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HomeMy WebLinkAbout13-4480 Sfip�eme Court Hof Pennsylvania Court';of Common Pleas For Prothonotary Use Only: Civil Cover: Sheet Docket No: CUMBERLAND „` County J ? _ '7 Q li t The information collected on this form is used solely 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: S E Complaint D Writ of Summons D Petition D Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff s Name: V. S . BANK NATIONAL Lead Defendant's Name: ASSOCIATION.AS TRUSTEE FOR THE PENNSYLVANIA SEAN M. CARR T HOUStNO FtNtiNCE iteENet Dollar Amount Requested: Dwithin arbitration limits I Are money damages requested? D Yes El No (check one) Ooutside arbitration limits O N Is this a Class Action Suit? Yes 0 No Is this an MDJAppeal? D Yes E No A, Name of Plaintiff /Appellant's Attorney: Leon P. Haller / Jill M. Wineka D Check here if you have no attorney (are a Self - .Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS D Intentional D Buyer Plaintiff Administrative Agencies D Malicious Prosecution D Debt Collection: Credit Card D Board of Assessment D Motor Vehicle D Debt Collection: Other D Board of Elections D Nuisance D Dept. of Transportation D Premises Liability D Statutory Appeal: Other S D Product Liability (does not include E mass tort) E3 Employment Dispute: Slander/Libel /Defamation Discrimination C D Other: D Employment Dispute: Other Zoning Board El , I D Other: O MASS TORT D Asbestos N D Tobacco D Toxic Tort - DES D Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS D Toxic Waste E] Other: D Ejectment D Common Law /Statutory Arbitration B D Eminent Domain /Condemnation D Declaratory Judgment D Ground Rent D Mandamus D Landlord/Tenant Dispute D Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY D Mortgage Foreclosure: Commercial Quo Warranto D Dental D Partition D Replevin D Legal D Quiet Title D Other: D Medical D Other: D Other Professional: Updated 1/1/2011 a Leon P. Haller, Esquire 2013 JUL 3 1 AN 9. Purcell, Krug & Haller C U MBERLAND CtiWi �Y 1719 North Front Street CU PENNSYLVANIA Harrisburg, PA 17102 71 7.234.4178 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 �t MORTGAGE FORECLOSURE Defendant I / SEAN M. CARR l3� �O 0 C( �J t tv? 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" (SERVICTO DE REFERENCIA DE ABOGADOS), (215) 238 -6300. s CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET _ CARLISLE, PA 17013 C $6 q1,6 717 - 249 -3166 z 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 SEAN M. CARR, 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 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. ACTION OF MORTGAGE FORECLOSURE SEAN M. CARR, 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, SEAN M. CARR, is an adult individual whose last known address is 5925 HIGHDALE CIRCLE, APT. A, ALEXANDRIA, VA 22310. 3. On or about, February 26, 2009, the said Defendant executed and delivered a Mortgage Note in the sum of $87,200.00 payable to MEMBERS 1 ST FEDERAL CREDIT UNION, 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 March 2, 2009 as Instrument Number 200905816 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 March 2, 2009 as Instrument Number 200905817. 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: 133 WEST LOCUST STREET, #113, 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 February 01, 2013 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $82,343.51 Interest at $15.73 per day $3,334.76 From 01/01/2013 To 08/01/2013 ( based on contract rate of 6.8750 %) Late Charges $28.64 $171.84 From 02/01/2013 to 08/01/2013 Escrow Credit ($667.17) Attorney's Fee at 5% of Principal Balance $4,117.18 TOTAL $89,300.12 * *Together with interest at the per diem rate noted above after August 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. The Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 which contained amendments to Act 91 of 1983 (35 P.S. 1680.401c et. sec .) and Pennsylvania Act 57 of 2008 which contained amendments to Act 6 of 1974 (41 P.S. 101 et. sec..) by sending to each Defendant, by certified and regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice dated April 18, 2013 is attached hereto as Exhibit "D ". 9. The Defendant has either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or has been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. 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 Service Members Civil Relief Act, 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 6.8750% ($15.73 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, KRU & 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) NOTE rr11 LOAN #:CAR1798652 FEBRUARY 26TH, 2009 CARLISLE l J rlV J PA [Date] [City] - I l./ 3 �g [State] 133 W.LOCUST ST, #113, MECHANICSBURG, I PA 17055 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 87, 200.00 (this amount is called "Principal "), plus interest, to the order of the Lender. The Lender is MEMBERS 1ST FEDERAL CREDIT UNION I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.875 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1ST day of each month beginning on APRIL 1ST, 2009 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on MARCH 1ST, 2039 1 still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 572.85 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When 1 make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. 1 may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. MULTISTATE FIXED PATE NOTE- Single Family - Fannie MaelFreddie Mac UNIFORM INSTRUMENT VMP0 3400 1101 For, (0603).00 Wolters Kluwer Financial Services Inil s: L V Form Page t of 3 i'vlO 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal 1 owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. 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. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I 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 the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. MULTISTATE FIX EO PATE NOTE - Single Family - Fannie Mae /Freddie Mac UNIFORM INSTRUMENT ENT Form 3200 1101 UMP,a VMPSN (0803).00 W o0era Nluw er financial Services Is: Page 2 0( 3 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. �� (Seal) (Seal) SEAN M CARR - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower [Sign Original Only] MULTISTATE FIXED RATE NOTE -Single Family - F aI �r Form 32001/01 Wolters Kluw ar Finaneia15enices � ! VMPSN (0803).00 By Ir1�1a15: Pape 3 of 3 � 116 -'rt 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: 16230567027UI 13 1943778 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): SEAN M. CARR Secured by the real property located at: 133 WEST LOCUST STREET #113, MECHANICSBURG, PA 17055 Municipality of: MECHANICSBURG Original Principal Amount: $87,200.00 County Recorded in: CUMBERLAND Mortgage Recorded: March 2, 2009 Instrument#: 200905816 Last Assignment to: PA Housing Finance Agency Instrument #: 200905817 IN WITNESS WHEREOF, the said Pennsylvania Housing Finance Agency, has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 106, PHFA) [CONDE] DATED: May 22, 2013 By: PENNSYLVANIA HOUSING FINANCE AGENCY Thomas F. Brzana, Jr. Director of Loan Servicing Division COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUP IN On this, th day of , 2013, before me, the undersigned officer, personally appeared Thomas F. Brzana, Jr. Director of Loan Sew_ixg Division, 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 sea]. Notary Public COMMONWEALT OF PENNSYLVANI Notarial Seal Kimberley A. Ayala, Notary Public City of Harrisburg, Dauphin County My Commission Expires San. 15, 2015 CERTIFICATE OF RESIDENCE OF ASSIGNEE MEMBER, PENNSYLVANIA ASSOCIATION 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 unit in the property known, named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.§ 3101 et seq. (the "Act "), by the recording of a Declaration dated November 27, 2007, recorded on December 7, 2007, in the Office of -the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument Number 200745678, and amended by an Amendment recorded on February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument Number 200803908, being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT, to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium, dated November 27, 2007, recorded December 7, 2007, in the Office of the " Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument Number 200745678, and aiflended by an Amendment recorded on February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument Number 200803908, and under and subject to easements and rights -of -way of record and visible by inspection. 