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HomeMy WebLinkAbout13-6211 Supreme Court of. Pennsylvania Court of Comm on Pleas For Prothonotary Use Only: Civil Cover. Sheet Docket No: CUM R County /2 ,r 691 �1 � The information collected on this form is used solely court administration purposes. This form does not supplement or replace the and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint 0 Writ of Summons El Petition M Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: U, S . BANK NATIONAL Lead Defendant's Name: ASSOCIATION.AS TRUSTEE FOR THE PENNSYLVANIA JILLIAN SCHREFFLER T Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? El Yes El No (check one) Qoutside arbitration limits O N Is this a Class Action Suit? E] Yes x No Is this an MDJAppeal? El Yes 0 No A Name of Plaintiff /Appellant's Attorney: Leon P. Haller / Jill M. Wineka El 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 El Intentional El Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution El Debt Collection: Credit Card El Board of Assessment 0 Motor Vehicle Q Debt Collection: Other 0 Board of Elections F1 Nuisance 0 Dept. of Transportation E] Premises Liability 0 Statutory Appeal: Other S Q Product Liability (does not include E mass tort) El Employment Dispute: El Slander/Libel /Defamation Discrimination C El Other: Employment Dispute: Other Q Zoning Board T 0 Other: I Other: O MASS TORT El Asbestos N Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Q Other: El Ejectment [] Common Law /Statutory Arbitration B El Eminent Domain /Condemnation [] Declaratory Judgment 0 Ground Rent E] Mandamus © Landlord /Tenant Dispute E] Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Quo Warranto Mortgage Foreclosure: Commercial El Dental n Partition El Replevin F1 Legal E] Quiet Title El Other: E] Medical rl Other: 0 Other Professional: Updated 1/1/2011 ) - fE;,, Leon P. Haller, Esquire ` Purcell, Krug & Haller 1719 North Front Street C UP 3 Pi 1_ A t . D C �1 U ` i 1, Harrisburg, PA 17102 f E f t -1 S `�LVA N I 717.234.4178 mtg @pkh.com U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING OF CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JILLIAN SCHREFFLER 13 6 / �� U Defendant THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717- 249 -3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA COUTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238 -6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE � ?- CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET / — CARLISLE, PA 17013 717-249-3166 (' U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION LAW VS. ACTION OF MORTGAGE FORECLOSURE JILLIAN SCHREFFLER, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 Attorney I.D.# 15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JILLIAN SCHREFFLER, 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, JILLIAN SCHREFFLER, is an adult individual whose last known address is 2455 JONES LANE, WHEATON, MD 20902. 3. On or about, July 30, 2009, the said Defendant executed and delivered a Mortgage Note in the sum of $132,456.00 payable to FIRST NATIONAL BANK OF CHESTER COUNTY thru AM HOME BANK division, 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 August 13, 2009 as Instrument Number 200928506 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 August 13, 2009 as Instrument Number 200928508. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on May 16, 2013 as Instrument Number 201316103. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 146 FAITH CIRCLE, CARLISLE, PA 17013 and is more particularly described in Exhibit `B" 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, 2011 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $129,816.91 Interest at $19.38 per day $20,038.92 From 01 /01 /2011 To 11 /01 /2013 ( based on contract rate of 5.3750 %) Accumulated Late Charges $167.70 Late Charges $29.67 $979.11 From 02/01/2011 to 11/01/2013 Escrow Deficit $7,790.57 Attorney's Fee at 5% of Principal Balance $6,490.85 TOTAL $165,284.06 * *Together with interest at the per diem rate noted above after November 01, 2013 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated March 23, 3011 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the March 23, 2011 Act 6 Notice is attached hereto and marked Exhibit "C ". 9. The within Mortgage is insured by the Federal Housing Administration under Title I1 of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non - active military duty is attached as Exhibit "D ". