HomeMy WebLinkAbout13-2558 Supreme Coil A o Penn lvania
Coll flt,COb11Y oi& For. Prothonotary Use Only:
j
C Vfl "C' •Sheet :Docket No:
CUr�,riD „ County
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 by law or rules of court.
"Commencement of Action:
Complaint Q Writ of Summons 0 Petition
' Transfer from Another Jurisdiction Q Declaration of Taking
Lead Plaintiff s Name: 1<J . S. BANK NATIONAL Lead Defendant's Name:
ASSOCIATION AS TRUSTEE FOR THE PENNSYLVANI DARLENE L. WOODALL N K A DARLENE L. AND RSON
T E Y
_ Dollar Amount Requested: Elwithin arbitration limits
Are money damages requested? E] Yes No (check one) noutside arbitration limits
N ` . Is this a Class Action Suit? Q Yes 6 No Is this an MDJAppeal? 0 Yes No
Name of Plaintiff/Appellant's Attorney: Leon P. Haller / Jill M. Wineka
Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant)
"X" to the left of e' ory that iRosf accurately describes your
e'of: .. `':..
Natur the: Case Place an.. ,.:...... :- the ONE :case'cat g ..
PRI : ` f you are making .more than .one. type of . claim, check the one that .
MARY.CAS E I
- ` you.consider.rnost important:
- - TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
Intentional Buyer Plaintiff Administrative Agencies
_ __ E] Malicious Prosecution Debt Collection: Credit Card Board of Assessment
n Motor Vehicle Debt Collection: Other Board of Elections
Ej Nuisance Dept. of Transportation
Premises Liability 0 Statutory Appeal: Other
rl Product Liability (does not include
mass tort) Employment Dispute:
Discrimination
Slander/Libel/ Defamation Employment Dispute: Other Zoning Board
C ,.. ; 0 Other: Other:
Other:
= == MASS TO
El Asbestos
Tobacco
Toxic Tort - DES _
RE
Toxic Tort - Implanter, PROPERTY MISCELLANEOUS
Toxic Waste E3 Ejectment r-1 Common Law /Statutory Arbitration
Other: Eminent Domain/Condemnation 0 Declaratory Judgment
":8 Q Ground Rent 0 Mandamus
- :_= Landlord/Tenant Dispute 0 Non - Domestic Relations
-_ _ Mortgage Foreclosure: Residential Restraining Order
== a PROFESSIONAL LIABLITY Q Mortgage Foreclosure: Commercial Quo Warranto
El Dental Partition Replevin
Legal 0 Quiet Title Other:
Medical [3 Other:
Other Professional:
Updated 1/112011
ILEB
OF THE PROTHONO3 . Ar ';Y
Leon P. Haller, Esquire 2B{3 MAY _8 AM J
Purcell, Krug & ller
11719 North Front Street CUMBERLAND COUNTY
Harrisburg, PA 17102 PENNSYLVAt"
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 FORECLOSURE
DARLENE L. WOODAL
L N/K/A DARLENE L. 13
ANDERSON
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 OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717- 249 -3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA
DE A.BOGADOS), (215) 238 -6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
LI O EI TIO 3 SOUTH BEDFORD STR
CA EET
717- 249 -3166 /+/
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
DARLENE L. WOODALL N/K/A DARLENE L.
ANDERSON,
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 -41.78
Attorney I.D.# 15700
Attorney for Plaintiff
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: 325 JUNIPER STREET, CARLISLE, PA 17013 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 $90,329.71
Interest at $2.51 per day $760.53
From 08/01/2012 To 06/01/2013
( based on contract rate of 1.0000 %)
Accumulated Late Charges $404.62
Late Charges $13.70 $123.30
From 09/01/2012 to 06/01/2013
Escrow Deficit $79.35
Attorney's Fee at 5% of Principal Balance $4,516.49
TOTAL $96,214.00
"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 letters
dated November 16, 2012 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the
November 16, 2012 Act 6 Notices 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 her 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 1.0000% ($2.51 per diem), together with other charges and
costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of
the property within described.
By:
PURCELL, KRUG & HA LER
Leon P. Haller, Esquire
I.D. # 15700
Jill M. Wineka
I.D. #58802
Attorneys for Plaintiff
1719 N. Front Street
Harrisburg, PA 17102
(717- 234 -4178)
QCIA K'an Number: 124007043
72-
NOTE
FHA CASE NO.
