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Home My WebLink About13-2557 Supreme Court =oPennsylvania t,.u. . ' For. Prothonotary Use Only: Cou> 0 :Comm. 'ORT... C1vil''OVRr :S.tlt et Docket No: CUMBERLIl ` C011IIty The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required bylaw or rules of court. =" Commencement of Action: Complaint Q Writ of Summons Petition s- Transfer from Another Jurisdiction Declaration of Taking Lead Plaintiffs Name: 1J. S. BANK NATIONAL Lead Defendant', s Name: ASSOCIATION AS TRUSTEE FOR THE PENNSYLVANI MATTHEW Y. SCHELL USING kiffMTCE_=Cy Dollar Amount Requested: within arbitration limits Are money damages requested? 0 Yes l No (check one) floutside arbitration limits NN. this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? Yes No ' <:A;: Name of Plaintiff/Appellant's Attorney: Leon P. Haller / Jill M. Wineka Check here if you have no attorney (are a Self - Represented [Pro SeJ Litigant) 'describes our .. - _ f the. Case Place an `X; to the of the ONE .case category' that most accurately y. Nature o PX IMARY .CASE: ` If you aie making more than Ane.`type of check the 'one that :;- y.. Q u consider .most important: TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional 0 Buyer Plaintiff Administrative Agencies - -= Malicious Prosecution 0 Debt Collection: Credit Card Board of Assessment _ n Motor Vehicle 0 Debt Collection: Other Board of Elections Nuisance El Dept of Transportation .... rr ` 0 Premises Liability El Statutory Appeal: Other Product Liability (does not include Employment Dispute: mass tort -;F= Discrimination 0 . Slander/Libel/ Defamation Employment Dispute: Other Zoning Board -_= Other: _ F1 Other: Other: MASS TORT Asbestos Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS --:_ Toxic Waste [3 Ejectment Common Law/Statutory Arbitration Other: fl Eminent Domain/Condemnation Declaratory Judgment Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order F FESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto - = Dental Partition _ Replevin Legal n Quiet Title Other: Medical 0 Other: Other Professional: Updated 1112011 FILED "JF THE PROTHONOTARY Leon P. Haller, Esquire 7013 MAY —8 AM .9: 140 Purcell, Krug & Haller 1719 North Front Street CUMBERLAND COUNTY Harrisburg, PA 17102 PENNSYLVANIA 717.234.4178 mtg @pkh.com U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING OF CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FO CLOSURE MATTHEW Y. SCHELL Defendant THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER O CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717 - 249 -3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER S DON C O N LA CO RTE EN FORMA ESC EL PUNTO D VISTA DE USTED YIO Q USTED, 0 SU ABO GADO, ALQUIER OBJECCION REGIS CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238 -6300. 0 CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET /,o CARLISLE, PA 17013 ✓8 �[J��/ 717 - 249 -3166 U.S. BANK NATIONAL ASSOCIATION AS IN THE COURT OF VAN A HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION LAW vs. ACTION OF MORTGAGE FORECLOSURE MATTHEW Y. SCHELL, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION -LAW vs. ACTION OF MORTGAGE FORECLOSURE MATTHEW Y. SCHELL, Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 and as amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through the Pennsylvania Housing Finance Agency ( "Agency "), its appointed Limited Power of Attorney, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. The Limited Power of Attorney executed October 4, 2006 between the Plaintiff and the Agency is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 11, 2006 in Book 731, Page 421. The Limited Power of Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 2. Defendant, MATTHEW Y. SCHELL, is an adult individual whose last known address is 810 WEST KELLER STREET, MECHANICSBURG, PA 17055. 3. On or about, November 22, 2010, the said Defendant executed and delivered a Mortgage Note in the sum of $87,497.00 payable to SUSQUEHANNA BANK, which Note is attached hereto and marked Exhibit "A ". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on November 24, 2010 as Instrument Number 201034486 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on November 24, 2010 as Instrument Number 201034487. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording, which Assignment is attached hereto and marked Exhibit `B ". The said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 810 WEST KELLER STREET, MECHANICSBURG, PA 17055 and is more particularly described in Exhibit "C" attached hereto. 6. The said Defendant is the real owner of the property. .7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on September 01, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $84,759.37 Interest at $11.18 per day $3,398.72 From 08/01/2012 To 06/01/2013 ( based on contract rate of 4.7500 %) Late Charges $18.26 $164.34 From 09/01/2012 to 06/01/2013 Escrow Deficit $922.46 Attorney's Fee at 5% of Principal Balance $4,237.97 TOTAL $93,482.86 "Together with interest at the per diem rate noted above after June 01, 2013 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated November 29, 2012 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the November 29, 2012 Act 6 Notice is attached hereto and marked Exhibit "D ". 9. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non - active military duty is attached as Exhibit "E ". