. The parties execute this Stipulation to resolve the pending Rule to Show Cause. Respectfully submitted, BY: BY: S en Howe! squire owell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for SVFCU Jill jJenk ns, squire KML Law Group P.C. Suite 5000 701 Market Street Philadelphia, PA 19106 (215) 825-6360 Supreme Court ID 306588 Attorney for PNC Rank PNC BANK, NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO CUMBERLAND COUNTY, NATIONAL CITY REAL ESTATE PENNSYLVANIA SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE, NO. 13-2260 PLAINTIFF VS. OWEN D. HIGHAM, DEFENDANT CIVIL ACTION - FORECLOSURE ORDER OF COURT AND NOW, this a' day of March 2014 the Sheriffs Proposed Schedule of Distribution shall be modified in accordance with the terms of the parties' Stipulation. The terms of the Stipulation are adopted as an Order of Court in this matter. Certified Copies To: By the Court: Howell, Esquire (Attorney for Petitioner Susquehanna Valley Federal C.U.) Howell Law Firm 3: = 619 Bridge Street c New Cumberland, PA 17070 u) r-- — --0> N.) = C) CD- > ...,4* P. Jenkins, Esquire (Attorney for PNC Bank) KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 Office of the Sheriff (Attn: Claudia) Pza Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF ME .FEEE1f = t , oi(7� ?;. r • � S 44, i l7 ,,P 10 Cikl3ERLAND COT :I P PENNSY LV „ IA PNC Bank National Association vs. Laurie A. Higham - Deceased (et al.) Case Number 2013 -2260 SHERIFF'S RETURN OF SERVICE 09/27/2013 03:25 PM - Deputy Jamie DiMartle, 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 22 Court land Road, Lower Allen - Township, Camp Hill, PA 17011, Cumberland County. 10/21/2013 03:42 PM - Deputy Ronald Hoover, 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 Britney Higham , who accepted as "Adult Person in Charge" for Owen D. Higham at 22 Court land Road, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, Owen D. Higham is currently in Dauphin County Prison. 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 $80,000.00 to Attorney Steven Howell, on behalf of Susquehanna Valley Federal Credit Union, being the buyer in this execution, paid to the Sheriff the sum of $ 12/30/2013 Proposed Schedule Of Distribution Posted, all parties notified. 01/09/2014 Exceptions to Proposed Schedule of Distribution filed in Sheriff's Office. 03/14/2014 Amended Distribution Schedule Posted 3/14/14. cab SHERIFF COST: $3,063.98 SO ANSWERS, March 26, 2014 RONFJY R ANDERSON, SHERIFF (c) CountySu:ie S:`7eriff, Tel &osaft, adk as- ,d. >. (44 9x3-7, 3,#3,3 Amended PROPOSED SCHEDULE OF DISTRIBUTION Date Filed: December 30, 2013 Writ No. 2013 -2260 Civil Term PNC Bank, National Association, Successor in Interest to National City Real Estate Services, LLC, Successor by Merger to National City Mortgage Inc., Formerly Known as National City Mortgage Co. Vs Owen D. Higham 22 Courtland Road Camp Hill, PA 17011 Sale Date: December 4, 2013 Buyer: Susquehanna Valley FCU Total Due Per Order of Court: $ 68,664.51 DISTRIBUTION: Receipts: Cash on Account (08/08/2013): $ 1,500.00 Cash on Account (12/04/2013): 15,000.00 Cash on Account (12/12/2013) 69,908.50 Total Receipts: $ 86,408.50 Disbursements: Sheriffs Costs 2,713.98 Legal Search 350.00 Transfer Tax (Local) 1,479.25 Transfer Tax (State) 1,479.25 Lower Allen Township Supervisors 841.23 Atty Michael McKeever 1,500.00 PNC Bank, National Association, Successor in Interest to National City Real Estate Services, LLC, Successor by Merger to National City Mortgage Inc., Formerly Known as National City Mortgage Co. (2013 -2260 Civil Term) 68,664.51 Susquehanna Valley Federal Credit Union 9,380.28 (2013 -1733 Civil Term) Total Disbursements: ($86,408.50) Balance for distribution: 00.00 So Answers: onny R. Anderson Sheriff On August 8, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Flown