1s o n 441- 7940407
MAY 18, 2007
[Date]
325 JUNIPER STREET, CARLISLE, PENNSYLVANIA 17013
[Property Address)
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, A
PENNSYLVANIA BANKING CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to ay the principal sum of NINETY -EIGHT
THOUSAND FOUR HUNDRED FIFTY -FIVE AND 00100 Dollars
(U.S.$ 98, 455.00 ), 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 FIVE AND 500/1000
percent ( 5 . 500 %) per year
until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same
date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might
result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning
on JULY 1, 2007 . Any principal and interest remaining on the first day of
JUNE 1, 2037 will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at 1767 SENTRY PARKWAY WEST, SUITE 220, BLUE BELL,
PENNSYLVANIA 19422
or at such other place as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 559. 02
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal,
interest and 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 of 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.)
❑ Growing Equity Allonge ❑ Graduated Payment Allonge
❑ Other (specify]
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or 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 the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower
makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender
agrees in writing to those changes.
I -
MULTLSTATE -FHA FDMD RATE NOTE (6/96)
tba M Sysxm3. 1- (SM 649 -1362 Page 1 of 2
r Y
,4 1 /
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Secur(ty Instrument, as described in Paragraph 4(C)
of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of
FOUR AND 000 /1000 percent ( 4.000 %)
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations 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 waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment
in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations.
As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable
law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means
the right to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note willbe 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.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated
in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made
in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this
Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a
guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may
enforce its rights under this Note against each person individually or against all signatories together. Any one person signing
this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees m the terms and covenants contained in pages I and 2 of this Note.
11, _ r
(Seal) (Seal)
L WOODALL - Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
MUL MrATE-FHA FDCiD RATE NOTE (6/46)
DM-1 sY-1, 1— MO) 649.1362 Page 2 of 2
u :m�.�m 1.1
ALLONGE
Loan Number: 124007043
Loan Date: MAY. 18, 2007
Borrower(s): DARLENE L WOODALL
Property Address: 325 JUNIPER STREET, CARLISLE, PENNSYLVANIA 17013
Principal Balance: $ 9 8, 4 5 5. 0 0
PAY TO THE ORDER OF
PENNSYLVANIA HOUSING FINANCE AGENCY
Without Recourse
Company Name: PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK
i .� l ' ��, .
By MORTGAGE UNDERWRIT MANAGER
(Name) (Title)
DENISE DIGIOVANNI
MULTISTATE NOTE ALLONGE 800-649 -7362
03/08/07 www.docmagic.com
Aj.,
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: 03220485105
Above space is intentionally 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): DARLENE L. ANDERSON
Secured by the real property located at: 325 JUNIPER STREET, CARLISLE, PA 17013
Municipality of CARLISLE
Original Principal Amount: $98,455.00 County Recorded in: CUMBERLAND
Mortgage Recorded: May 30, 2007 Record Book: 1993 Page: 4322
Last Assignment to: PA Housing Finance Agency Record Book: 737 Page: 1566
IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of
Mortgage to be executed by its duly authorized officer. (Series: 096, PHFA) [GUTSHALE]
DATED: March 8, 2013 By: PENNSYLVANIA HOUSING FINANCE AGENCY
Thomas F. Brzana, Jr.
Director of Loan Servicing
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN r
On this, the Q q ` " ^ day of ����uCr — , 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 U.
COMMQN OF PENNSY LVANIA
Notarial Seal
Kimberley A. Ayala, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires Jan. is, 2015
CERTIFICATE OF RESIDENCE OF ASSIGNEE MEMSEP, PENN SYL VANIA ASSOCIATIO of NOTARIES
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
Authorized Officer
ALL that certain tract of land with the improvements thereon erected, situate in the Second Ward of the Borough of
Carlisle, Cumberland County, Pennsylvania, bounded and described as follows;
BEGINNING at a point on the southern side of Juniper Street at the Northeast corner of Lot No I 1 A in the hereinafter
mentioned plan of Lots which point is located 120 feet from a concrete marker on the southerly side of Juniper Street;
thence North 20 degrees 40 minutes East along Juniper Street a distance of 30 feet to a point at the northwestern
corner of Lot 12A as shown said plan of lots; thence South 69 degrees 13 minutes East along Lot No. 12A a distance
of 125.30 feet to a point at lands now or formerly of Lightner; thence South 20 degrees 54 minutes West along land
now or formerly of Lightner, a distance of 30 feet to a point at the southeastern corner of Lot No 1 1 A as shown on
said Plan of Lots; thence North 69 degrees 13 minutes West along Lot No 1 1 A a distance of 125.24 feet to a point on
the southerly side of Juniper Street being the point and place of BEGINNING.