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 4.7500% ($11.18 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PURCELL, KRUG & HALLER Leon P. Haller, Esquire I.D. # 15700 Jill M. Wineka I.D. #58802 Attorneys for Plaintiff 1719 N. Front Street Harrisburg, PA 17102 (717- 234 -4178) r r X�646 se No. 3451 -703 Multistate Loan #: 1026179 November 22, 2010 [Date] 810 West Keller Street, PA 17055 p 1. PARTIES g at the end of this Note, and the person's successors and assigns. "Lender means "Borrower" means each person signin Susquehanna Bank and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST FOUR HUNDRED NINETY-SEVEN AND 001100 rontises to pay the principal sum of EIGHTY-SEVEN THOUSAN In return for a loan received from Lender, Borrower p Dollars (1J.S. $ 87,497.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Four and three quarters percent (4.750%) per vear until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date ument." The Security Instrument protects the Lender from losses which might result if as this Note and called the "Security Insv Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on January 1, 2011. Any principal and interest remaining on the first day of December 2040 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at Susquehanna Bank 4185 West Market Street, York, PA 1740 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount ount Each monthly payment of principal interest the Security Instrument, that shall be applied to princ pal, interest and will be part of a larger monthly p ym ent re red by other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants o the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑ ❑ Graduated Payment Allonge Growing Equity Allonge El Other [specify] 10/95 VM (O FHA Id�,ltlstate Rx0 Rate Note r , t Page f o/ 3 VMP e Writers Kluwer Finanaal Services 611,. t [t Loan #: 1026179 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for d ar t artial prepayment,ethere will be no changes t in by the due or in the r of the monthly payment unless Lender agrees n p prepay Y writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph the amount 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender of may he o erdua amount of in h payment of Four percent ( 4.0000 (B) Default as limited by regulations If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lenders rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require osts and ire Borrower to pay thi law. Such fees and cos bear interest from the d to of disbursement at he he the not pal of this of Note. applicable 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. given b first class mail to Lender at the address stated in Any notice that must be given to Lender under this Note will beg Y Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay on amount et hs e obligations, including is a guarantor, surety or the obligations of endorser this Note is also guarantor, obligated to do these things. Any p or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under 1s Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. FHA Itistate Fixed Pate Note PeBe 2 VMP Wdters K i wet Financial Services BY SIGNING BELOW, Borrow ccepts and agrees to the terms and covenants contained in this Note. (Seal) (Seal) Borrower Matthew Y. the I Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower i 1 / y/ /�.� VMPiR (0809) FHA Multislele Fixae Rare Nore Page 3 3 or f3 3 VMP e W011— Kl w r Financial Services WITHOUT RECOURSE PAY TO THE ORDER OF t PENNSYLVANIA HO SING F INANCE A GENCY S ANNA gB' El PEGGY AT INSON, VICE PRESIDENT FOR SUSQUEHANNA BANK Record Prepared by & Return to: U.S. Bank National Association c/o PHFA - Accounting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, Pennsylvania 17105 -5057 717 - 780 -3800 or 1- 800 - 346 -3597 PIN / ID Number: 22240783067 Above space is in tentionally left blank for recording data ASSIGNMENT OF MORTGAGE For value received, PENNSYLVANIA HOUSING FINANCE AGENCY ( "PHFA "), hereby grant, sell, convey, assign and deliver unto the U.S. BANK NATIONAL ASSOCIATION, (Trustee for the Pennsylvania Housing Finance Agency, pursuant to a Trust Indenture dated as of April 1, 1982), its successors and assigns, the following described Mortgage, together with the Note secured thereby: Name of Original Mortgagor(s): MATTHEW Y. SCHELL Secured by the real property located at: 810 WEST KELLER STREET, MECHANICSBURG, PA 17055 Municipality of: TOWNSHIP OF MONROE Original Principal Amount: $87,497.00 County Recorded in: CUMBERLAND Mortgage Recorded: November 24, 2010 Instrument#: 201034486 Last Assignment to: PA Housing Finance Agency Instrument #: 201034487 IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 112, PHFA) [HANES] DATED: March 12, 2013 By: N HOUSING FINANCE AGENCY Thomas F. Brzana, Jr. Director of Loan Servicing COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, thell day o yy' F (✓ , 2013, before me, the undersigned officer, personally appeared Thomas F. Brzana, Jr. Director of Loan Servicing, an authorized officer of the Pennsylvania Housing Finance Agency, and acknowledged that he, being authorized to do so, executed the foregoing instrument for the purposes therein contained. In witness whereof, I have hereunto set my hand and official seal. Notary Public rol i Ial _ NP4MVAN A .. Notarial seal Kimberley A. Ayala, Notary Public City of Harrisburg, Dauphin County My Commission Expires Jan. 15, 20 MEMBER, PENNSYLVANIA A5500AUUN ur NOTARIES CERTIFICATE OF RESIDENCE OF ASSIGNEE I certify that the principal