4 Date: 4/18/2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the Program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any questions, You may call'the Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired hearing can call 717- 780 - 1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIUN OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. t ) ( ACT691 LR /dtmdocs /ALSV/ HOMEOWNER'S NAME(S): SEAN M. CARR PROPERTY ADDRESS: 133 WEST LOCUST STREET #113 THE SCHOOL HOUSE CONDOMINIUM MECHANICSBURG, PA 17055 -6359 LOAN ACCOUNT NO.: 1943778 CURRENT LENDER /SERVICER: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 15057 Harrisburg, PA 17105 -5057 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the Consumer Credit Counseling Agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the Consumer Credit Counseling Agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated Consumer Credit Counseling Agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated Consumer Credit Counseling ACT691 LR /dtmdocs /ALSV/ Agencies listed at the end of this Notice. Only Consumer Credit Counseling Agencies have applications for the Program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for Emergency Mortgage Assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (if you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 133 WEST LOCUST STREET #113, THE SCHOOL HOUSE CONDOMINIUM, MECHANICSBURG, PA 17055 -6359, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months February, 2013 thru the first of April, 2013 in the amount of $2,130.00 plus late charges that have accrued in the amount of $85.92 and other charges (inspection fees and / or attorney fees and costs in the amount of $64.00) . THE TOTAL AMOUNT DUE IS $2,279.92. This includes all payments, fees and expenses due, less any funds we are holding in suspense. HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,279.92 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash in our office, cashier's check, certified check or money order made payable and sent to: PENNSYLVANIA HOUSING FINANCE AGENCY 211 N FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105 -5057 ACT691 LR /dtmdocs /ALSV/ IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately three months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105 -5057 1- 800 - 822 -7375 717 - 614 -2518 (FAX) Contact Person: KIMBERLEY AYALA Counseling Agencies In addition to mailing Appendix B, Notice of Face -To -Face Meeting, please notify PHFA (when we are the first lien holder) of the face -to -face meeting and pending submission of application for HEMAP assistance by sending an e-mail to: Kayala@phfa.org. If you do not have access to e-mail, please call Kim Ayala at 717 - 780 -1815 and advise of the face -to -face meeting. EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. (This does not apply if your mortgage was originated under the Home Start Program.) ACT691 LR /dtmdocs /ALSV/ YOU MAY ALSO HAVE THE RIGHT • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service /CCCS of Wester Housing Alliance of York/Y Housing Resources 2000 Linglestown Road 290 West Market Street Harrisburg, PA 17102 York, PA 17401 717 -855 -2752 Maranatha Community Action Commission of Capital Region 43 Philadelphia Avenue 1514 Derry Street Waynesboro, PA 17268 Harrisburg, PA 17104 717- 762 -3285 717 - 232 -9757 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 - 334 -1518 717 - 780 -3940 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717 - 234 -6616 717 - 264 -5913 ACT691 LR /dtmdocs /ALSV/ Pennsylvania Housing Finance Agency Accounting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05 -5 05 7 (800) 346 -3597 FAX (717) 780 -3804 TTY (717) 780 -1869 NOTICE 4/18/2013 SEAN M. CARR 5925 HIGHDALE CIR APT A ALEXANDRIA, VA 22310 RE: Account #1943778 TO: SEAN M. CARR 133 WEST LOCUST STREET #113 MECHANICSBURG, PA 17055 -6359 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. Attachment: Housing Counseling List ACT691 LR /dtmdocs /ALSV/ HUD - APPROVED CREDIT COUNSELING AGENCIES 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- 930A663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 17608 -1676 Phone: 717-397-5182 ACT691 LR /dtmdocs /ALSV/ ......... .. _ _ _ V 7196 9008 9111 8541 7753 7196 9008 9111 8541 7746 3 T0: SEAN M CARR TO: SEAN M CARR 5925 HIGHDAL A 133 WEST � s 'R,EET #113 ® , THE SC � ° SSE,C OMINIUM y 1 7� MEC I� P ?R G , PA �7a0� ALEXANDRI, � 2310 - a 20 >y3 � tI' I:� A P R 1 8 201'3 i' 1•, II 1. 1� SENDER: SENDER: REFERENCE, 9 3 CO DE� CONDE',, . 1 7 °__ REFERENCE. 1943778` 7 ff SPS PS Form 3800 January 2005 'y PS Form 3800 January 2005 1, RETURN Postage .46 0 RETURN Postage . RECEIPT RECEIPT Certified Fee 3 10 Certified Fee SERVICE 3 . 10 SERVICE Return Receipt Fee Return Receipt Fee 2. 5 5 l; 2. " R I Restricted Delivery Restricted Delivery Total Postage & Fees 6.11 i; Total Postage & Fees 6 .11 ® POSTMARK OR DATE I LISPS® POSTMARK OR DATE USPS Receipt for Receipt for Certified Mail' Certified mail'" No Insurance Coverage Provided No Insurance Coverage Provided Do Not Use for International Mail Do Not Use for International Mail n A pf b b A to M 6 c O I F� ',D' L71 W � O M S 6 C+ 0 �oxwt�J h ° o `. mot' N� ,y T so to to `C rn y 9 N ° w ?C 01 ��, FI � .. c % m c_ U o F-� c m �7 i' O N m nth � o x ,� w i co H '.L'i In ro f , p m N m E H r mul m �. (1 O H o w H ` > o co 9 C ti '�� b In a' i c -4 CC I o �� fcs T ru H n f j,. us tail,. �, �� w j o,: ; 4 Hasler 04/1812 H (10 Hasler r a i I V 04I18(sC1 $O1 . 20( Ifs l �• ZIP 17101 01 s 011 D1 26019 t1 �. y'• ZIP 17101 s 011D12601 a' 1 ------------------------------ • TH IS SECTION ON D ELIVERY 2. Article Number B. Date of Delivery A. Received by (Please Print Clearly) C. Signatu Addressee Agent 7196 9005 gill X D. Is delivery 5541 7746 nt from If YES, en address different item t? ter delivery address below: Type CERTIFIED co 3- Service ID MAIL❑� C� x'E 4. Restricted Delivery? (Extra Fee) Yes = ` 1. Article Addressed to: r i' SEAN M CARR 133 WEST LOCUS E TSCOo THE SCHOOL HOUS MECHANICSBURG,PA 17055 1943778 CONDE Doinestic Return Receipt 2005 PS Form 3811, January i. .- ... ry __ dY) 6 D 1 ' . A. Re�rvl b ( Ptease Print 2, Article Nm uber = v p C, Signature Q Agent C3 Addressee' C3 Yes x \�o tfr rpa ejl],1 5 5 41 7? 53 D. Is delivery a r delivery -7 differ r� No 7 y96 90138 If YES, enter livery r� t MAII- CERTIFIED g, Service Type �Yes ` Extra Fee) 4, Restricted D eiivery? ( .. ddre Article A ed to: Cp,RR 1 ' M 5925 gIGHI)ALE CIR AP p ' ALEXP NDRIA e VA 22310 CONDE 19 43778 Domestic Return Receipt January 2005 i PS Form 3811, - Department of Defense Manpower Data Center Results as of: Jun -21- 201308:36:52 SCRA 3.0 / Pursuant to Servicememben Civil Relief Act Last Name: CARR First Name: SEAN Middle Name: M Active Duty Status As Of: Jun -21 -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 Leff 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. AN Y , 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 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 CARR 1943778 u a — c� tr , Fri 70 �— C/i , CD < U.S. BANK NTIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS OF z' c°? AS TRUSTEE FOR THE I'PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA =� kD `4 HOUSING FINgCEtiAr -f NCY VS. SEAN M. CARR I Defendant(s) l3 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 s tted: 7/30/13 Date Leon P. taller / Jill M. Wineka Attorney for Pl inftiff Purcell, Krug a d Haller 1719 North Fron Street Harrisburg PA 17101 PA ID 15706 / 58802 v . U.S. BANK NATIONAL ASSOCIATION AS ; IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE PlaintI�s) VS. SEAN M. CARR 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 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 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? CO-B Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? INFORMATI 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: Amount owed: Value: Year: Automobile #2 #2: Model: Amount owed: Value: Yea r: Other transportation (automobiles boats motorcycles) Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Y 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 paving) EXPENSE AMOUNT EXPENSE Mortgage AMOUNT 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 n No n If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: .