and numbered as, 22 Courtland Road, Camp Hill, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 8, 2013 By: Real Estate Coordinator LS :b V 8- Sny 1101 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013 -2260 Civil Terse PNC BANK NATIONAL ASSOCIATION vs. Owen D. Higham Atty.: Michael McKeever ALL THAT CERTAIN tract or parcel of land, situate in Lower Al- len Township, Cumberland County, Pennsylvania, bounded and de- scribed in accordance with a survey and plan thereof, made by D.P. Raffensperger Associates, Engineers and Surveyors, dated November 21, 1973, as follows, to wit: BEGINNING at a point on the northerly line of Courtland Road (50 feet wide) which point is 622.97 feet in a westerly direction from the northwesterly corner of the intersec- tion of Cumberland and Court land Roads; thence along the northerly line of Courtland Road in an arc, hav- ing a radius of 180 feet in a westerly direction 54.0 feet to a point; thence North 10 degrees 26 minutes East 29.08 feet to a point; thence North 04 degrees 02 minutes East 126.90 feet to a point on the southern line of Lot No. 92 on the hereinafter mentioned Plan of Lots; thence along the south- ern line of Lots Nos. 92 and 93 South 78 degrees 23 minutes East 101.07 feet to a point on the western line of Lot No. 75; thence along the western line of Lot No. 75 South 22 degrees 25 minutes West 160 feet to a point on the northerly line of Courtland Road, the place of BEGINNING. BEING part of Lot No. 76, Tract No.3 on the plan of Cumberland Park, recorded in Plan Book 6, Page 3. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY LOWER ALLEN TOWNSHIP. BEING PREMISES: 22 Courtland Road, Camp Hill PA 17011. 63 SOLD as the property of OWEN D. HIGHAM. TAX PARCEL # 13 -23- 0557 -031. BEING the same premises which SUSAN A. NELSON, SINGLE WOMAN by deed dated 5/10/1990 and re- corded 5/16/1990 in Cumberland County in Deed Book Volume 0 -34 at Page 363 granted and conveyed unto OWEN D. HIGHAM AND LAURIE A. HIGHAM, HIS WIFE and the said LAURIE A. HIGHAM departed this life on 2/18/2012, vesting title solely in OWEN D. HIGHAM. 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. SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot- News Co. 2020 Technology Pkwy Suite'300 Mechanicsburg, PA 17050 Inquiries - 717 -255 -8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 tve PatriotXews Now you know 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. _PI.LRI icwT..,..... -�__ -- 2013 -2260 Civil Term PNC BANK NATIONAL ASSOCIATION vs. Owen D. Hlgham Atty: Michael McKeever ALL THAT CERTAIN TRACT OR ARCEL OF LAND, SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND It DESCRIBED IN ACCORDANCE WITH 1 A SURVEY AND PLAN THEREOF, i MADE 13Y D.P. RAFFENSPERGER i ASSOCIATES, ENGINEERS AND i SURVEYORS, DATED NOVEMBER 21, , 1973, AS FOLLOWS, TO WIT. BEGINNING AT A POINT ON THE NORTHERLY LINE OF COURTLAND ROAD (50 FEET WIDE) WHICH POINT N IS 622.97 rEET DIRECTION FROM THE NORTHWESTERLY CORNER OF THE INTERSECTION OF CUMBERLAND AND COURTLAND ROADS; THENCE ALONG THE NORTHERLY LINE OF :. --. )e‘hn, IN _AN ARC, ,.. This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 Sworn to and subscribed before me this 11 day of November, 2013 A.D. ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp,, Dauphin County My 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 Susquehanna Valley Federal Credit Union 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 6th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2260, at the suit of PNC Bank, NA against Owen D. Higham is duly recorded as Instrument Number 201407355. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /Art` 1 , A.D. a©i ( -f-') day of (A.) .1A , 0-), @V Recorder of Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018