business and mailing address for this assignment and assignee is: U.S. Bank National Association, c/o PHFA - Accounting & Loan Servicing 211 North Front Street, P.O. Box 15057, Harrisburg, Pennsylvania 17105 -5057 A 6C I ��sf < < p l All that certain lot of land situate in the Township of Monroe (Silver Spring Township in prior deed), County of Cumberland and State of Pe nsylvania, bounded and described as follows: I BEGINNING at a point on the North side of West Keller Street at a distance of three hundred fifty (350) feet measured in a Westerly direction aong West Keller Street from the Westerly line of Long Meadow s Street; thence in a Northerly direction . long the line of Lot No. 63 on the hereinafter mentioned Plan of Lots, one hundred forty-three (143) fed to a point on the Southerly line of a five (5) foot alley; thence in a Westerly direction along said alley, Ofty (50) feet to a point; thence in a Southerly direction along the i line of Lot No. 65 on said Plan of Lots, one hundred forty-three (143) feet to a point on the Northerly line of West Keller Street; thence along West Keller Street in an Easterly direction, fifty (50) feet to a point, the place of beginning; and BEING Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong, known as Point Comfort, said Plan being duly recorded in the office of the Recorder of Deeds in and for Cumberland County in Plan Book 2, page 36. Being County Parcel Number 22 -24 -0783 -067 I i Pennsylvania HOUSin Finance Agency Accounting & Loan Servicing 211 North Front Street, P.D. Box 15057 Harrisburg, PA 1 71 05 -5 05 7 (800) 346 -3597 FAX (717) 780 -3899 TTY (717) 780 -1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 11/29/2012 RE: Account No. 2344604 MATTHEW Y. SCHELL 810 W KELLER ST MECHANICSBURG, PA 17055 -4028 RE: 810 WEST KELLER STREET MECHANICSBURG, PA 17055 -4028 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter We, Us or Ours) on your property located at 810 WEST KELLER STREET, MECHANICSBURG, PA 17055 -4028, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $637.00 for 9/2012 through 11/2012 for a total of $1,911.00. Late charges and NSF charges that have accrued to this date in the amounts of $54.78 and $.00 respectively, are also due. The total listed below includes all fees (including inspections and securing that needed to be completed) less any funds we are holding in suspense. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $1,985.78. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $1,985.78, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash in our office, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET /P.O. BOX 15057 HARRISBURG, PA 17105 -5057 1- 800 - 822 -7375 or TTY (800) 346 -3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgageed p roperty. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the mortgage debt. If.we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, 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 fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty -day period, you will not be required to pay attorney fees. FHAACT /dtmdocs /ALSV/ We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty -day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriff Ps foreclosure sale You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1- 800 - 822 -7375. This payment must be made payable in cash in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND 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 RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default the mortgage will be restored to the same position as it no default had occurred However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Sincerely, j' Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105 -5057 TLG/ FHAACT /dtmdocs /ALSW Pennsylvania Housing Finance Agency Acco unting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05 -5 05 7 (800) 346 -3597 FAX (717) 780 -3899 TTY (717) 780 -1869 NOTICE 11/29/2012 MATTHEW Y. SCHELL 810 W KELLER ST MECHANICSBURG, PA 17055 -4028 RE: Account #2344604 TO: MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 -4028 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ( "HUD ") and experienced in the provision of homeownership counseling. Attached is a current list of HUD - approved counseling agencies for Pennsylvania. If these agencies are not near you, you can call HUD's toll free number (800) 569 -4287 for financially distressed mortgagors for information concerning HUD - approved housing counseling agencies. Attachment: Housing Counseling List FH AACT /dtmdocs /ALSV/ * ** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY * ** CCCS OF WESTERN PA- HARRISBURG NACA 2000 LINGLESTOWN RD. 1341 N DELAWARE AVE; SUITE 312 HARRISBURG, PA. 17110 PHILADELPHIA, PA. 19125 Phone:888 -599 -2227 Phone:888- 297 -5568 HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT 34 S. Duke St. ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 York, PA 17401 -1106 PHILADELPHIA, PA. 19103 -1828 Phone: 800 - 864 -4909 Phone:800- 930 -4663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608 -1676 Phone: 717 - 397 -5182 FH AACT /dtmdocs /ALSV/ 6 � , Penns3ivan ' Accounting & Loan Service P.O. Bog 15057 Harrisburg, PA 17105 -5057. SRV STR Loai 7196 9 008 9111 1 1 7 629 0471 CP: Bori Em P. Ema. Z. Bo ri F mo EmP �� r Em a, i[5 +X�j��yQ�' �® Prod Addi Mai MATTHEW Y S' N: T E fi ! r :L 810 W KELLE� Add: MECH?ANICSBU RETURN TO SENDER LENCL.AIMED Leg UNA BLE TO FORWARD D-C,'- 17 P a g, I z� Wmm -a m UJ -I c z 4e C m —I m N `A m CL w N 0 N m y n , 3 m Ld _. a °8 m W C!] C] n I � —Act Letter CD CD r CD D ' r . r. - : Department of Defense Manpower Data Center Results as of Apr -06 -2073 07:55:06 SCRA 3.0 X Status Report 5 .. Pursuant to Servicomen s Civil Relief Act j , Last Name: SCHELL First Name: MATTHEW Middle Name: Y Active Duty Status As Of: Apr -06 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status - Service Component - NA NA - No - NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her 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 DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. X) } 4 . Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 (� l Y U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. PENNSYLVANIA HOUSING FINANCE AGENCY, Attorney -in -Fact for U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Dated B Thomas F. Brzana, Jr., Director of Loan Servicing for the Pennsylvania Housing Finance Agency, Attorney -in- Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency SCHELL 2344604 IN THE COURT OF COMMON PLEAS OF — U U.S. BANK NATIONAL ASSOCIATION AS r - 1 C a fi ? TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA =M =� r� FINANCE AGENCY Plaintiff(s) ,r— 11 �C'� Co --BCD VS. y z ., CD--T! CS MATTHEW Y. S CHELL 22 _ )> � /J 0 � � . , Defendants , Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court - supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectful mi 5/7/13 Date Leon f. H:aller / Ji M. Wineka Attorney for Plaintiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 PA ID 157h / 58802 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST OMERIPRIMARY APPLICATIO Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? C O-BORRO WER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? INF FINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Asset Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles boats motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses You are currently oayinal EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following'information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH I/We, authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed U.S. BANK NATIONAL ASSOCIATION ; IN THE COURT OF COMMON PLEAS OF AS TRUSTEE FOR THE PENNSYLVANIA HOUSING: CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff(s) . VS. MATTHEW Y. SCHELL Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date SHERIFF'S OFFICE OF CUMBERLAND COUNTY F,f L Ronny R Anderson OT THC .0 I i 0 h,0 y Sheriff t Jody S Smith V�011 15 Chief Deputy CUt",B-E R L A IN D C up4 y Richard W Stewart OMCE TWZ$4EPIrr FEN NSYLVAH1 Solicitor US Bank National Association Case Number MatS. 2013-2557 thew Y Schell SHERIFF'S RETURN OF SERVICE 05/09/2013 03:02 PM-Deputy Shawn Harrison, being duly sworn according to law, servo a F equlested Notice of Ig ga!t�q - , rec c Residential Mortgage Foreclosure Diversion Program and Complaint in rti, osure by t personally"handing a true copy to a person representing themselves t t"[Deendant, to wit: . I Matthew Y Schell at 810 W. Keller Street, Monroe Township, Mechanics A 5 S S WN HA ON, DEPUTY 05/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 810 W. Keller Street, Monroe Township, Mechanicsburg, PA 17055. SHERIFF COST: $54.30 SO ANSWERS, May 13,2013 RbNN"Y R ANDERSON, SHERIFF {c)OountySufto Sheriff,Toleosoft,Itir, 1_�. T(IF a r O;° HE T rROTHON -0 I'm 1iky LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER ?6013 JUL 18 AN i i: 4 7 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 CUMBERLAND COUNTY (717) 234-4178 PENNSYLVANIA ATTORNEY FOR PLAINTIFF U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW VS . NO. 13 -2557 CIVIL TERM MATTHEW Y. SCHELL IN MORTGAGE FORECLOSURE Defendant MOTION TO LIFT STAY IMPOSED BY THE MORTGAGE FORECLOSURE DIVERSION PROGRAM AND NOW comes Plaintiff, U. S . Bank National Association Trustee for The Pennsylvania Housing Finance Agency, through it ' s counsel, Leon P . Haller , and in accordance with Paragraph (k) of the Order of February 28, 2012 , establishing the Mortgage Foreclosure Diversion Program, represents as follows : 1 . The within foreclosure action was filed May 8 , 2013 . 2 . Service of the Complaint and Notice of Residential Mortgage Foreclosure Diversion Program was made on May 9 2013 . 3 . More than sixty (60) days have elapsed since the service of the Notice of the Residential Mortgage Foreclosure Diversion Program. 4 . Defendant has not opted to participate in the Mortgage Foreclosure Diversion Program. 5 . Plaintiff, in accordance with the provisions of the Mortgage Foreclosure Diversion Program, requests that the stay be lifted. WHEREFORE, Plaintiff requests that the stay imposed by the Cumberland County Mortgage Foreclosure Diversion Program be lifted to allow Plaintiff to proceed with the foreclosure action. PURCELL, KRUG & HALLER By Leon Haller 1719 North Front Street Harrisburg, PA 17102 -2392 (717 ) 234 -4178 Attorney ID #15700 Attorney for Plaintiff Dated: July 16 , 2013 VERIFICATION I verify that the statements made in the foregoing Petition to Lift Stay, are true and correct . I understand that false statements herein are made subject to the penalties of 18 Pa - C . S . Section 4904 relating to unsworn falsification to authorities . Leon P . Haller Dated : July 16 , 2013 C LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW Vs . NO . 