- Phone: I /We, named authorize the above 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY w Ronny R Anderson i1 FMD- �° ��"� ' f 7 Sheriff l.i .[HE IFJ DTHO�1; Ire � � Jody S Smith #. Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor ' F PENNSYLVANIA US Bank National Association Case Number vs. 2013-4480 Sean M Carr SHERIFF'S RETURN OF SERVICE 0810112013 03:36 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 133 West Locust Street,#113, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant. 08/01/2013 03:36 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: Sean M Carr, 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 133 West Locust Street,#113, Mechanicsburg Borough, Mechanicsburg, PA 17055. Per the Mechanicsburg Postmaster the defendant moved and left no forwarding address. SHERIFF COST: $65.30 SO ANSWERS, August 30,2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Eno. 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 SEAN M. CARR Defendant No. 2013-04480-CIVIL PRAECIPE TO REINSTATE c7 r rn w o in .1-20 —+ x TO THE PROTHONOTARY: tor-- I1 , -< : Kindly reinstate the complaint on the above captioned matter. c --- 'f' c c DATE: September 27, 2013 PURCELL, KRUG, & HALLER BY Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 ukrispci 6811 e,Ic NFL"' i 'z* aa(1,a71 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ti,xr t 1Ur bt, Lo +, Jody S Smith Chief Deputy PC/- ,;:;7* - . -13 I<'C 115 pH 3: - , Richard W Stewart ;� Solicitor U BERLAND Cu I PENNSYLVANIA US Bank National Association Case Number vs. 2013-4480 Sean M Carr SHERIFF'S RETURN OF SERVICE 10/08/2013 08:39 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: Sean M Carr, 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 30 Briarwood Lane Apt. A, South Middleton, Carlisle, PA 17015. Deputies were advised by defendant's father that the defendant is now in Fairfax County Detention Center. SHERIFF COST: $34.78 SO ANSWERS, October 09, 2013 RONR ANDERSON, SHERIFF T:e,eoscl•, U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE SEAN M. CARR Vele.ndant No. 2013-04480-CIVIL RETURN OF SERVICE • TO THE PROTHONOTARY: ` 'rn cn , Kindly file the Out of State Service Return on the above captioned matter. DATE: November 11, 2013 PURCELL, KRUG, & HALLER BY Leon P. llaller 1719 North Front eet Harrisburg, Pa 7102 Attorney f. laintiff Attorney )# 15700 OFFICE OF THE SHERIFF COUNTY OF FAIRFAX Mark W. Sites, Sheriff 4110 Chain Bridge Road Fairfax,Virginia 22030 Phone(703)246-3227 Fax(703)691-9513 AFFIDAVIT OF SERVICE COMONWEALTH OF VIRGINIA COUNTY OF FAIRFAX RE: U.S. Bank National Association,As Trustee for the Pennsylvania Housing Finance Agency VS: Sean M. Carr Before me,the undersigned authority,personally appeared PFC AE Boyd, a person competent to make oath, and who by me being duly sworn, deposes and says: That this Complaint in Mortgage Foreclosure,Notice of Residential Mortgage Foreclosure Diversion Program, Request for Conciliation Conference and Worksheet,came to hand on 10/23/2013 at 1:20 P.M.,and executed by delivering Sean M. Carr, IN PERSON at Fairfax County Adult Detention Center at 10520 Judicial Drive,Fairfax, VA 22030, County of Fairfax, Commonwealth of Virginia, on 10/24/2013 at 10:40 A.M., a true copy of the above mentioned process. MARK W. SITES, SHERIFF FAIRFAX COUNTY, VIRGINIA 000 ow.4, Deputy Sheriff r i t °�e,me this S day of LIF.. NNry Public �y My commission Expires: COMM',3S1ON NUMBER . Off. 7362429 ;•/�• „'1, EALTIA OF /'0, 11 I110°. 'E lLE:1J-OF fl QTl f ` THE PROTF1 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 2013 NOV 1 8 Pli 3• tt 6 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 CUM BE S L COUNTY (717)234-4178 PE �f SYVANIA 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 -04480 CIVIL SEAN M. CARR : 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 July 31, 2013 . 2 . The mortgaged property is vacant 3 . Service of the Complaint was made on October 24 , 2013 . 4 . The Notice of Residential Mortgage Foreclosure Diversion Program was served on Defendant, Sean M. Carr , on September 24 , 2013 , at The Fairfax Adult Detention Center , 10520 Judicial Drive, Fairfax, Virginia 22030 . 5 . The property is not residential real property within the meaning of the Mortgage Foreclosure Diversion Program in that Defendants do not reside at the property and it is vacant . 6 . Plaintiff requests that the stay imposed by the Mortgage Foreclosure Diversion Program 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: November 13 , 2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a1���ty of ealtr?br��,y� • Jody S Smith Chief Deputy C" : Richard W Stewart Solicitor OF:Ica OF ME VERIFF US Bank National Association Case Number vs. 2013-4480 Sean M Carr SHERIFF'S RETURN OF SERVICE 10/08/2013 08:39 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: Sean M Carr, 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 30 Briarwood Lane Apt.A, South Middleton,Carlisle, PA 17015. Deputies were advised by defendant's father that the defendant is now in Fairfax County Detention Center. SHERIFF COST: $34.78 SO ANSWERS, • October 09,2013 RONR ANDERSON,SHERIFF • • (c)CountySuite Sheriff,Teleosoft,Inc. N SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson • Sheriff Jody S Smith •40." at rrrttirp4.4 Chief Deputy :.. a • Richard W Stewart • Solicitor OFFICE OFTVE SKRIFF US Bank National Association • vs. Case Number Sean M Carr 2013 4480 • SHERIFF'S RETURN OF SERVICE 08/01/2013 03:36 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 133 West • Locust Street,#113, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant. 08/01/2013 03:36 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: Sean M Carr, 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 133 West Locust Street,#113, Mechanicsburg Borough, Mechanicsburg, PA 17055. Per the Mechanicsburg Postmaster the defendant moved and left no forwarding address. SHERIFF COST: $65.30 SO ANSWERS, August 30, 2013 RONR ANDERSON, SHERIFF • • (c)CountySuilo Sheriff,Teleosoff.Inc. • 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: November 13 , 2013 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U 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 - 04480 CIVIL SEAN M. CARR : IN MORTGAGE FORECLOSURE Defendant CERTIFICATE OF SERVICE I , Leon P . Haller , the undersigned, Attorney for Plaintiff , hereby certify that I served on the 13th day of November , 2013 , a copy of the Petition to Lift Stay Imposed by Mortgage Foreclosure Diversion Program upon each of the following persons at the address shown below: Sean M. Carr Fairfax County Adult Detention Center 10520 Judicial Drive Fairfax, VA 22030 Leon P . Haller Dated : November 13 , 2013 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 - 04480 CIVIL SEAN M. CARR IN MORTGAGE FORECLOSURE Defendant O R D E R AND NOW, this L O� day of IUovt-44-r 2013 , upon consideration of Plaintiff Petition to Lift Stay and Plaintiff representing the property to be vacant and not owner occupied, 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. Ld 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. 2013-04480-CIVIL t"� N SEAN M. CARR, - DEFENDANT(S) MORTGAGE FORECLOSURE rC PRAECIPE •- TO THE PROTHONOTARY OF THE WITHIN COUNTY: i Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) SEAN M. CARR 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 $82,343.51 Interest $3,334.76 Per diem of$15.73 From 01/01/2013 To 08/01/2013 Late Charges $171.84 ($28.64 per month to 08/01/2013) Escrow Credit -$667.17 5%Attorney's Commission $4,117.18 TOTAL $89,300.12 **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 L,4001. 11er PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 cuvve hi iob fflaI/eJ 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. 2013-04480-CIVIL IN MORTGAGE FORECLOSURE SEAN M.CARR, DEFENDANT(S) CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on December 5, 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 '. 