BEING all of Lot No. 12 on a Subdivision Plan for Section No. 1 of Willow Crossing as recorded in Cumberland
County in Plan Book 25, Page 90.
PARCEL 403 -22- 0485 -105
t
� if
Pennsylvania
ll iusi>niq Finance A e.xy - Accounting & Loan Servicing
211 North Front Street, P.O. Box 15057
Harrisburg, PA 17105 -5057
(800) 346 -3597 FAX (717) 780 -3899
TTY (717) 780 -1869
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
11/16/2012
RE: Account No. 1579754
DARLENE L. ANDERSON
PO BOX 694
CARLISLE, PA 17013 -0694
RE: 325 JUNIPER ST
CARLISLE, PA 17013 -2525
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 325 JUNIPER ST, CARLISLE, PA 17013 -2525, IS IN SERIOUS
DEFAULT because you have not made the monthly payments of $652.00 for 9/2012 through 11/2012
for a total of $1,956.00. Late charges and NSF charges that have accrued to this date in the amounts of
$432.02 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 $2,427.02.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the
total amount of $2,427.02, 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
property
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 /ALSW
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 if no default had
occurred However, you are not entitled to this right to cure your default more than three times in any
calendar year.
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,
-- 10", L
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
Dousing Finance A,gt =Ycy ccounting & Loan Servicing
211 North Front Street, P.O. Box 15057
Harrisburg, PA 17105 -5057
(800) 346 -3597 FAX (717) 780 -3899
TTY (717) 780 -1869
NOTICE
11/16/2012
DARLENE L. ANDERSON
PO BOX 694
CARLISLE, PA 17013 -0694
RE: Account #1579754
TO: DARLENE L. ANDERSON
325 JUNIPER ST
CARLISLE, PA 17013 -2525
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
FHAACT /dtmdocs /ALSW
* ** 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
FHAACT /dtmdocs /ALSW
Print Key Output Pa;'
5770SS1 V7R1MO 100423 PHFASYSI 11/09/12 10; go '0��
mmm m
Display Device . . . . . . QPADEVOOTO 9, c < m o In Z
User GUTSHALE MHz (T1 -J
_ 0 �, l _.,
0
SRV860 -02 _____________________ ______________ °_______________= 1 (c - 70 v g .�. > O �'
GUTSHALE PERSONAL_ 13<_PROPERTY_DATA li �. w y c a w m r ^D
z. Er
® 3 m G" CA DC C
Loan# 000157 Inv# 1 96 Asum: Y Total Due 2427.02 Due w m a w w z
CP: GUTSHALE Msg #1: 24 2: 3: 27 UnPaidBal 90329.71 LPR ® o
® m m o m In W O1
Borr 1: DARLENE L ANDERSON 717 - 38 IL a - n ti
Empl: Sal: 0 m cwo
Email: dlandy518aaol.com On -Line Reg: Y/N N
Borr 2: 000-00 -0000
Empl: Sal: 0
Email: On-Line Reg: Y/N O
Prop: 325 JUNIPER ST Number of Children: 00 y F-' Cn '
Addr: Ages: 00 ! W O �^
CARLISLE PA 170132525 Seller: 0 7 + ►iJ
Mail: PO BOX.694
Addr : y Ln N N Lry
J -
CARLISLE PA 170130694
' ,7 °
M
Legal Description:`•='
F3 =Exit F6= Additional Names and Addresses F7 =Next Loan J
na -ta FB =Prev Loan F12= Return F16 =Opt Out Info
Idlaoa�{ ulnlay ol3sawod 9002 Aja:luer 't l86 wjoj Sd R o Cn M M �-U
j z3 M0H C/) M
9a <mc o _111 Z
Cal (��z v3
0 m - j z � M W
®. M N >
o
`I�z'HS 7t7
sn� P SL6LST SD �. o M M 0 v � Z •• ,b �n �d �'
°� w y `C a y n r t - �
51 v n 3 m n c' M O H N G7
o a. m w CA Z
ETOLT Vd'agSIa H
to Tn r �
f,
C�7
-.1
T CD � u, � I'd t� I-
NOS2I�Q
CD
N
Ln
:ol passa.iPPV 9 1 0 !IJ ' L Q 10. H W vl
sa (aaj e4c3) UUaA1190 pelolalsaa •b �p
F-'
En 15
wtIIHW 031a111:130 ad tl aolnaag g > W
ON S O
❑ :MOleq ssa�ppe Ganllep aelua ' A 11 T� Z
A ❑ L L well woof luejoillp cseippe ,jenll P I '0 O ru
0esswppy b
' ( �f X 9929 6292 TTT6 9006 96TL r� 0 13=
CJI " N N
`• •____.. �Jnleuelg •0 ja m �7 W l0 rP
Ai• n!leo 1 Step •8 Moo luu esee t
• d Id) q penleDey •d
I
jegwnN 0 1 0 1PV •Z
Department of Defense Manpower Data Center Results as of: Apr -18 -2013 07:57:40
SCRA 3.0
Status Re port
Pursuant to Servicemernbers Civil Relief Act
Last Name: ANDERSON
First Name: DARLENE
Middle Name: L
Active Duty Status As Of: Apr -18 -2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA 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 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.