13 -2557 CIVIL TERM MATTHEW Y. SCHELL IN MORTGAGE FORECLOSURE Defendant CERTIFICATE OF SERVICE I, Leon P. Haller , the undersigned, Attorney for Plaintiff, hereby certify that I served on the 16th day of July, 2013 , a copy of the Petition to Lift Stay Imposed by Mortgage Foreclosure Diversion Program upon each of the following persons at the addresses shown below: Matthew Y. Schell 810 West Keller Street Mechanicsburg, PA 17055 Leon P. Ha ler Dated: July 16 , 2013 Attorney fo ,.Plaintiff . f U. S . BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION - LAW VS . NO. 13 -2557 CIVIL TERM MATTHEW Y. SCHELL IN MORTGAGE FORECLOSURE Defendant ORDER AND NOW, this ZZJ day of 9'1t1 , 2013 , upon consideration of Plaintiff Petition to Lift Stay, Notice of the Residential Mortgage Foreclosure Diversion Program having been served on May 16 , 2013 , and Defendant having not opted to participate in the Mortgage Foreclosure Diversion Program, IT IS HEREBY ORDERED that the stay imposed by the Mortgage Foreclosure Diversion Program be lifted and Plaintiff may proceed with its mortgage . foreclosure action. BY THE COURT: J. c , r -Z-) z '"r'7 N 7� 3 )CD Cz co O^. U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, < r`, DEFENDANT(S) MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: 3 CD Ii ' 1 Y`R Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) MATTHEW Y. SCHELL for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance $84,759.37 Interest $3,398.72 Per diem of$11.18 From 08/01/2012 To 06/01/2013 Late Charges $164.34 ($18.26 per month to 06/01/2013) Escrow Deficit $922.46 5%Attorney's Commission $4,237.97 TOTAL $93,482.86 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG &HALLER By Leon P _tAgrer PA I.D. # 1 0 171 orth Front Street Harrisburg, PA 17102 (717) 234-4178 ��.� o U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS �~s TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIL FINANCE AGENCY, G PLAINTIFF CIVIL ACTION LAW G-) Vs. NO. 13-2557 CIVIL --- .7--, CD IN MORTGAGE FORECLOSURE —0 "n MATTHEW Y. SCHELL, N DEFENDANT(S) —� co CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on July 25, 20131 served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s)in this matter by regular first class mail,postage prepaid, as indicated on the attached Notice. By Leon P. Halle A I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff NO. 13-2557 CIVIL VS. CIVIL ACTION LAW MATTHEW Y. SCHELL IN MORTGAGE FORECLOSURE Defendant DATE OF THIS NOTICE: July 25,2013 TO: MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL,KR G &HA LER By LEON P. HALLER,Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717)234-4178 U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL i. MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT C C:� ' - > AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF DAUPHIN 1, LEON P. HALLER, Attorney for the Plaintiff in the above matter, being duly sworn according to law, hereby certify that the Mortgage in the above case is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 1715z11) and therefore does not fall within the provisions of PA Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program). Sworn to and subscribed before me this day of 20� LEON LER, ESQUIRE otary u is Ci ' Ufi��c U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO, 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT NON-MILITARY AFFIDAVIT C-- COMMONWEALTH OF PENNSYLVANIA C) SS COUNTY OF DAUPHIN Personally appeared before me,a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendants above named are not on active duty in the Military Service nor engaged in any way which would bring them within the Servicemembers' Civil Relief Act. A copy of the search through the Defense Manpower Data Center website is attached. Sworn to and subscribed before e,this,6' day , Of 20� LEON P.11A- LLER, ESQUIRE of y P is COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL I'AARYU.N0 1C-r-ERRETTI N 'ary Public LOVIC7RX-dor Twp,,f)ZU410n County 01 P0y Commission Expires Aug.C,2014 4 Department of Defense Manpower Data Center Results as of:Aug-14-201309:09:41 Y SCRA 3.0 Stan,is deport pursuanuto SIrrtc+ernemobees Civil Relief Act Last Name: SCHELL First Name: MATTHEW Middle Name: Y Active Duty Status As Of: Aug-14-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals'actve duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Dale Order Notification End Dale Status Service Component NA NA -No NA This response reflects whether the Individual or his/her 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 DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aaj, F _ vG Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 i The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: K41BOF71 EOB8B00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW AT NO. 13-2557 CIVIL U.S.BANK NATIONAL ASSOCIATION,AS Total Judgment Amount $93,482.86 TRUSTEE FOR THE PENNSYLVANIA HOUSING Interest $2,013.56 FINANCE AGENCY, Per diem of$11.18 to sale PLAINTIFF date 12/4/2013 Late Charges $109.56 VS. $18.26 per month to sale date 12/4/2013 MATTHEW Y. SCHELL, Escrow Deficit $1,874.27 DEFENDANT(S) TOTAL WRIT $97,480.25 *Plus additional interest,late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday,December 04,2013 (PROTHONOTARY'S USE) Pltf.Paid Deft.Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION-MORTGAGE FORECLOSURE-) c r TO THE PROTHONOTARY/CLERK OF SAID COURT: MOD OD Issue Writ of Execution in the above captioned case. , • ) r-- �o -'TI Date: August 12 2013 D n °;=- ry off, Attorney for Plaintiff - ^r 1719 North Front Street IPofrP. Haller CO Harrisburg, PA 17102 PA I.D. #15700 (717)234-4178 WRIT OF EXECUTION-MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUN Y: To satisfy the judgment, interest and costs i the abo a captioned case,you are directed to levy upon and sell the property described in the attached descriptio know as 810 WEST KELLER STREET MECHANICSBURG,PA 17055 DateROTHONOTARY/CLERK CIVIL DIVISION Qr' Y 5Li 3 "—r DEPUTY IDS 75' �,� so 160. a �-� a ALL THAT CERTAIN lot of land situate in the Township of Monroe (Silver Spring Township in prior deed), County of Cumberland and State of Pennsylvania,bounded and described as follows: BEGINNING at a point on the North side of West Keller Street at a distance of three hundred fifty (350) feet measured in a Westerly direction along West Keller Street from the Westerly line of Long Meadow Street; thence in a Northerly direction along the line of Lot No. 63 on the hereinafter mentioned Plan of Lots, one hundred forty three(143) feet to a point on the Southerly line of a five(5) foot alley; thence in a Westerly direction along said alley, fifty(50) feet to a point; thence in a Southerly direction along the line of Lot No. 65 on said Plan of Lots, one hundred forty three (143) feet to a point on the Northerly line of West Keller Street; thence along West Keller Street in an Easterly direction, fifty (50) feet to a point,the place of BEGINNING. BEING Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong, known as Point Comfort, said Plan being recorded in Cumberland County Plan Book 2, Page 36. HAVING THEREON ERECTED A DWELLING KNOWN AS 810 WEST KELLER STREET MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-067. BEING THE SAME PREMISES WHICH Helen E. Hale by deed dated 11/22/10 and recorded 11/24/10 in Cumberland County Instrument No. 201034485, granted and conveyed unto Matthew Y. Schell. TO BE SOLD AS THE PROPERTY OF MATTHEW Y. SCHELL ON JUDGMENT NO. 13-2557 CIVIL s 1 U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW C-) , VS. NO. 13-2557 CIVIL tnm � r 'r MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) - ! AFFIDAVIT PURSUANT TO RULE 3129.1 no X.. = The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as7of tfi date the praecipe for the writ of execution was filed, the following information concerning the real property located at 810 WEST KELLER STREET MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE. 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 PSECU P. O. Box 67013 Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 TENANT/OCCUPANT 810 WEST KELLER STREET MECHANICSBURG, PA 17055 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorit' Le aller PA I.D. #15700 urcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 DATE:August 12, 2013 A i U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 c rn TAKE NOTICE: a _ o That the Sheriffs Sale of Real Property(real estate)will be held: C -v n r� N DATE: Wednesday,December 04,2013 , TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property,together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 810 WEST KELLER STREET MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 13-2557 CIVIL JUDGMENT AMOUNT $93,482.86 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MATTHEW Y. SCHELL A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten(10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. i YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 a i ALL THAT CERTAIN lot of land situate in the Township of Monroe (Silver Spring Township in prior deed), County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Keller Street at a distance of three hundred fifty (350) feet measured in a Westerly direction along West Keller Street from the Westerly line of Long Meadow Street;thence in a Northerly direction along the line of Lot No. 63 on the hereinafter mentioned Plan of Lots, one hundred forty three (143) feet to a point on the Southerly line of a five (5) foot alley; thence in a Westerly direction along said alley, fifty(50) feet to a point; thence in a Southerly direction along the line of Lot No. 65 on said Plan of Lots, one hundred forty three (143) feet to a point on the Northerly line of West Keller Street; thence along West Keller Street in an Easterly direction, fifty (50) feet to a point,the place of BEGINNING. BEING Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong, known as Point Comfort, said Plan being recorded in Cumberland County Plan Book 2, Page 36. HAVING THEREON ERECTED A DWELLING KNOWN AS 810 WEST KELLER STREET MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-067. BEING THE SAME PREMISES WHICH Helen E. Hale by deed dated 11/22/10 and recorded 11/24/10 in Cumberland County Instrument No. 201034485, granted and conveyed unto Matthew Y. Schell. TO BE SOLD AS THE PROPERTY OF MATTHEW Y. SCHELL ON JUDGMENT NO. 13-2557 CIVIL WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2557 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff(s) From MATTHEW Y.SCHELL (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 GARNISHEES)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $93,482.86 L.L.: $.50 Interest PER DIEM OF$11.18 TO SALE DATE 12/4/2013-$2,013.56 Atty's Comm: Due Prothy: $2.25 Atty Paid: $203. Other Costs: LATES CHARGES-$1 09.56-$18.26 PER MONTH TO SALE DATE 12/4/13 ESCROW DEFICIT-$1,874.27 Plaintiff Paid: Date: August 16,2013 David D.Bu 11, Prothonota (Seal) Deputy REQUESTING PARTY: Name: LEON P.HALLER,ESQUIRE Address: PURCELL,KRUG&HALLER 1719 NORTH FRONT STREET HARRISBURG,PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 `U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 =` rrj t ._ DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street , V Carlisle, PA 17013 TENANT/OCCUPANT - 810 WEST KELLER STREET MECHANICSBURG, PA 17055 Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 PSECU P. O. Box 67013 Harrisburg, PA 17105 By P , KRUG& HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES,Q,. 