'aller 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 HOUSING CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, Plaintiff NO.2013-04480-CIVIL VS. CIVIL ACTION LAW SEAN M. CARR IN MORTGAGE FORECLOSURE Defendant DATE OF THIS NOTICE: December 5,2013 TO: SEAN M. CARR 30 BRIARWOOD LANE,APT. A CARLISLE, PA 17015 SEAN M. CARR 133 WEST LOCUST#113 MECHANICSBURG,PA 17055 SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX,VA 22030 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 PURCE ,, 'UG & •LLER By LEON P.HALLER, •'one for Plaintiff I.D. # 15700 1719 N.Front St.,Harrisburg, PA 17102 (717)234-4178 ,d Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW AT NO. 2013-04480-CIVIL U.S.BANK NATIONAL ASSOCIATION,AS Total Judgment Amount $89,300.12 TRUSTEE FOR THE PENNSYLVANIA HOUSING Interest $4,747.20 FINANCE AGENCY, Per diem of$15.73 to sale PLAINTIFF date 6/4/2014 Late Charges $286.40 VS. $28.64 per month to sale date 6/4/2014 SEAN M. CARR, Escrow Deficit $1,845.13 DEFENDANT(S) TOTAL WRIT $96,178.85 *Plus additional interest,late charges and other costs to date of sheriff's 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: February 18, 2014 rri -rY m Attorney for Plaintiff d ' r 1719 North Front Street 'eon P. Haller r\.)Harrisburg, PA 17102 PA I.D. #15700 (717)234-4178 WRIT OF EXECUTION-MORTGAGE FO' CLOSURE =-+ .p- COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the al).ve c.ptioned case,you are directed to levy upon and sell the property described in the attached description known a- 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG,PA 17055 Date: PROTHONO RY/CLERK CIVIL DIVISION (C) BY 01 PUTY ��. a.�S /03 7S<< St)(--c- /03 , 63(113'Si Tel ° l ) 9 � , 3 �k� P--k-scr . ALL THAT CERTAIN UNIT in the property known,named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S. Section 3101 et seq (the"Act") by the recording of a Declaration dated November 27,2007,recorded on December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908,being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate undivided interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium, dated November 27, 2007, recorded December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, and under and subject to easements and rights of way of record and visible by inspection. BEING A CONDOMINIUM UNIT KNOWN AS: 133 WEST LOCUST STREET,UNIT 113, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Rovegno Real Estate Partners,by deed dated February 26, 2009 and recorded March 2,2009 in Cumberland County Instrument No. 200905815, granted and conveyed unto Sean M. Carr. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013-04480-CIVIL ASSESSMENT NO. 16-23-0567-027-U-113 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. 2013-04480-CIVIL SEAN M.CARR, IN MORTGAGE FORECLOSURE DEFENDANT _ -o-• -fl .Ca V.:.) ;= AFFIDAVIT IDAVIT . COMMONWEALTH OF PENNSYLVANIA • SS COUNTY OF DAUPHIN I,LEON P.HALLER, Attorney for the Plaintiff in the above matter,being duly sworn according to law, hereby certify that the Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners'Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. Sworn to and subscribed before me this §-day • of �- 20 /y • / LEON '. -/ LER,ESQUIRE if AA ot. ��. •c COMMONW ALV.10: MARYLAND 41 FERR7 P u;biic f Lower Pnxton Twp.,vu .;:^C arly My Comm ssi .1 Explac Aug.V,201.:. 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. 2013-04480-CIVIL -: c=) SEAN M.CARR, IN MORTGAGE FORECLOSURE y -- . DEFENDANT i e N _-- .) r' U�r . 4 C NON-MILITARY AFFIDAVIT -, ,-_ rc--, COMMONWEALTH OF PENNSYLVANIA `1`' - . 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 me his day • of 20 ■ 0.°I.P / - LE&-,-' ALLER, ESQUI�' / / :� otary P ilic Lc^ e .nr Pub;; P� 'i° �.' ,,w, .,6,.upii n Court My C'�^a<:',fss:on Expires Aug.8,2014 Department of Defense Manpower Data Center Results as of:Feb-17-201409:51:38 AM SCRA 3.0 t a,a ' i4, ; Status Report s . Pursuant to Servicememrs Civil Relief Act Last Name: CARR First Name: SEAN Middle Name: M Active Duty Status As Of: Feb-17-2014 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 Da a 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. )11)11201# �. p lail/(411117**4.°' 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/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: P7X005E8N079V70 _ 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. 2013-04480-CIVIL SEAN M.CARR, 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 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 j;.� SEAN M. CARR ~cam ra' �� 133 WEST LOCUST STREET UNIT 113 �`q-; MECHANICSBURG, PA 17055 SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX, VA 22030 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): Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 133 WEST LOCUST STREET UNIT 113 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 authoritie Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:February 18, 2014 w 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. 2013-04480-CIVIL SEAN M. CARR, IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 _Y s. TAKE NOTICE: rn rn �--, c_- That the Sheriffs Sale of Real Property(real estate) will be held: -+o c� DATE: Wednesday,June 04, 2014 =c, 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: 133 WEST LOCUST STREET UNIT 113 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. 2013-04480-CIVIL JUDGMENT AMOUNT$89,300.12 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: SEAN M. CARR 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 UNIT in the property known,named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S. Section 3101 et seq(the "Act") by the recording of a Declaration dated November 27, 2007,recorded on December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate undivided interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium,dated November 27, 2007, recorded December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, and under and subject to easements and rights of way of record and visible by inspection. BEING A CONDOMINIUM UNIT KNOWN AS: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Rovegno Real Estate Partners,by deed dated February 26,2009 and recorded March 2,2009 in Cumberland County Instrument No. 200905815, granted and conveyed unto Sean M. Carr. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013-04480-CIVIL ASSESSMENT NO. 16-23-0567-027-U-113 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-4480 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 SEAN M.CARR (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: $89,300.12 L.L.: $.50 Interest $4,747.20-PER DIEM OF$15.73 TO SALE DATE 6/4/2014 Atty's Comm: Due Prothy: $2.25 Atty Paid: $260.58 Other Costs: LATE CHARGES-$286.40-$28.64 PER MONTH TO SALE DATE 6/4/2014-ESCROW DEFICIT-$1,845.13 Plaintiff Paid: Date: 2/21/14 / ~_ David D.Bu-11, Prothonota (Seal) = �5/ ��_ _ /!/_ _ 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 TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF SEAN M. CARR, VS. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL MORTGAGE FORECLOSURE MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129.2(c)(1)(i)(C) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by Defendant located at 133 WEST LOCUST STREET, MECHANICSBURG, PA 17055. 2. Defendant SEAN M. CARR was personally served with the Complaint, October 24, 2013 at Fairfax Adult Detention Center, Fairfax, VA . However, the Sheriff's office has been unable to serve Defendant SEAN M. CARR with the Notice of Sale at the property, or locate at any new forwarding addresses found for the Defendant. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, WestLaw People Finder, Inmate Locator, and also by attempting to obtain a phone number for the Defendant. 4. The Sheriff posted the Defendant's property with a Notice of Sale or Handbill, March 24, 2014, pursuant to Rule 3129.2(b) 5. The following addresses have been attempted with the following results: 133 West Locust Street, Unit 113, Mechanicsburg, PA - property vacant 30 Briarwood Lane, Carlisle, PA 17013- Several attempts have been made. The Sheriff's office Reported no vehicles were in the driveway and there was no answer at the door. There was No response to call back cards left at the residence. The Cumerland County Sheriff's office sent notice to the Defendant at Fairfax County Adult Detention Center, 10520 Judicial Drive, Fairfax, VA 22030. The mail was returned "Return of Sender". 