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
- 6 �_
Results as of : Apr -18 -2013 08:01:04
Department of Defense Manpower Data Center
SCRA 3.0
Status Report
Pursuant to Servicemembers Civil Relief Act
Last Name: WOODALL
First Name: DARLENE
Middle Name: L
Active Duty Status As Of: Apr -18 -2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the Individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or Hls/Her Unit Was Notified of a Future CalITUp 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.
W
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
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
By
Thomas F. Brzana, Ir., 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
ANDERSON 1579754
c
U.S. BANK NATIONAL ASSOCIATION AS rn� r-
IN THE COURT OF COMMON PLEAS OF ;Z) --C — v ,
TRUSTEE FOR THE "PENNSYLVNAIA HOUSING
CUMBERLAND COUNTY, PENNSYLVANIA e;n �''
FINANCE AGENCY C)
-•� C'D
Plaintiff(s) r" C.7
VS.
DARLENE L. WOODALL N /K /A DARLENE L.
ANDERSON
Defendant(s) 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.
Respectfully
5/7/13
Date Leon P. Ifaller / Jill M. Wineka
Attorney for Plaintiff
Purcell, Krug and Haller
1719 North Front Street
Harrisbur PA 17101
PA ID 157�a / 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:
-- C - LISTOMERIPRIMARY APPLICATION
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 paying)
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/Tuit. 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:
AUTHORIZATION
[/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 AS IN THE COURT OF COMMON PLEAS OF
TRUSTEE FOR THEPPENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA
FINANCE AGENCY Plaintiff(s)
VS.
DARLENE L. WOODALL N /K /A DARLENE L.
ANDERSON
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
Ronny RAnderson (� ` =
Sheriff
Jody S Smith V,
:
i
Chief Deputy � ��� PH 12 E•
Richard W Stewart �EP�'� yL,1t, � �� t,
Solicitor Orr c �FT�a�SKRir
US Bank National Association
vs.
Case Number
Darlene L Woodall 2013-2558
SHERIFF'S RETURN OF SERVICE
05/13/2013 08:46 PM - 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 325 Juniper
Street, Carlisle Borough, Carlisle, PA 17013. There were no occupants other than defendant Darlene L.
Woodall.
05/13/2013 08:46 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy to a person representing themselves to be the Defendant, to wit:
Darlene L Woodall at 325 Juniper Street, Carlisle Borough, Carlisle, PA 17013.
ANDA COBAUGH, DEPUTY
SHERIFF COST: $55.78 SO ANSWERS,
May 14, 2013 RON R ANDERSON, SHERIFF
{c)CountySuite Sheriff,Teleosoit,Inc.
U.S. Bank National Association,As : IN THE COURT OF COMMON PLEAS
Trustee For The Pennsylvania Housing : CUMBERLAND COUNTY,
Finance Agency : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-2558 c= -
Darlene Woodall N/K/A Darlene L.