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.3750% ($19.38 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, & 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) Loan In i 0000697425 ntldUalace NOTE — r... "e 441- 92s97e6 July 30th, 2009 Carlisle, PA IDMI Icbl IS—) 146 Faith Circle, Carlisle, F —neylveuia 17013 1. PARTIES 'Borrmwer' means each person s pdu it the end of this Note, and the person's soecason and assigns. "Lender MICROS First llatitmal Hank of Cheater County than Am Hose Hank division and its succeums and assigns. 2. BORROWER'S PROMISE TO PAY; MXRFST In renua for a Ian received ft to Lender. Borrower promises m pay the Principal sour of one Hundred Thirty Two Theueend Four Hundred riity Six and ne /100 - - - - - Dollars (U.S. $ 132,436.0D ) phs hnemsI to the Order of Lender. loterert will be charged on unpaid principal, from the date of disbursement of the loan procecds by Lcudcr, at the rate of rive and three eighths Pettem ( 5.375 %) per year until the loll amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promt9e m pay is secu, by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the - Security Instrument.' The Security Instrume protects the Lends from losses which might result if Borrows defaults under this Note. - 4. MANNER OF PAYMENT (A) Time Borrower shill make a payment of principal and interest to Lender on the fast day of each month beginning on September let, 2009 Any principal ant inwresst m:mainiug w tine t m day of August, 2039 will be due on that slate, which is called the 'Maturity Dam." (B) Place Payment shall be made at 3640 Heapland Road, Kotmtville, PA 17554 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount FAch momddy payment of principal and Interest will be in the amount of U.S. $741.72 This amount will be part of a larger monthl paymcat tequired by the Security Insuv- not, that shall be applied to principal, hunst and other items in the under deccribed in the Security lowument. (D) Alloega to tbb Nate for Payment Attimanrrm If an allooge providing for payment adjustments is estcuted by Borrower together wild this Note, the coven is of the allunge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonym were a part of this Note. [Check applicable box) ❑ Graduated Paymem ABorge ❑ Other 19-w) ❑ Growing Equity Allooge S. BORROWER'S RIGB)T TO PREPAY Harrower has the right to pay die debt evidenced by this Note. in whole or in pan, without charge or penalty, on the tits[ day of any month. Lendcr shall accept pncpaymcni mother days providod that Borrower pays interest on the amount prepaid rim the remainder of the month m the cxu2u "quhW by Lender std pemdtied by reguladoms of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in de amount of Olt monthly paymem udess Lcuder agrees in wridna m those changes. 6. BORROWER'S FAILURE TO PAY (A) Late parse for Orerdue Payments If Lender has not received the full monthly payment required by the Swunty Instrument, as described in Paragraph 4(t7 of this Note by the end of Firteea calendar days aflrr the payment is due, Lender ®y collect a late charge in the amount of roue pen ( 4.000 %) mf the overdue amount of each payment. (� Defailt If Borrower defaults by failing 10 pay in foil amp monthly payment, then Lender may. except as limited by regulations of the Secretary in the case of payment defaults, require immodi to payment ins full of the principal bab Initials: FHA Midwre Rate Note- tSr9S AAM P .V I as �1 exh �klj 9' ` Loan. ID 0 0000697425 remaining due and all seemed interest. leader may choose not to eaerose tbis option without waiving its sighs in the event of any subargtren default. In many ctrettmstances regatatiom issued by the Seetetaty will limit Lender's rights to require imme"It: payment in full in the case *(payment defaults. Ibis Note does npl sathorist accckratiou whra not par®ned by HUD .egutaeom. As used in this Note, "Seesetary" wane the Secretary of Houmng sad Urban Development or his or her designee. (Q Payment of CMS and Eapemser If Lender has required tmmediste payment in fall, as described above. Leader may require Borrower to pay coats and ezpcases inhd'iq reasonable and ctcuommy attorneys' tea for enforcing this Note to the extent not prohibited by applicable law. Smb fees and costs &baU bar interest ft= the dam of disbursement at the same rate as the principal of this Notc. 7. WAIVERS Borrower and any other person who has obligations nnda this Note waive the tights of presertmmt and notice of disbonoc. 