6. The Notice of Sheriffs Sale will be published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale pursuant to Rule 3129.2(d) 7. Plaintiff requests an Order approving service by sending copies of the Notice by registered/certified mail to Defendant SEAN M. CARR'S last known addresses pursuant to Pennsylvania Rule of Civil Procedure 3129(C) and PaRCP 430. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. BY Leon P. Haller Attorney for Plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 Attorney ID #15700 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF SEAN M. CARR, DEFENDANT VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant SEAN M. CARR in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. The Defendant is not known at 133 West Locust Street, #113, Mechanicsburg, PA 17055. The postmaster consider 30 Briarwood lane, Carlisle, PA to be a good address. However, several attempts were made to serve the Defendant at this address and there was no response at the residence. X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant. Plaintiff's Attorney attempted to contact the Defendant at 717-249-1946, however, there was no answer. X That he contacted WestLaw People Finder, a national credit service, with respect to the location of the Defendant. The last known address listed is 30 Briarwood Lane, Carlisle, PA. The process server was unable to serve the Defendant at this address. X That he has conducted a search through Inmate Locator. The Defendant is no longer incarcerated at Fairfax Adult Detention Center and there were no inmates located by the name of Sean M. Carr.. Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. PURCELL, KRUG, & HALLER BY: Sworn to and subscribed befog un this 3/ti1 day � ,2014 Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff Attorney ID# 15700 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BONITA E PRUSSACK Notary Public HARRISBURG CITY; DAUPHIN COUNTY My Commission Expires Sep 26.2017 Commonwealth of Pennsylvania In the Court of Common Pleas of Cumberland County CASE NO.: 2013-04480—CIVIL AFFIDAVIT OF SERVICE U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency vs. Sean M. Carr Commonwealth of Pennsylvania County of Dauphin ss. I, Todd Kepner, a competent adult, being duly sworn according to law, depose and say that at 12:46 PM on 05/19/2014, I non—served Sean M. Carr at 133 West Locust Street, #113, Mechanicsburg, PA 17055 in the manner described below: a true and correct copy of Notice of Sheriff's Sale of Real Estate Pursuant to Pennsylvania Rule of Civil Procedure 3129.1 issued in the above captioned matter. Comments/Prev. Attempts: The call box said the number was disconnected. A white female office person with brown hair, 45 years of age, 5' 08", 140 lbs. stated the apartment has been vacant for about 2 months. Sworn to and subscribed before me on this , 20A. d-`" day of NOTARY PPBLIC COMINOivWW Litt OF PENNSYLVANIA Notarial Seal Shinkowsky, Notary Public Lo = Paxton Twp., Dauphin County My Commission Expire Sept. 28, 2014 Member. Pennsvivania Association cF Notaries X Todd Kepner Shinkowsky Investigations PO Box 126538 Harrisburg, PA 17112 (800) 276-0202 Atty File#: - Our File# 31800 Law Firm: Purcell, Krug and Haller Address: 1719 North Front Street, Harrisburg, PA, 17102-2392 Telephone: (717) 234-4178 Commonwealth of Pennsylvania In the Court of Common Pleas of Cumberland County CASE NO.: 2013-04480—CIVIL AFFIDAVIT OF SERVICE U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency vs. Sean M. Carr Commonwealth of Pennsylvania County of Dauphin ss. I, Robert Calantropio, a competent adult, being duly sworn according to law, depose and say that at 10:13 AM on 05/03/2014, I non—served Sean M. Carr at 30 Briarwood Lane, Carlisle, PA 17013 in the manner described below: a true and correct copy of Notice of Sheriff's Sale of Real Estate Pursuant to Pennsylvania Rule of Civil Procedure 3129.1 issued in the above captioned matter. Comments/Prev. Attempts: 04/18/2014 6:10 PM — No answer. No lights were observed illuminated within the residence. There was a white Ford 4x4 pickup truck with PA registration YSV5720 in the driveway. There were two vehicles visible in the garage through the side window, a car and another SUV (neither the plates, make or model could be made out due to the garage being dark). 04/19/2014 12:40 PM — No answer. No lights were observed illuminated within the residence. No vehicles were parked in the driveway. 04/21/2014 6:47 PM — No answer. No lights were observed illuminated within the residence. No vehicles were parked in the driveway. 04/23/2014 9:20 PM — No answer. No lights were observed illuminated within the residence. No vehicles were parked in the driveway. 05/01/2014 5:30 PM — No answer. No lights were observed illuminated within the residence. No vehicles were parked in the driveway. 05/03/2014 10:13 AM — No answer. No lights were observed illuminated within the residence. No vehicles were parked in the driveway. Sworn to and subscribed before me on this frGty , 20LL. "74 day of NOTARY PU$LIC COMMONIi+1 d Th OP PENNSYLVANIA Notarial Seal John 'iLninkowsky, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Sept. 28, 2014 Member. Pennsvly n'a Aernr 1'tian of Notaries Law Firm: Purcell, Krug and Haller Address: 1719 North Front Street, Harrisburg, PA, 17102-2392 Telephone: (717) 234-4178 x Robe t Calantropio Shinkowsky Investigate s PO Box 126538 Harrisburg, PA 17112 (800) 276-0202 Atty File#: P01455/40003-13 - Our File# 31230 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY US Bank National Association vs. Sean M Carr Case Number 2013-4480 SHERIFF'S RETURN OF SERVICE 02/27/2014 Ronny R. Anderson, Sheriff, being duly sworn according to Iaw, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mai!ed a notice of the action bycert/fimdmail, return receipt requested, hothe within named Defendant, to wit: Sean M. Carr at Fairfax County Adult Detention Center, 10520 Judicial Drive, Fairfax, VA 22030. 08/24/2014 03:53 PM - Deputy Ryan Burgett, 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 133 West Locust Street Unit 113, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 04/15/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he mailed a true copy of the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, by Certified K8ai|, Return Receipt Requaxted, to the within named Defendant, to wit: Sean M. Carr at Fairfax County Adult Detention Center, 10520 Judicial Drive, Fairfax, VA 22030, and said item was returned to the Cumberland County Sheriffs Office unopened and marked as "Return to Sender on 4/14/14, return receipt card was detached from the item. cab. SHERIFF COST: $954.24 SO ANSWERS, April 15, 2014 RONNYRANDERSON, SHERIFF wCounlySu,leSMeriff, Tejeosuinc February 28, 2014 POSTMASTER MECHANICSBURG, PA 17055 City, State, Zip Code PURCELL KRUG & HALLER 1719 N. FRONT STREET HARRISBURG, PA 17102-2392 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address of a boxholder for the following SEAN M. CARR Address: 30 BRIARWOOD LANE, A. A, CARLISLE, PA 17013 NOTE: The name and last known-addr egured fot:_ctzange..of-address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.5(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manuel 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party except a corporation acting pro se must cite statute): NOT APPLICABLE 3. The names of all known parties to the litigation: SEAN M. CARR, Defendant; U.S. BANK NATIONAL ASSOCIATION; AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff 4. The court in which the case has been or will be heard: CUMBERLAND COUNTY COURT OF COMMON PLEAS 5. The docket or other identifying number if one has been issued: 2013 -04480 -CIVIL 6. The capacity in which this individual is to be served (e.g. defendant or witness) DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,0000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I Certify that the above info on is true and that the address information is needed and will be used solely for connection with actual or prospective litigation. Service of le Signature Leon P. Haller, Esquire Printed Name BOXHOLDER'S POSTMARK Not known at address given. Moved. Left no forwarding address. Ntlsuch address 6o29 g5 Pin 0(t. SE.20 Address: 1719 N. Front Street Harrisburg, PA 17102 POST OFFICE USE ONLY No Change of address order on file NAME and STREET ADDRESS • or February 28, 2014 POSTMASTER MECHANICSBURG, PA 17055 City, State, Zip Code PURCELL KRUG & HALLER 1719 N. FRONT STREET HARRISBURG, PA 17102-2392 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address of a boxholder for the following SEAN M. CARR Address: 133 WEST LOCUST STREET, #113, MECHANICSBURG, PA 17055 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.5(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manuel 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): ATTORNEY 7. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party except a corporation acting pro se must cite statute): NOT APPLICABLE 8. The names of all known parties to the litigation: SEAN M. CARR, Defendant; U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff 9. The court in which the case has been or will be heard. CUMBERLAND COUNTY COURT OF COMMON PLEAS 10. The docket or other identifying number if one has been issued: 2013 -04480 -CIVIL 11. The capacity in which this individual is to be served (e.g. defendant or witness) DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,0000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I Certify that the above inform Service of legal proc Signature Leon P. Haller, Esquire Printed Name n is true and that the address information is needed and will be used solely for nection with actual or prospective litigation. Address: 1719 N. Front Street Harrisburg, PA 17102 BOXHOLDER'S POSTMARK SNot known at address given. • Moved. Left no forwarding address. No such address POST OFFICE USE ONLY No Change of address order on file. NEW ADDRESS or NAME and STREET ADDRESS • Westlaw SSN: 177-68-XXXX SSN issued in PA in 1987-1989 Additional SSN(s): 156-92-XXXX Phone: 717-249-1946 717-461-2277 717-506-0395 Year of Birth: 1985 Age: 28 RiskFlags! Permissible lise(s) SEAN M CARR 30 BRIARWOOD LN CARLISLE, PA 17015-7900 As of 4/17/2014 10:53:43 AM Page 1 'S ri = 1431Intelinfl C. c lt'rat['. u. qrLphicei trrn Iu'.c, of your rcpr)rt. Permissible Use Selection - For use in complying with Federal, State or local laws, rules and other applicable legal requirements - GLB Permissible Use Selection - For use in connection with a civil, criminal or arbitral legal proceeding or legal research - DPPA Permissible Use Selection - Use in connection with a non-commercial purpose - VOTERS Possible. Name Variations CARR, SEAN M CARR, SEAN Possible Previous Other Addresses. 30 BRIARWOOD LN 30 BRIARWOOD LANE 5925 HIGHDALE CIR APT A 5925 HIGHDALE APA CIR 950 WALNUT BOTTOM RD 133 W LOCUST ST APT 113 118 S BALTIMORE AVE 5925 HIGHDALE CI 30 BRIARWOODLN CARLISLE, PA 17015 CARLISLE, PA 17013 ALEXANDRIA, VA 22310 ALEXANDRIA, VA 22310 CARLISLE, PA 17015 MECHANICSBURG, PA 17055 MOUNT HOLLY 17065 SPRINGS, PA ALEXANDRIA, VA 22310 CARLISLE, PA 17015 717-249-1946 717-249-1946 © 2014 Thomson Reuters. No Claim to Orig. US Gov. Works. Inmate Locator - Search for an inmate Page 1 of 1 Please Enter Criteria to search for an Inmate. If you are having problems finding an inmate, please enter only the inmate's last name and try your search again. - searcn criteria Last Name: CARR Inmate Number: First Name: FEAN Middle Name: Sex: -ALL- Race: -ALL- �► Committing County: -ALL- Location: -ALL- Citizenship: -ALL- DOB (yyyymmdd) Age 1. - Sort By o Name r- , Inmate Number Race Committing County Location Date Of Birth Find Inmate http://inmatelocator.cor.state.pa.us/inmatelocatorweb/ 2/28/2014 Inmate Locator - Search results Page 1 of 1 Inmate Locator Results No inmate found according to the requested search criteria. Please click here to search again. If you have problems finding an inmate, please contact the Support Team. Jump to search page http://inmatelocator.cor.state.pa.us/inmatelocatorweb/Criteria.aspx 2/28/2014 Commonwealth of Virginia - Department of Corrections - Offenders, Offender Locator Page 1 of 2 Agencies Governor 0 Search Virginia.Gov Home > Offenders > Offender Locator Contact Us 1 Search this Site Sut About Us Offender Locator Search Results Victim Services No Offenders Match Your Search Criteria Offenders Facilities Community Corrections Career Opportunities Procurement Forms Resources and Links Board of Corrections Virginia Parole Board 0 If you want to send money to an offender, please visit our JPay Offender Accounts page to learn more information or visit the JPay website to transfer funds. « New Search These records are updated once per day. Information is subject to change without notice. For assistance, please contact the Offender Management Unit. cps View VADOC Expenses View eVA Public Reports (external site) Return to Top t http://vadoc.virginia.gov/offenders/locator/results.aspx K2/18/2014 Commonwealth of Virginia - Department of Corrections - Offenders, Offender Locator Page 2 of 2 Contact Us Organizational Chart (pdf) Web Policy FOIA Notice (.pdf) COV Outlook Additional software may be required to view some of the documents on this website. .PDF — Adobe Acrobat Reader .DOC, .DOCX — Word Viewer .XLS, .XLSX — Excel Viewer © Virginia Department of Corrections WAI Level AA Compliant http://vadoc.virginia.gov/offenders/locator/results.aspx 2/18/2014 VINELink ver. 2.0 Page 1 of 1 • Horne English J Espanol • Search & Register • Local Victim ResourcesOffender • Map Virginia Statewide VINE VINE Service Number : (800) 467-4943 TTY : (866) 847-1298 No offenders matching your criteria were found Select the agency that you would like to search. 0 All Agencies Department of Corrections Choose Agency Enter the Offender ID or Offender's First and Last Name. Offender ID: - or - *Last Name: carr Partial last name search .First Name: sean Note that the first name can be a partial search, entering "JO" will match "JOHN", "JOE" etc. •Indicates Required Field Enter the following information if known. Date of Birth: 17-1 mm/dd/yyyy (4 -digit year is required) Age Range: search Disclaimer: This Web Site is being provided as a service to victims of crime by Appriss Incorporated. The information contained on the site is for personal use and any commercial use of this information is strictly prohibited. You may not collect, sell, offer for sale, modify, reproduce, display, publicly perform, import, distribute, retransmit or otherwise use the content from this Web Site in any way, without the express written permission of Appriss Incorporated. Appriss Inc. ©1997-2014. https://www.vinelink. com/vinelink/searchResultsAction.do?searchType=offender&siteld=... 4/17/2014 Inmate Locator Page 1 of 1 A -Z Topics Site Map FOIA Search bop.gov Home First SEAN About Us 1 Inmates Locations Jobs Find an inmate. Business Resources Locate the whereabouts of a federal inmate incarcerated from 1982 to the present. Middle M 0 Results for search SEAN M CARR About Us About Our Agency About Our Facilities Historical Information Statistics Inmates Find an Inmate Communications Custody & Care Visiting Voice a Concern Find By Number Last CARR Find By Name Race About the inmate locator & record availability Locations List of our Facilities Map of our Locations Search for a Facility Jobs Life at the BOP Explore Opportunities Current Openings Our Hiring Process Contact Us I FOIA I No FEAR Act I Privacy Policy i Information Quality I Website Feedback USA.gov l Justice.gov i Open Government http://www.bop.gov/ ateloc/ Business Acquisitions Solicitations & Awards Reentry Contracting Age Clear Form Resources Policy & Forms News Articles Publications Research & Reports Sex Contact Us I Search Resources For,,. Victims & Wdnesses Employees Ex -Offenders Media Reps 2/28/2014 VERIFICATION I, Leon P. Haller, verify that the statements made in the foregoing Motion for Service of Notice of Sale 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 Attorney for Plaintiff PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney ID #15700 Dated: June 3, 2014 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF SEAN M. CARR, DEFENDANT VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to -wit, this 5'day of 7,14,E , 2014, upon consideration of the Plaintiffs Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED that service of the Notice of Sale as required