Anderson U)r
Defendant : CIVIL ACTION-
MORTGAGE FORECLOSU
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012, governing the
Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned
hereby certifies as follows:
1. Defendant is 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 false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
Q
t z zc
Sig ature of Defendant's Counsel/Appoi ed Date
Legal Representativ '
S' ature of Defendant Date
U.S. Bank National Association, As IN THE COURT OF COMMON PLEAS
Trustee For The Pennsylvania Housing CUMBERLAND COUNTY,
Finance Agency PENNSYLVANIA
Plaintiff
V. Docket No. 13-2558
Darlene Woodall N/K/A Darlene L.
Anderson
Defendant CIVIL ACTION-
: MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
1,Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant,
Darlene Anderson,hereby certify that I am serving a copy of the Praecipe for Entry of
Appearance and Request for Conciliation Conference on the Plaintiff, through their attorney, on
the following date and in the manner indicated below:
U.S. First Class Mail, Postaize Pre-Paid
Leon P.Haller,Esq.
Purcell,Krug,&Haller
1719 North Front Street
Harrisburg,PA 17102
MIDPENN LEGAL SERVICES
DATE:
Jaime M. Haley, Esquire
Attorney for Defendants
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
U.S. Bank National Association, As : IN THE COURT OF COMMON PLEAS
Trustee For The Pennsylvania Housing : CUMBERLAND COUNTY,
Finance Agency : PENNSYLVANIA
Plaintiff
•
v. : Docket No. 13-2558
•
Darlene Woodall N/K/A Darlene L.
•
Anderson
Defendant : CIVIL ACTION-
: MORTGAGE FORECLOSURE., y.,,
lnar
PRAECIPE FOR ENTRY OF APPEARANCE - Orr(
:-;
TO THE PROTHONOTARY:
Please enter the appearance of MidPenn Legal Services on behalf of the Defendant,
Darlene Anderson, in the above matter, representing the Defendant in the Cumberland County
Residential Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE: �J6 ( 28( O/a A(e_Cf_eyk
�� Jaime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
fi
U.S. Bank National Association, As : IN THE COURT OF COMMON PLEAS
Trustee For The Pennsylvania Housing : CUMBERLAND COUNTY,
Finance Agency : PENNSYLVANIA
-s
Plaintiff ==-�
as c__
= '-�
unr` --
v. : Docket No. 13-2558 <> ao Q
Darlene Woodall N/K/A Darlene L. z CD
Anderson
Defendant : CIVIL ACTION-
MORTGAGE FORECLOSURE
CASE MANAGEMENT ORDER
AND NOW, this/7ih day of?&l1w, 2013, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on llu olO at o1,'1Y/ 7 in
/a at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
r
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of the
plaintiff/lender is not available by telephone during the Conciliation Conference, the
court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
DISTRIBUTION:
Jaime M.Haley,Esquire
MidPenn Legal Services
401 E. Louther Street, Ste_103
Carlisle,PA 17013
For the Defendant
✓Leon P. Haller,Esq.
Purcell,Krug, &Haller
1719 North Front Street
Harrisburg,PA 17102
For the Plaintiff
U.S. BANK NATIONAL IN THE COURT OF COMMON PLEAS OF
ASSOCIATION, as Trustee For CUMBERLAND COUNTY, PENNSYLVANIA
The Pennsylvania Housing Finance
Agency, CIVIL ACTION—LAW
Plaintiff NO. 13-2558
VS.
DARLENE WOODALL n/k/a
DARLENE L. ANDERSON, IN MORTGAGE FORECLOSURE
ORDER
AND NOW, this 9 day of August, 2013, on agreement of the parties,the
conciliation conference herein is continued generally. The matter to be relisted at the request of
either party.
BY THE COURT,
A
Kevin Hess, P. J.
.-//Leon P. Haller, Esquire
Purcell, Krug and Haller
1719 North Front Street
Harrisburg, PA 17102
For the Plaintiff
Jaime M. Haley, Esquire {
MidPenn Legal Services - =
401 E. Louther Street, Suite 103
Carlisle, PA 17013
For the Defendant
:rlm
CCfj
13
U.S. BANK NATIONAL : IN THE COURT OF COMMON PLEAS OF
ASSOCIATION, as Trustee For : CUMBERLAND COUNTY, PENNSYLVANIA
The Pennsylvania Housing Finance :
Agency, : CIVIL ACTION-LAW
Plaintiff : NO. 13-2558
vs. •
•
DARLENE WOODALL n/k/a •
DARLENE L. ANDERSON, : IN MORTGAGE FORECLOSURE
ORDER
AND NOW, this 30- day of October, 2013, at the request of the plaintiff, a
continued conciliation conference is set for Thursday, November 21, 2013, at 1:30 p.m. in
Chambers of the undersigned.