'Prow wax n' man the right to require Lender to demand payment of amounts due. "Notice of diabonor' mcnns tbt right to require I.mdcr to give mfiec in fiber person that amounts doe have not been paid. & GIVING OF NOTICES Unless applicWc bw requires a differem method, may. that mutt be given to Bormwa under this Note will be givca by tklivaing it or by mar7tng it by fiat class mail to Borrower at the property •ddtrsa above or at a dltfema address if Borrower has gives Lender a notice of Borrower's mffnmr address. Any notice that mast be given to ILOde order this Note will be givca by fum class wait to Leader at the addren stated in paragraph 4(B) or at a diffuent addreim if Borrower is given a nodce of that diffemn address. f. OBLIGATIONS OF PIKRSONS UNDER THIS NOTE If more than ore person signs this Note, each person if folly and personally obligated to Yap all of the promises made in this Note, in<ladina the promise to pay the full amom t owed. Any person who is a guarantor. suety or endorser of this Now is also obligated to do these things. Any person who takes over them obligations, including the obligations of a guarantor. ammy or endorser of this Note, is also obligated to keep all of the ;amine- made in thin Nom. Leader may enforce its rights under this Note against each person indvidniny of against all signatories together. Any one person signing this Nat may be required to pay all of the amounts owed under this Nom. BY SIGNING BELOW, Borrower accepts and agrees to die reruns and covenants contained in this Nate. S / w (Seal) Jell m ncheettl.m _Do wer (Snap .Borrower (fit) -Bwmwmr (Seal) Borrowel - ]sorrorver - &mower IStsn Origfnof 0nfy1 PHA Ntrer..ae Nrre)+.ore -1al9S ALLONGE TO NOTE This allonge makes reference to the following Note: Borrower(s): Jillian Schreffler loan#: 2009785 Property Address: 146 Faith Circle Carlisle, PA 17013 Loan Amount: $132,456.00 Note Date: July 30th, 2009 Therefore, in reference to the captioned Note, the following applies: Pay Without Recourse to Pennsylvania Housing Finance Agency First National BapU h ester County thtu "e Division i ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEING Lot No. 25 on the Plan of Kingsbrook, Section 3, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 27, Page 3; containing 50 feet along the East along Faith Circle, containing 200 feet along land now or formerly of Hooke, Lebo & Hooke, and containing 200 feet along the South along Lot No. 24 on said Plan; and containing 10,000 square feet. BEING improved with a six room semi - detached brick and aluminum siding dwelling house known and numbered as 146 Faith Circle. UNDER AND SUBJECT to conditions, restrictions, reservations, rights -of -way and easements of prior record and as may appear on the above - recited survey. Pennsylvania Musing Finance Agen -..counting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05 -5 05 7 (800) 346 -3597 FAX (717) 780 -3899 TTY (717) 780 -1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 3/23/2011 RE: Account No. 2009785 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 -8889 RE: 146 FAITH CIRCLE CARLISLE, PA 17013 -8889 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter We, Us or Ours) on your property located at 146 FAITH CIRCLE, CARLISLE, PA 17013 -8889, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $965.00 for 1/2011 through 3/2011 for a total of $2,895.00. Late charges and NSF charges that have accrued to this date in the amounts of $227.04 and $.00 respectively, are also due. The total listed below includes all fees (including inspections and securing that needed to be completed) less any funds we are holding in suspense. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $3,122.04. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $3,122.04, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either. by cash in our office, cashier's check, certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET /P.O. BOX 15057 HARRISBURG, PA 17105 -5057 1- 800 - 822 -7375 or TTY (800) 346 -3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgageed property. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees, even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty -day period, you will not be required to pay attorney fees. &4 bil f I r I FHAACT /dtmdocs /ALSV/ C We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty -day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriffas foreclosure sale You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1- 800 - 822 -7375. This payment must be made payable in cash in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND .COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Sincerely, Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/ P.O. Box 15057 Harrisburg, PA 17105 -5057 TLG/ FH AACT /dtmdocs /ALSV/ Pennsylvania Housing Finance Agee Y ._.:counting & Loan Servicing 211 North Front Street, P.O. Box 15057 Harrisburg, PA 1 71 05 -5 05 7 (800) 346 -3597 FAX (7-17) 780 -3899 TTY (717) 780 -1869 NOTICE 3/23/2011 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 -8889 RE: Account #2009785 TO: JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 -8889 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ( "HUD ") and experienced in the provision of homeownership counseling. Attached is a current list of HUD - approved counseling agencies for Pennsylvania. If these agencies are not near you, you can call HUD's toll free number (800) 569 -4287 for financially distressed mortgagors for information concerning HUD - approved housing counseling agencies. Attachment: Housing Counseling List FH AACT /dtmdocs /ALSV/ *"* PLEASE BE. SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY * ** CCCS OF WESTERN PA- HARRISBURG NACA 2000 LINGLESTOWN RD. 1341 N DELAWARE AVE; SUITE 312 HARRISBURG, PA. 17110 PHILADELPHIA, PA. 19125 Phone:888- 599 -2227 Phone:888- 297 -5568 HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT 34 S. Duke St. ONE PENN CENTER;1617 JFK BLVD; SUITE 1550 York, PA 17401 -1106 PHILADELPHIA, PA. 19103 -1828 Phone: 800 - 864 -4909 Phone:800- 930 -4663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster, PA 1 760 8 -1 67 6 Phone: 717 - 397 -5182 FH AACT /dtmdocs /A LSV/ G: 1 9849 2514 4081 7160 390 – — TO: JILLIAN SCHREFFLER U' ?'! -' = 146 FAITH CIRCLE CD p o = CARLISLE, PA 17 013, 1 © in 6 SENDER: BASSETT t < a.. OWL -o REFERENCE: 2009785 Y = z Ed P- IrZj 10 90 D — -, � 1il i = � F, <E to PS Form 36 January 2005__ — - i � Ti w. ;z 0 RETURN Postage . 44 -- "} IJl - A RECEIPT Certified Fee L — _ 2.80 u SERVICE r Retum Receipt Fee 2 Restricted Delivery Total Postage &Fees I 5.5 u , US Postal Service POSTMARK OR DATE Receipt for Certified mail No Insurance Coverage Provided Do Not Use for International Mao P� 010 W c*t �:1� ----------------------------------- - -------- - - - - -- ---- - - - - -- .. - �e ti 0 ® a I I' . 0 � H fiY.l W F:4 a u P4 ft C3 to W Ir ® m �® -a a � a F r` 17 c-i U •Q a •E th t cd in tn o a1 •C M i Results as of : Sep -26 -2013 06:48:32 Department of Defense Manpower Data Center SCRA 3.0 Status Report Pursuant to Service me bers Civil. Relief Act p. , Last Name: SCHREFFLER First Name: JILLIAN Middle Name: Active Duty Status As Of: Sep -26 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date - Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component ' NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Pq ,rr 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 W 3 B y U4ft46 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 SCHREFFLER 2009785 U.S. BANK NATIONAL ASSOCIATION AS IN THE COURT OF COMMON PLEAS OF ' TRUSTEE FOR THE ENNSYLVANIA HOUSING: CUMBERLAND COUNTY, PENNSYLVANIA ; C.) FINANCE AGENCY Plaintiff(s) ' JILLIAN SCHREFFLER-` Defendants Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court - supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by . a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectf mitte 10/21/13 Date Leon P. Haller / Jill M. Wineka Attorney for Pl 'nftiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 PA ID 1570a / 58802 U.S. BANK NATIONAI, ASSOCIATION AS : IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY Plaintiff(s) VS. JILLIAN SCHREFFLER Defendants) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies 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: CUSTOMERIPRIMARY APPLICATION Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-B Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Asset Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently payin &) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4�sttr of Comb rrt�f e _! I 1�l Jody S Smith , Chief Deputy 20 13 DEC -2 AM I( (',) Richard W Stewart CUMBERLAND COUNTY Solicitor OFgCE vhF SKRtFr PENNSYLVANIA U.S. Bank National Assocation vs. Case Number Jillian Schreffler 2013-6211 SHERIFF'S RETURN OF SERVICE 11/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jillian Schreffler, 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 146 Faith Circle, North Middleton, Carlisle, PA 17013. Residence is vacant and to this date the Carlisle Postmaster has not provided a good forwarding address. 