by Pennsylvania Rule of Civil procedure 3129.2(c)(1)(i)(C) be made upon Defendant SEAN M. CARR by mailing of copies of the Notice by ordinary and Certified mail to the Defendant's last known addresses at 133 West Locust Street, #113 Mechanicsburg, PA 17055 and 30 Briarwood Lane, Carlisle, PA 17013. ce, fyz_, t,.. .9.t.) uft_. Lis/1Y U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on A 101cp la3If- , 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: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX, VA 22030 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 By P '+ , KRUG & HALLER ttorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. JILL M. WINEKA LISA RYNARD SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX, VA 22030 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 LAW OFFICES Well,gag (1r X114/14 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533-3836 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. eon P. Haller PA Attorney for Plaintiff 5700 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, TAKE NOTICE: DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 04, 2014 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: 133 WEST LOCUST STREET UNIT 113 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. 2013 -04480 -CIVIL JUDGMENT AMOUNT $89,300.12 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: SEAN M. CARR 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 SHERIFFS 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 UNIT in the property known, named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S. Section 3101 et seq (the "Act") by the recording of a Declaration dated November 27, 2007, recorded on December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate undivided interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium, dated November 27, 2007, recorded December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, and under and subject to easements and rights of way of record and visible by inspection. BEING A CONDOMINIUM UNIT KNOWN AS: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Rovegno Real Estate Partners, by deed dated February 26, 2009 and recorded March 2, 2009 in Cumberland County Instrument No. 200905815, granted and conveyed unto Sean M. Carr. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013 -04480 -CIVIL ASSESSMENT NO. 16-23-0567-027-U-113 ,7196 9008 9111 3021 7629 7196 9008 9111 3021 7636 TO: SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 SENDER: P01455/40003 REFERENCE: NOS 06/04/14 PS Form 3800, January 2005 RETURN RECEIPT SERVICE Postage Certified Fee Return Receipt Fee Restricted Delivery Total Postage & Fees USPS• Receipt for Certified Mail'" No Insurance Coverage Provided Do Not Use for International Mat 9 2.70 5.05 TO: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SENDER: P01455/40003 REFERENCE: NOS 06/04/14 PS Form 3800 Janua RETURN RECEIPT SERVICE 2005 Postage Certified Fee Return Receipt Fee Restricted Delivery Total Postage & Fees uses• Receipt for Certified Mail" No it surance Coverage Provided Do Not the for International Mai 7196 9008 9111 3021 7612 TO: SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX, VA 22030 SENDER: P01455/40003 REFERENCE:. NOS 06/04/14 PS Form 3800, Janua ry 2005 3 30 2.70 5.05 POS icof cc • C ck RETURN RECEIPT SERVICE Postage Certified Fee Return Receipt Fee Restricted Delivery Total Postage & Fees USPS• Receipt for Certified Mair No Insurance Coverage Provided Do Not Use for International Mal lJ� 3.30 2.70 5.05 fl7y R DATE l • PENNSYLVANIA HOUSING FINANCE AGENCY v. SEAN M. CARR Cumberland County Sale 6/4/2014 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) One piece of ordinary mail addressed to: SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) One piece of ordinary mail addressed to: SEAN M. CARR FAIRFAX COUNTY ADULT DETENTION CENTER 10520 JUDICIAL DRIVE FAIRFAX, VA 22030 Postage: Postmark: SSP PITNEY BOWES 02 1M 0004284324 FEB 26 2014 MAILED FROM ZIP CODE 1 7102 $ 01.30° U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) One piece of ordinary mail addressed to: Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, PA 17013 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Postage: Postmark: ;o � r �-,J, 1 — yf`-`-_ z , s PITNEY BOWES 02 1M $ 01.30° 0004284324 FEB26 2014 MAILED FROM ZIP CODE 1 7102 PENNSYLVANIA HOUSING FINANCE AGENCY v. SEAN M. CARR Cumberland County Sale 6/4/2014 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: TENANT/OCCUPANT 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 Postage: Postmark: CO' 1.04, ii="0111130 2 •1191118118111, PITNEY Bowls 021M $01.30° 0004284324 FEB26 2014 MAILED FROM ZIP CODE 1 710 2 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE SUPPLEMENTAL RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 4.a9 daaly- , 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: SCHOOL HOUSE CONDOMINIUM ASSOCIATION 104 SOUTH HANOVER STREET CARLISLE, PA 17013 ATTORNEY CHRISTOPHER E. RICE MARTSON LAW OFFICE 10 EAST HIGH STREET CARLISLE, PA 17013 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 r CPI ry HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL.IR. JILL M. WINEKA LISA RYNARD LAW OFFICES 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 SCHOOL HOUSE CONDOMINIUM ASSOCIATION 104 SOUTH HANOVER STREET CARLISLE, PA 17013 ATTORNEY CHRISTOPHER E. RICE MARTSON LAW OFFICE 10 EAST HIGH STREET CARLISLE, PA 17013 HERSHEY (717)533-3836 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 an•y being notified of said Sheriffs Sale. Leon P. Haller PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, TAKE NOTICE: DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 04, 2014 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: 133 WEST LOCUST STREET UNIT 113 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. 2013 -04480 -CIVIL JUDGMENT AMOUNT $89,300.12 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: SEAN M. CARR 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 UNIT in the property known, named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S. Section 3101 et seq (the "Act") by the recording of a Declaration dated November 27, 2007, recorded on December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate undivided interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium, dated November 27, 2007, recorded December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, and under and subject to easements and rights of way of record and visible by inspection. BEING A CONDOMINIUM UNIT KNOWN AS: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Rovegno Real Estate Partners, by deed dated February 26, 2009 and recorded March 2, 2009 in Cumberland County Instrument No. 200905815, granted and conveyed unto Sean M. Carr. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013 -04480 -CIVIL ASSESSMENT NO. 16-23-0567-027-U-113 PENNSYLVANIA HOUSING FINANCE AGENCY v. SEAN M. CARR Cumberland County Sale 6/4/2014 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: SCHOOL HOUSE CONDOMINIUM ASSOCIATION 104 SOUTH HANOVER STREET CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: ATTORNEY CHRISTOPHER E. RICE MARTSON LAW OFFICE 10 EAST HIGH STREET CARLISLE, PA 17013 Postage: Postmark: S�P�Es POS)- `,% o - JPITNEY BOWES 02 1M $ 02.60° 0004284324 APR 29 2014 MAILED FROM ZIP CODE 1 710 2 4U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE SUPPLEMENTAL RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 6/11A i aoi 4 , 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: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES Aiwa, 76e, Yeaile, HOWARD B. KRUG LEON P.HALLER JOHN W. PURCELL JR. JILL M. WINEKA LISA RYNARD SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533-3836 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 ' ' . • , by being notified of said Sheriffs Sale. Bv: Leon P. Haller PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF SEAN M. CARR, DEFENDANT AND NOW, to -wit, thi VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL MORTGAGE FORECLOSURE ORDER OF COURT of J«f-,2014, upon consideration of the Plaintiffs Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED that service of the Notice of Sale as required by Pennsylvania Rule of Civil procedure 3129.2(c)(1)(i)(C) be made upon Defendant SEAN M. CARR by mailing of copies of the Notice by ordinary and Certified mail to the Defendant's last known addresses at 133 West Locust Street, #113 Mechanicsburg, PA 17055 and 30 Briarwood Lane, Carlisle, PA 17013. BY THE COURT 1 C ii f) f\J U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, TAKE NOTICE: DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 04, 2014 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: 133 WEST LOCUST STREET UNIT 113 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. 