BY THE COURT,
hi_
Kevi • . Hess, P. J.
Leon P. Haller, Esquire
Purcell, Krug and Haller
1719 North Front Street
Harrisburg, PA 17102
For the Plaintiff
Jaime M. Haley, Esquire
MidPenn Legal Services
401 E. Louther Street, Suite 103
Carlisle, PA 17013
For the Defendant
err cis
:rim r- ca
C6r I'QS frla
c �
/0/3 I
U.S. BANK NATIONAL : IN THE COURT OF COMMON PLEAS OF
ASSOCIATION, as Trustee For : CUMBERLAND COUNTY, PENNSYLVANIA
The Pennsylvania Housing Finance :
Agency, : CIVIL ACTION—LAW
Plaintiff : NO. 13-2558
vs. •
•
DARLENE WOODALL n/k/a •
DARLENE L. ANDERSON, : IN MORTGAGE FORECLOSURE
ORDER
AND NOW, this Z Z 1 day of November, 2013, following conciliation conference,
this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program
and the stay entered herein is vacated.
BY THE COURT,
AZ-
K7 A. Hess, P. J.
,on P. Haller, Esquire
Purcell, Krug and Haller
1719 North Front Street
Harrisburg, PA 17102
For the Plaintiff
/Jaime M. Haley, Esquire
MidPenn Legal Services _
401 E. Louther Street, Suite 103 -� `''
rn r7
Carlisle, PA 17013
For the Defendant cn r- ry
:rlm
-r,
CD
/0 al/ 3
/77
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. 2013-02558 ? f
DARLENE L.L. WOODALL N/K/A DARLENE L.
ANDERSON, MORTGAGE FORECLOSURE .
DEFENDANT(S) y '�,
PRAECIPE �., ..-,
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
rQ
Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s)
DARLENE L. WOODALL NX/A DARLENE L. ANDERSON 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 $90,329.71
Interest $760.53
Per diem of$2.51
From 08/01/2012
To 06/01/2013
Accumulated Late Charges $404.62
Late Charges $123.30
($13.70 per month to
06/01/2013)
Escrow Deficit $79.35
5%Attorney's Commission $4,516.49
TOTAL $96,214.00
"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
Leo . Haller PA I.D. # 15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178 ovwk- .sb
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. 2013-02558
IN MORTGAGE FORECLOSURE
DARLENE L. WOODALL N/K/A DARLENE L.
ANDERSON,
DEFENDANT(S)
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on December 16, 2013 I 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. er PA 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,
HOUSING FINANCE AGENCY, PENNSYLVANIA
Plaintiff
NO.2013-62558
VS.
DARLENE L. WOODALL N/K/A DARLENE CIVIL ACTION LAW
L.ANDERSON IN MORTGAGE FORECLOSURE
Defendant
DATE OF THIS NOTICE: December 16,2013
TO:
DARLENE L.WOODALL N/K/A DARLENE L.ANDERSON
P.O.BOX 694
CARLISLE,PA 17013
DARLENE L.WOODALL N/K/A DARLENE L.ANDERSON
325 JUNIPER STREET
CARLISLE,PA 17013
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.
IWORTANT 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, 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. 2013-02558
DARLENE L. WOODALL N/K/A DARLENE L. IN MORTGAGE FORECLOSURE
ANDERSON,
DEFENDANT
NON-MILITARY AFFIDAVIT
�
� ��i
COMMONWEALTH OF PENNSYLVANIA rQ flyl
SS
COUNTY OF DAUPHIN y.c E5
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 this 3 day
of 20I
N P. HALLER, ESQUIRE
Notary bli
i
CONMg,1fi/iIEALT!I C _ViaNl;1
NO SSAL �
MARYLAND K.PERRETTI.Nc; •y Publ�
Lower Paxton Twp.,Dauphin Cou��ty
My Commission Expires Aug.a,2094
l Department of Defense Manpower Data Results as of:Jan-11-201410:26:12
Center
SCRA 3.0
�Y✓y
Status Report
Pursuant.to Servicernemben Civil Relief Act.
Last Name: WOODALL
First Name: DARLENE
Middle Name: L.