11/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 146 Faith Circle, North Middleton, Carlisle, PA 17013.Residence is vacant. SHERIFF COST: $60.78 SO ANSWERS, November 21, 2013 RONNK ANDERSON, SHERIFF 'w)CountySuito Sheriff.Teiosof•.inc. 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 JILLIAN SCHREFFLER Defendant No. 2013-06211 PRAECIPE TO REINSTATE c. I TO THE PROTHONOTARY: -ts Kindly reinstate the complaint on the above captioned matter. DATE: January 14, 2014 PURCELL, KRUG, & HALLER BY Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 � 4'1I.75p it•I ;ess( U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY vs. JILLIAN SCHREFFLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RETURN OF SERVICE No. 2013 -06211 TO THE PROTHONOTARY: Kindly file the Out of State Service Return on the above captioned matter. DATE: March 3, 2014 PURCELL, KRUG, & HALLER B- Leon ' . Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 CUMBERLAND COUNTY CIVIL DIVISION US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOUSING AGENCY Plaintiff JILLIAN SCHREFFLER Defendant AFFIDAVIT OF SERVICE CASE# 2013-06211 I, Karl Stephens, having been duly authorized to make service of the COMPLAINT IN MORTGAGE FORECLOSURE DIVERSION PROGRAM, REQUEST FOR CONCILIATION CONFERENCE AND FINANCIAL WORKSHEET in the above entitled case, hereby depose and say: That my age and date of birth are as follows: Over the age of 18, D.O.B.: 7/25/67 That my business address is: PO Box 6811, Silver Spring, MD 20916. Telephone # 301- 929-6819. That I am not a party to or otherwise interested in this suit. That at 4:00pm on the 21ST day of JANUARY, 2014, I served the named defendant • JILLIAN SCHREFFLER at her usual place of abode: 2455 JONES LAN., WHEATON, MD 20902. I solemnly affirm under the penalties of perjury that the foregoing affidavit upon personal knowledge, information, and belief is true. DESC: WHITE FEMALE, 5'8, 160LB, APPROX 45-50Y0A SUBSCRIBED & SWORN BEFORE ME 1/21/14 Date: Signature of Process Server MARGARET L. CAULK Notary Public, State of Maryland County of Montgomery I* Commission Expires June 14, 2014 4 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VS. iZ L% l'TFWIliONOTA,i.- 2011;1111R27 PH 1: 16 CUMBERLAND COUNTY PENNS YLVAN1A : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW : NO. 13-6211 CIVIL JILLIAN SCHREFFLER : 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 its 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 October 22, 2013, 2. Service of the Complaint and Notice of Residential Mortgage Foreclosure Diversion Program was made on January 21, 2014. 3. More than sixty (60) days have elapsed since the service of the Notice of the Residential Mortgage Foreclosure Diversion Program. 4. The property is vacant and not owner occupied. 5. The Notice of Residential Mortgage Foreclosure Diversion Program was served on Defendant on January 21, 2014. 6. Defendant has not opted to participate in the Mortgage Foreclosure Diversion Program. 7. Plaintiff, in accordance with the provisions of the Mortgage Foreclosure Diversion Program, requests that the stay be lifted. WHEREFORE, Plaintiff requests that the stay imposed by the Cumberland County Mortgage Foreclosure Diversion Program be lifted to allow Plaintiff to proceed with the foreclosure action. PURCELL, KRUG & HALLER By: Dated: March 25, 2014 Leon P. Hal -r 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Attorney ID #15700 Attorney for Plaintiff 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. 4 Leon P. Haller Dated: March 25, 2014 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW : NO. 13-6211 CIVIL JILLIAN SCHREFFLER : IN MORTGAGE FORECLOSURE Defendant CERTIFICATE OF SERVICE I, Leon P. Haller, the undersigned, Attorney for Plaintiff, hereby certify that I served on the 25th day of March, 2014, a copy of the Petition to Lift Stay Imposed by Mortgage Foreclosure Diversion Program upon each of the following persons at the addresses shown below: Jillian Schreffler 2455 Jones Lane Wheaton, MD 20902 Leon P. Hailer Dated: March 25, 2014 Attorney for P aintiff U.S. BANK NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW vs. : NO. 13-6211 CIVIL JILLIAN SCHREFFLER : IN MORTGAGE FORECLOSURE Defendant ORDER AND NOW, this 2' of +41 , 2014, upon consideration of Plaintiff