2013 -04480 -CIVIL JUDGMENT AMOUNT $89,300.12 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: SEAN M. CARR 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 UNIT in the property known, named and identified in the Declaration Plan referred to below as The School House Condominium, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S. Section 3101 et seq (the "Act") by the recording of a Declaration dated November 27, 2007, recorded on December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, being designated on such Declaration Plan as Unit 113, as more fully described in such Declaration Plan and Declaration, together with a proportionate undivided interest in the Common Elements, as defined in such Declaration. UNDER AND SUBJECT to restrictions and covenants of record including, but not limited to, Declaration of The School House Condominium, dated November 27, 2007, recorded December 7, 2007, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200745678, and amended by an Amendment recorded February 8, 2008, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument Number 200803908, and under and subject to easements and rights of way of record and visible by inspection. BEING A CONDOMINIUM UNIT KNOWN AS: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES WHICH Rovegno Real Estate Partners, by deed dated February 26, 2009 and recorded March 2, 2009 in Cumberland County Instrument No. 200905815, granted and conveyed unto Sean M. Carr. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013 -04480 -CIVIL ASSESSMENT NO. 16-23-0567-027-U-113 7196 9008 9111 3021 5823 TO: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 SENDER: BAV REFERENCE: PHFA VS. CARR PS Form 3800, Janu RETURN RECEIPT SERVICE ry Postage 2005 Certified Fee Return Receipt Fee Restricted Delivery Total Postage & Fees al 3.30 2.70 5.05 1) USPS' Receipt for Certified Mail"' No Insurance Coverage Provided Do Not Use for International Mali POS 7196 9008 9111 3021 5816 TO: SEAN M. CARR 133 WEST LOCUST STREF1`" UNIT 113 MECHANICSBURG, PA 17055 SENDER: BAV REFERENCE: PHFA VS. CARR PS Form 3800, Janua RETURN RECEIPT SERVICE ry Postage 2005 Certified Fee Return Receipt Fee 3.30 2.70 5.05 Restricted Delivery Total Postage & Fees x/71 USPS' Receipt for Certified Mail'" No Insurance Coverage Provided Do Not Use for International Mall POSTMARK OR PENNSYLVANIA HOUSING FINANCE AGENCY v. SEAN M. CARR Cumberland County Sale 6/4/2014 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: SEAN M. CARR 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055 Postage: Postmark: elts P°87'13, ® PITNEY BOWES 0 21 M $ 02.60° 0004284324 JUN12 2014 MAILED FROM ZIP CODE 1 7102 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SEAN M. CARR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2013 -04480 -CIVIL IN MORTGAGE FORECLOSURE SUPPLEMENTAL 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 133 WEST LOCUST STREET UNIT 113 MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): SEAN M. CARR 30 BRIARWOOD LANE APT. A CARLISLE, PA 17015 2. above: SAME E -4 C. --0 :c ^' ziz c tv r Name and address of Defendant(s) in the Judgment, if different from that liStgd. ii.(1)j • 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: 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: SCHOOL HOUSE CONDOMINIUM ASSOCIATION 104 SOUTH HANOVER STREET CARLISLE, PA 17013 ATTORNEY CHRISTOPHER E. RICE MARTSON LAW OFFICE 10 EAST HIGH STREET CARLISLE, PA 17013 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants if any .. . DOMESTIC RELATIONS OFFICE (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 0.r ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P,00lller PA I.D. #15700 Purce I, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATED: April 29, 2014 i Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE F.MOTHOh.0Trif`, l SEF 17 AH 8: iii CUMBERLAND COUNTY PENNSYLVANIA US Bank National Association vs. Sean M Carr Case Number 2013-4480 SHERIFF'S RETURN OF SERVICE 02/27/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Sean M. Carr at Fairfax County Adult Detention Center, 10520 Judicial Drive, Fairfax, VA 22030. 03/24/2014 03:53 PM - Deputy Ryan Burgett, 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 133 West Locust Street Unit 113, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 04/15/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he mailed a true copy of the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, by Certified Mail, Return Receipt Requested, to the within named Defendant, to wit: Sean M. Carr at Fairfax County Adult Detention Center, 10520 Judicial Drive, Fairfax, VA 22030, and said item was returned to the Cumberland County Sheriffs Office unopened and marked as "Return to Sender" on 4/14/14, return receipt card was detached from the item. cab. 06/03/2014 As directed by Leon P. Haller, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 08/06/2014 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, 1 Courthouse Square, Carlisle, PA on August 06, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Leon Haller, on behalf of U.S. Bank National Association Trustee for the Pennsylvania Housing Finance Agency, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $844.22 SO ANSWERS, August 26, 2014 c) CountySu to Sheriff, Teleosoft. Inc. RONIV R ANDERSON, SHERIFF ..3V I-1- PP � ? ) 3///7 On February 27, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as 133 West Locust Street, Unit 113 Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: February 27, 2014 By: /Ltd -CEJ_. Real Estate Coordin or EO C j LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-4480 Civil Term U.S. Bank National Association vs. Sean M. Carr Atty.: Leon P. Haller ALL THAT CERTAIN CONDOMIN- IUM UNIT, situated in the Borough of Mechanicsburg, County of Cum- berland, Commonwealth of Pennsyl- vania, known and identified as The School House Condominium, and being more specifically known as: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055. ASSESSMENT NO. 16-23-0567- 027-U-113. Reference Cumberland County Instrument No. 200905815. TO BE SOLD AS THE PROPERTY OF SEAN M. CARR ON JUDGMENT NO. 2013 -04480 -CIVIL. 39 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: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coy , Editor SWORN TO AND SUBSCRIBED before me this da of May, 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 2020 Technology Pkwy r. Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 be atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 2013-4480 Civil Term US Bank National Association Vs Sean M Carr Atty: Leon P. Haller ' ALL THAT CERTAIN CONDOMINIUM UNIT, situated in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, known and identified as The School House Condominium, and being more specifically known as: 133 WEST LOCUST STREET, UNIT 113, MECHANICSBURG, PA 17055 ASSESSMENT NO. 16-23-0567- 027-U-113 Reference Cumberland County Instrument No. 200905815. TO BE SOLD AS THE PROPERTY ' OF SEAN M. CARR ON JUDGMENT NO:2013 -04480-CI V I L This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 Sworn to - d , b .cribed before me this y of May, 20 4 A.D. ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTAR!EF 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 Pennsylvania Housing Fin Agency, Tr is the grantee the same having been sold to said grantee on the 6th day of August A.D., 2014, under and by virtue of a writ Execution issued on the 21st day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Tenn, 2013 Number 4480, at the suit of Pennsylvania Housing Fin Agency, Tr against Sean M Carr is duly recorded as Instrument Number 201420904. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of Recorder of Deeds ds, Cumberland County, Carlisle, PA ion Expires the First Monday of Jan. 2018