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 HERSHEY LEON P.HALLER TELEPHONE(717)2344178 (717)533-3836 JOHN W.PURCELL JR. FAX(717)234-1206 JILL M.WINEKA LISA RYNARD MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 810 WEST KELLER STREET MECHANICSBURG, PA 17055 Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 PSECU P. O. Box 67013 Harrisburg, PA 17105 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being not ed of said Sheriffs Sale. By: Le aller PA I.D.15700 ttorney for Plaintiff U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property(real estate)will be held: DATE: Wednesday, December 04,2013 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property,together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 810 WEST KELLER STREET MECHANICSBURG,PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 13-2557 CIVIL JUDGMENT AMOUNT $93,482.86 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MATTHEW Y. SCHELL A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten(10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot of land situate in the Township of Monroe (Silver Spring Township in prior deed), County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Keller Street at a distance of three hundred fifty (350) feet measured in a Westerly direction along West Keller Street from the Westerly line of Long Meadow Street; thence in a Northerly direction along the line of Lot No. 63 on the hereinafter mentioned Plan of Lots, one hundred forty three (143) feet to a point on the Southerly line of a five (5) foot alley; thence in a Westerly direction along said alley, fifty(50) feet to a point; thence in a Southerly direction along the line of Lot No. 65 on said Plan of Lots, one hundred forty three (143) feet to a point on the Northerly line of West Keller Street; thence along West Keller Street in an Easterly direction, fifty (50) feet to a point, the place of BEGINNING. BEING Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong, known as Point Comfort, said Plan being recorded in Cumberland County Plan Book 2, Page 36. HAVING THEREON ERECTED A DWELLING KNOWN AS 810 WEST KELLER STREET MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-067. BEING THE SAME PREMISES WHICH Helen E. Hale by deed dated 11/22/10 and recorded 11/24/10 in Cumberland County Instrument No. 201034485, granted and conveyed unto Matthew Y. Schell. TO BE SOLD AS THE PROPERTY OF MATTHEW Y. SCHELL ON JUDGMENT NO. 13-2557 CIVIL 71% 9008 9111 9610 4000 TO: MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG,PA 17055 SENDER: P01455/39840 REFERENCE: NOS 12/04/13 PS Form F,800 January 2005 RETURN Postage RECEIPT Certified Fee 3.10 SERVICE Return Receipt Fee 2.55 _ Restricted Delivery 4.75 _ Total Postage&Fees 1106 USFW POST 6)R DATE Receipt for Certified Mail" No Irmmm a Cowmpa Prwidrrd Do Not UN for kMrlr ou"and $ENNSYLVANIA HOUSING FINANCE AGENCY v.MATTHEW Y. SCHELL Cumberland County Sale 12/4/2013 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG,PA 17055 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 U. S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 j One piece of ordinary mail addressed to: Postmark: PSECU P. O. Box 67013 Harrisburg, PA 17105 o�PtES"P% • ' PIr-FY B.wr, 02 1M $ 01.20') 0004284324 AUG28 2013 MAILED FROM ZIP CODE 1 710 2 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 U.S.POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell,Krug&Haller Postage: 1719 North Front Street Harrisburg,PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 810 WEST KELLER STREET MECHANICSBURG,PA 17055 { 5�P1is pcs;�� Y n '" z' PIIN£Y BOWES 021M $ 02.400 0004284324 AUG28 2013 MAILED FROM ZIP CODE 17102 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff w yy��tr art Nttt�it.1 Jody S Smith 4,44. I! 1 Chief Deputy �, .r a ems. Richard W Stewart I n T Solicitor OFFICE OF FoE SMERIFF 1,I k, ti, US Bank National Association vs. Case Number Matthew Y Schell 2013-2557 SHERIFF'S RETURN OF SERVICE 09/24/2013 08:21 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 810 West Keller Street, Mechanicsburg, PA 17055, Cumberland County. 09/27/2013 02:46 PM - Deputy Jamie DiMartle, 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 the Defendant, to wit: Matthew Y Schell at 810 W. Keller Street, Monroe Township, Mechanicsburg, PA 17055, Cumberland County. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Leon Haller, on behalf of U.S. Bank National Association, as Trustee for the Pennsylvaia Housing Finance Agency, being the buyer in this execution, paid to the Sheriff the sum of$. SHERIFF COST: $831.57 SO ANSWERS, January 10, 2014 RONNK ANDERSON, SHERIFF W oD pd. t sb r' ' aof 01.0 lc;Coun'ySuite Shrift,TalRoso t.Inc • On August 20, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 810 West Keller Street, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 20, 2013 By: Real Estate Coordinator !v U • • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-2557 Civil Term US BANK NATIONAL ASSOCIATION vs. MATTHEW Y. SCHELL Atty.:Leon P.Haller ALL THAT CERTAIN lot of land sit- uate in the Township of Monroe(Sil- ver Spring Township in prior deed), County of Cumberland and State of Pennsylvania, being Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong,known as Point Comfort, recorded in Cumberland County Plan Book 2,Page 36 and having thereon erected a residential dwelling known as:810 WEST KELLER STREET ME- CHANICSBURG,PA 17055. TAX PARCEL NO. 22-24-0783- 067. Reference Cumberland County Instrument No.201034485. TO BE SOLD AS PROPERTY OF MATTHEW Y. SCHELL ON JUDG- MENT NO. 13-2557 CIVIL. 104 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. Lisa Mar e Coyne, Ed or � ,rl SWO1t1 TO AND SUBSCRIBED before me this 25 da of October, 2013 Notary NOI.ARIAL SEAL DEBJRAH A COLLINS Notary Public CAR M ROUGH,CUMNLD UY' y LISLE Commission BO Expires Apr BERLA 28,2C001.1 14N The Patriot-News Co. 2020 Technology Pkwy he patriotxews Suite 300` Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 2013-2557 C1v]Term 10/13/13 -- US BANS NATIONAL ASSOCIATION / 10/20/13 MATTHEW Y SCHELL " 10/27/13 Attye Leon P Hailer ALL THAT CERTAIN lot of land situate I i in the Township of Monroe(Silver Spring 4( . 1bvmship in prior deed); County of' Cumberland and State of Penasyhfania, ` being Lot No.64 oe.tbe.Planof.Lois laid,' !ourtirGenttg S 'known Sworn • :ad iu• cribe• before me th - 1 •ay of Novembe , 2013 A.D. •Point ;Worded io CuMberland ' I i , I I ( , / ty 2 Page 36 and having �� . . `Jw ttt tt-'ete�d a residential dwelling V — Nota 'w• IC 111 known as 81PWEST I3EL ER STREET MECHANICSBURG;PA 17055 MIP TAX PARtL ND.22-24-0783{167. Reference Qtmberland County Instrument No.201034485. TO BE SOLD AS PROPERTY OF MATTHEW Y.SCHELL ON JUDGMENT NO.13-2557 czvvn C__Mf O1J+U ALE 'F PENNSYLVANIA No,aric'Sea' Holly Lynn vt° BFI,t itary Public Washington Twp,,Dauphin County y Commission Expires Dec.12,2016 EM______ 6 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTAR1Fc 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 U.S. Bank National Association as Trustee for the Pennsylvania Housing Finance Agency 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 16th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2557, at the suit of U.S. Bank National Association as Trustee for the Pennsylvania Housing Finance Agency against Matthew Y. Schell is duly recorded as Instrument Number 201401151. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this J 5- day of , A.D. ` J L{ ) 11/1/t f X 1,2e-,Lt.071 , be/301t/ Recorder' Deeds Recorder of Deeds rvmheriand County,Carlisle,PA My Commissuun Ezp N,c'he First Monday of Jan.2018 COPY U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 810 WEST KELLER STREET MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): MATTHEW Y. SCHELL 810 WEST KELLER STREET MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE. 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 PSECU P. O. Box 67013 Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: UNKNOWN • 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 810 WEST KELLER STREET MECHANICSBURG, PA 17055 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unworn falsification to authorit' Lei aller PA I.D. #15700 urcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:August 12, 2013 U.S.BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 13-2557 CIVIL MATTHEW Y. SCHELL, IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property(real estate)will be held: DATE: Wednesday,December 04,2013 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property,together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 810 WEST KELLER STREET MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 13-2557 CIVIL JUDGMENT AMOUNT $93,482.86 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MATTHEW Y. SCHELL A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD,TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. • • YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot of land situate in the Township of Monroe (Silver Spring Township in prior deed), County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Keller Street at a distance of three hundred fifty (350) feet measured in a Westerly direction along West Keller Street from the Westerly line of Long Meadow Street;thence in a Northerly direction along the line of Lot No. 63 on the hereinafter mentioned Plan of Lots, one hundred forty three (143) feet to a point on the Southerly line of a five (5) foot alley; thence in a Westerly direction along said alley, fifty(50) feet to a point; thence in a Southerly direction along the line of Lot No. 65 on said Plan of Lots, one hundred forty three (143) feet to a point on the Northerly line of West Keller Street; thence along West Keller Street in an Easterly direction, fifty (50) feet to a point, the place of BEGINNING. BEING Lot No. 64 on the Plan of Lots laid out by George B. Vogelsong, known as Point Comfort, said Plan being recorded in Cumberland County Plan Book 2, Page 36. HAVING THEREON ERECTED A DWELLING KNOWN AS 810 WEST KELLER STREET MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-067. BEING THE SAME PREMISES WHICH Helen E. Hale by deed dated 11/22/10 and recorded 11/24/10 in Cumberland County Instrument No. 201034485, granted and conveyed unto Matthew Y. Schell. TO BE SOLD AS THE PROPERTY OF MATTHEW Y. SCHELL ON JUDGMENT NO. 13-2557 CIVIL