Petition to Lift Stay, Notice of the Residential Mortgage Foreclosure Diversion Program having been served on January 21, 2014, the Defendant having not opted to participate in the Mortgage Foreclosure Diversion Program, IT IS HEREBY ORDERED that the stay imposed by the Mortgage Foreclosure Diversion Program be lifted and Plaintiff may proceed with its mortgage foreclosure action. BY THE COURT: Al U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JILLIAN SCHREFFLER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013-06211 DEFENDANT(S) MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) JILLIAN SCHREFFLER 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 Interest Per diem of $19.38 From 01/01/2011 To 11/01/2013 Accumulated Late Charges Late Charges ($29.67 per month to 11/01/2013) Escrow Deficit 5% Attorney's Commission TOTAL $129,816.91 $20,038.92 $167.70 $979.11 $7,790.57 $6,490.85 $165,284.06 CD =fflo CD **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 Sheriffs Sale. PURCELL, KRUG & HA By on P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. JILLIAN SCHREFFLER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO, 2013-06211 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on April 15, 2014 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. er PA I.D.# 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 c) CID :S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. JILLIAN SCHREFFLER Defendant DATE OF THIS NOTICE: April 15, 2014 TO: JILLIAN SCHREFFLER 2455 JONES LANE WHEATON, MD 20902 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2013-06211 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717- 249 -3166 PURCELL, KRUG & HALLER By LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234 -4178 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW VS. NO. 2013-06211 JILLIAN SCHREFFLER, IN MORTGAGE FORECLOSURE DEFENDANT AFFIDAVIT COMMONEALTH OF PENNSYLVANIA : SS COUNTY OF DAUPHIN I, LEON P. HALLER, Attorney for the Plaintiff in the above matter, bein sworn according to law, hereby certify that the Mortgage in the above case is insured-by "' the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 1715z11) and therefore does not fall within the provisions of PA Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program). Sworn to and subscribed befor p e this i day of f J 20 u ✓. r ' Public , I'Jot COMMONWEALTI NOTARIAL SEAL MARYLAND It. F_ERRE►TI, Notary Public Lower Pa :ccn wp., Dauphin County My Co nrnission Expires Aug. 8, 2014 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JILLIAN SCHREFFLER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013-06211 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN T33 r-rt rn —0 cD, 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 Ii J!44lI. N t ary u c COMMQNWEA2NNSYLVAIA NOTARIAL SEAL ARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County Mv Commission Expires Aug. 8, 2014 HALLER, ESQUIRE department of Defense Manpower Data Center Results as of : Apr -23 -2014 07:47:52 AM SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: SCHREFFLER First Name: JILLIAN Middle Name: Active Duty Status As Of: Apr -23 -2014 On Active Duty On Active Duty Status Date , Active Duly Start Dale _ Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duly Status Date Left Active Duty Within 367 D s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA I 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 Data 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, 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 (NOM 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: 99D0P8E1D084L40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2013-06211 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JILLIAN SCHREFFLER, . DEFENDANT(S) Total Judgment Amount $165,284.06 Interest $5,603.11 Per diem of $19.38 to sale date 9/3/2014 Late Charges $296.70 $29.67per month to sale date 9/3/2014 Escrow Deficit $4,418.14 TOTAL WRIT $175,602.01 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE :DATE: Wednesday, September 03, 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: April 23, 2014 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 eon P. Haller PA I.D. #15700 WRIT OF EXE UTION - MORTGAGE FO COMMONWEALTH OF PENNSYLVANI COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the sell the property described in the attached description Date: at,,A 14D6:1 0-12[' l0S.`7S c< <. (1.