Active Duty Status As Of: Jan-11-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Dale Status Service Component
NA ,NA v f. ��No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Dale 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 His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Servlce Component
4•
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.
41a, - it
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
" The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PCO93LDR.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: 56J3B87BF09DAC0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION-LAW AT NO. 2013-02558
U.S.BANK NATIONAL ASSOCIATION,AS Total Judgment Amount $96,214.00
TRUSTEE FOR THE PENNSYLVANIA HOUSING Interest $905.31
FINANCE AGENCY, Per diem of$2.51 to sale
PLAINTIFF date 6/4/2014
Late Charges $164.40
VS. $13.70 per month to sale
date 6/4/2014
DARLENE L. WOODALL N/K/A DARLENE L. Escrow Deficit $2,946.73
ANDERSON,
DEFENDANT(S) TOTAL WRIT $100,230.44
*Plus additional interest,late charges and other costs
to date of sheriffs sale.
SALE DATE: Wednesday,June 04,2014
(PROTHONOTARY'S USE)
Pltf,Paid
Deft.Paid
Due Proth/Clerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION-MORTGAGE FORECLOSURE
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue Writ of Execution in the above captioned case.
Date: January 11,2014 -cam---.
rnco C_ -
:2t FT1 Attorney for Plaintiff -Z_
1719 North Front Street Leo aller �y, a '
Harrisburg,PA 17102 P I.D. #15700 C:D
(717)234-4178 *cam., o
=C:>
r
WRIT OF EXECUTION-M RTGAGE FORECLOSURE F'
COMMONWEALTH OF PENNSYLVANIA
S
COUNTY OF CUMBERLAND
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the ov captioned case,you are directed to levy upon and
sell the property described in the attached description kn wn as 25 JUNIPER STREET CARLISLE,PA
17013
DaterPROTHONOTARY/CLERK CIVIL DNISION
s� BY
S. �F DEPUTY
o3.•?S `` ,as-�>.�
.so ��.Dog , s3 �ILf I�loa3
-2 r ����
r
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the Second Ward of
the Borough of Carlisle,County of Cumberland and Commonwealth of Pennsylvania,bounded and
described as follows:
BEGINNING at a point on the southern side of Juniper Street at the Northeast corner of Lot No. 11 A in the
hereinafter mentioned plan of lots,which point is located 120 feet from a concrete marker on the southerly
side of Juniper Street;thence North 20 degrees 40 minutes East along Juniper Street, a distance of 30 feet to
a point at the northwestern corner of Lot 12A as shown on said plan of lots;thence South 69 degrees 13
minutes East along Lot No. 12A a distance of 125.30 feet to a point at lands now or formerly of Lightner;
thence South 20 degrees 54 minutes West along land now or formerly of Lightner,a distance of 30 feet to a
point at the southeastern corner of Lot No. 1 IA as shown on said Plan of Lots;thence North 69 degrees 13
minutes West along Lot No. I IA a distance of 125.24 feet to a point on the southerly side of Juniper Street,
being the point and place of BEGINNING.
BEING all of Lot No. 12 on a Subdivision Plan for Section No. 1 of Willow Crossing, as recorded in
Cumberland County Plan Book 25,Page 90.
HAVING THEREON ERECTED A DWELLING KNOWN AS 325 JUNIPER STREET, CARLISLE,
PA 17013
PARCEL NO. 03-22-0485-105
BEING THE SAME PREMISES WHICH Craig B. Kissinger and Jill E. Kissinger,his wife,by deed dated
May 15, 2007 and recorded May 30,2007 in Cumberland County Record Book 280 Page 909, granted and
conveyed unto Darlene L. Woodall. Darlene L. Woodall is now known as Darlene L. Anderson.