`7SIi 1(0. cbtt rrtop Pl r- X <CD Vii'C) c) CLOSURE 135, r`..) -_r e captioned case, you are directed to levy upon and 46 FAITH CIRCLE CARLISLE, PA 17013 PROTHONb ARY/CLERK CIVIL DIVISION BY t,-). as 193Sso P-* DEPUTY ()64P,Liqi ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, County of Cumberland County, and Commonwealth of Pennsylvania, bounded and described as follows: BEING Lot No. 25 on the Plan of Kingsbrook, Section 3, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 27, Page 3; containing fifty (50) feet along the East, along Faith Circle, containing two hundred (200) feet along land now or formerly of Hooke, Lebo & Hooke, and containing two hundred (200) feet along the South along Lot No. 24 on said Plan; and containing 10,000 square feet. HAVING THEREON ERECTED a semi-detached brick and aluminum siding dwelling house known as: 146 FAITH CIRCLE, CARLISLE, PA 17013 UNDER AND SUBJECT to conditions, restrictions, reservations, rights of way and easements or prior record and as may appear on the above -recited survey. BEING THE SAME PREMISES WHICH Jeremy W. Stansfield and Cynthia M. Stansfield, his wife, formerly known as Cynthia M. Crawford, by deed dated 07/30/2009 and recorded 08/13/2009 in Cumberland County Instrument No. 2009-28505, granted and conveyed to Jillian Schreffler. TO BE SOLD AS THE PROPERTY OF JILLIAN SCHREFFLER ON JUDGMENT NO. 2013-06211 ASSESSMENT NO. 29-14-0868-074 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JILLIAN SCHREFFLER, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013-06211 IN MORTGAGE FORECLOSURE 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 146 FAITH CIRCLE CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): JILLIAN SCHREFFLER 2455 JONES LANE WHEATON, MD 20902 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 2. Name and above: SAME c-) rn rn cf) r-� DC it © address of Defendant(s) in the Judgment, if different from that ftec1M in ( -C, IND 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 5. Name and address of every other person who has any record lien on the property: NONE 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 4 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 146 FAITH CIRCLE CARLISLE, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authoriti DATE: April 23, 2014 . Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 A U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. JILLIAN SCHREFFLER, DEFENDANT(S) TAKE NOTICE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2013-06211 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, September 03, 2014 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 cn E (..) cor- < mac-, cn IN) 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: 146 FAITH CIRCLE CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2013-06211 JUDGMENT AMOUNT $165,284.06 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILLIAN SCHREFFLER 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. 1 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, County of Cumberland County, and Commonwealth of Pennsylvania, bounded and described as follows: BEING Lot No. 25 on the Plan of Kingsbrook, Section 3, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 27, Page 3; containing fifty (50) feet along the East, along Faith Circle, containing two hundred (200) feet along land now or formerly of Hooke, Lebo & Hooke, and containing two hundred (200) feet along the South along Lot No. 24 on said Plan; and containing 10,000 square feet. HAVING THEREON ERECTED a semi-detached brick and aluminum siding dwelling house known as: 146 FAITH CIRCLE, CARLISLE, PA 17013 UNDER AND SUBJECT to conditions, restrictions, reservations, rights of way and easements or prior record and as may appear on the above -recited survey. BEING THE SAME PREMISES WHICH Jeremy W. Stansfield and Cynthia M. Stansfield, his wife, formerly known as Cynthia M. Crawford, by deed dated 07/30/2009 and recorded 08/13/2009 in Cumberland County Instrument No. 2009-28505, granted and conveyed to Jillian Schreffler. TO BE SOLD AS THE PROPERTY OF JILLIAN SCHREFFLER ON JUDGMENT NO. 2013-06211 ASSESSMENT NO. 29-14-0868-074 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net U. S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Vs. NO 13-6211 Civil Term CIVIL ACTION — LAW JILLIAN SCHREFFLER WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $165,284.06 L.L.: $.50 Interest PER DIEM OF $19.38 TO SALE DATE 9/3/2014 - $5,603.11 Atty's Comm: Atty Paid: $221.28 PER MONTH TO SALE DATE 9/3/2014 ESCROW DEFICIT - $4,418.14 Plaintiff Paid: Date: 4/30/2014 (Seal) 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 Due Prothy: $2.25 Other Costs: LATE CHARGES - $296.70 - $29.67 David D. Buell, Prothonotary Deputy 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. 