TO BE SOLD AS THE PROPERTY OF DARLENE L. WOODALL N/K/A DARLENE L. ANDERSON
ON JUDGMENT NO.2013-02558
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. 2013-02558
DARLENE L.WOODALL N/K/A DARLENE L. IN MORTGAGE FORECLOSURE
ANDERSON,
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 325 JUNIPER STREET CARLISLE,PA 17013:
1. Name and address of the Owner(s) or Reputed Owner(s): z
DARLENE L. WOODALL N/K/A rnn -�-
DARLENE L. ANDERSON �V'-- .— � '
325 JUNIPER STREET U'�
CARLISLE, PA 17013
DARLENE L. WOODALL N/K/A
DARLENE L. ANDERSON
P. O. BOX 694
CARLISLE, PA 17013
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
5. Name and address of every other person who has any record lien on the property:
NONE
J f
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
325 JUNIPER STREET
CARLISLE, PA 17013
(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 authoritie
Leo . aller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE:January 11, 2014
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
VS. NO. 2013=02558
DARLENE L.WOODALL N/K/A DARLENE L. IN MORTGAGE FORECLOSURE
ANDERSON,
DEFENDANT(S)
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE: f,
X, _ �h
That the Sheriffs Sale of Real Property (real estate) will be held:
;Q C:3
DATE: Wednesday,June 04, 2014 U';> cr%
TIME: 10:00 O'clock A.M.
Z5
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:
325 JUNIPER STREET
CARLISLE,PA 17013
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No.2013-02558 JUDGMENT AMOUNT $96,214.00
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
DARLENE L. WOODALL N/K/A DARLENE L. ANDERSON
i
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 tract of land with the improvements thereon erected, situate in the Second Ward of
the Borough of Carlisle,County of Cumberland and Commonwealth of Pennsylvania,bounded and
described as follows:
BEGINNING at a point on the southern side of Juniper Street at the Northeast corner of Lot No. 1 I in the
hereinafter mentioned plan of lots,which point is located 120 feet from a concrete marker on the southerly
side of Juniper Street;thence North 20 degrees 40 minutes East along Juniper Street, a distance of 30"feet to
a point at the northwestern corner of Lot 12A as shown on said plan of lots;thence South 69 degrees 13
minutes East along Lot No. 12A a distance of 125.30 feet to a point at lands now or formerly of Lightner;
thence South 20 degrees 54 minutes West along land now or formerly of Lightner, a distance of 30 feet to a
point at the southeastern corner of Lot No. I IA as shown on said Plan of Lots;thence North 69 degrees 13
minutes West along Lot No. I IA a distance of 125.24 feet to a point on the southerly side of Juniper Street,
being the point and place of BEGINNING.
BEING all of Lot No. 12 on a Subdivision Plan for Section No. 1 of Willow Crossing, as recorded in
Cumberland County Plan Book 25,Page 90.
HAVING THEREON ERECTED A DWELLING KNOWN AS 325 JUNIPER STREET, CARLISLE,
PA 17013
PARCEL NO. 03-22-0485-105
BEING THE SAME PREMISES WHICH Craig B. Kissinger and Jill E. Kissinger, his wife,by deed dated
May 15,2007 and recorded May 30,2007 in Cumberland County Record Book 280 Page 909, granted and
conveyed unto Darlene L. Woodall. Darlene L. Woodall is now known as Darlene L. Anderson.
TO BE SOLD AS THE PROPERTY OF DARLENE L. WOODALL N/K/A DARLENE L. ANDERSON
ON JUDGMENT NO. 2013-02558
■
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 13-2558 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 DARLENE L.WOODALL N/K/A DARLENE L.ANDERSON
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $96,214.00 L.L.: $.50
Interest PER DIEM OF$2.51 TO SALE DATE 6/4/2014-$905.31
Atty's Comm: Due Prothy: $2.25
Atty Paid: $204.53 Other Costs: LATE CHARGES-$13.70 PER
MONTH TO SALE DATED 6/4/2014-$164.40
ESCROW DEFICIT-$2,946.73
Plaintiff Paid:
Date: 1/16/14
David D.Buell,Prothonotary
(Seal}
` y: J _
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
Leon P. Haller
Purcell, Krug & Haller
1719 N. Front Street
Harrisburg, PA 17102-2392
(717) 234-4178
lhaller@bkh.com
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
Plaintiff
vs.
DARLENE L. WOODALL n/k/a
DARLENE L. ANDERSON,
Defendant
TO THE PROTHONOTARY:
(i
jn,
AY 8 pi12: 7
CLINBERL AND
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
No. 2013-02558
IN MORTGAGE FORECLOSURE
PRAECIPE
Please mark the judgment entered in the above captioned case satisfied of
record, because the mortgage has been reinstated and the default cured.
PURCELL,
HALLER
By
Leon P.Haller ID #15700
Attorney for Plaintiff
Date: May 6, 2014
amstdaqs64.ki
CAL% 19 119,11