2013-06211 JILLIAN SCHREFFLER, IN MORTGAGE FORECLOSURE DEFENDANT(S) RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 5JDCj I + , 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: JILLIAN SCHREFFLER 2455 JONES LANE WHEATON, MD 20902 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 Pennsylvania Housing Finance Agency 211 North Front Street ' o` P. O. Box 15057 Harrisburg, PA 17105-5057 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 146 FAITH CIRCLE CARLISLE, PA 17013 By L, KRUG & HALLER ttorneys for Plaintiff '� T 1719 North Front Street -' Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES ,Q� 1719 NORTH FRONT STREET HOWARD B.KRUG HARRISBURG,PENNSYLVANIA 17102-2392 HERSHEY LEON P.HALLER TELEPHONE(717)2344178 (717)533-3836 JOHN W.PURCELL JR. FAX(717)234-1206 JILL M.WINEKA LISA RYNARD JILLIAN SCHREFFLER 2455 JONES LANE WHEATON, MD 20902 JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 146 FAITH CIRCLE CARLISLE, PA 17013 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. By. e . Haller PA I.D.15700 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, PLAINTIFF CIVIL ACTION LAW VS. NO. 2013-06211 JILLIAN SCHREFFLER, IN MORTGAGE FORECLOSURE DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, September 03,2014 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: 146 FAITH CIRCLE CARLISLE, PA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2013-06211 JUDGMENT AMOUNT $165,284.06 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILLIAN SCHREFFLER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, County of Cumberland County, and Commonwealth of Pennsylvania, bounded and described as follows: BEING Lot No. 25 on the Plan of Kingsbrook, Section 3, as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 27, Page 3; containing fifty (50) feet along the East, along Faith Circle, containing two hundred (200) feet along land now or formerly of Hooke, Lebo & Hooke, and containing two hundred (200) feet along the South along Lot No. 24 on said Plan; and containing 10,000 square feet. HAVING THEREON ERECTED a semi-detached brick and aluminum siding dwelling house known as: 146 FAITH CIRCLE, CARLISLE, PA 17013 UNDER AND SUBJECT to conditions, restrictions, reservations, rights of way and easements or prior record and as may appear on the above-recited survey. BEING THE SAME PREMISES WHICH Jeremy W. Stansfield and Cynthia M. Stansfield, his wife, formerly known as Cynthia M. Crawford,by deed dated 07/30/2009 and recorded 08/13/2009 in Cumberland County Instrument No. 2009-28505, granted and conveyed to Jillian Schreffler. TO BE SOLD AS THE PROPERTY OF JILLIAN SCHREFFLER ON JUDGMENT NO. 2013-06211 ASSESSMENT NO. 29-14-0868-074 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff CIVIL ACTION LAW# 2013-06211 JILLIAN SCHREFFLER Defendant AFFIDAVIT OF SERVICE I, Karl Stephens, having been duly authorized to make service of the NOTICE OF SHERIFF SALE in the above entitled case, hereby depose and say: That my age and date of birth are as follows: Over the age of 18, D.O.B.: 7/25/67 That my business address is: PO Box 6811, Silver Spring, MD 20916. Telephone# 301- 929-6819. That I am not a party to or otherwise interested in this suit. That at 8:15pm on the 30"' day of JULY, 2014, 1 served the named Defendant : JILIAN SCHEFFLER personally at her usual place of abode: 2455 JONES LN., WHEATON, MD 20902 1 solemnly affirm under the penalties of perjury that the foregoing affidavit upon personal knowledge, information, and belief is true. DESC: WHITE FEMALE, 5'8, 230LB, APPROX 40YOA Signature of Process Server Date: <�3Uf� SUBSCRIBED & SWORN BEFORE ME 7/30/14 taPPET 4 c . Q, 9G MARGARET L.CAULK NOTARY`� Notary Public,State of Maryland PUBLIC r County of Montgomery � �Go` My Commission Expires June 14,2018 7196 9008 9111 3021 6615 7196 9008 9111 3021 6622 TO: JILLIAN SCHREFFLER TO: JILLIAN SCHREFFLER 2455 JONES LANE 146 FAITH CIRCLE WHEATON,MD 20902 CARLISLE,PA 17013 SENDER: P01455/40336 SENDER: P01455/40336 REFERENCE: NOS 09/03/14 REFERENCE: NOS 09/03/14 PS Form 3800 January 2005 PS Form 3800,January 2005 RETURN Postage RETURN Postage RECEIPT Certified Fee 3.30 RECEIPT Certified Fee 1-10 SERVICE SERVICE Return Receipt Fee 2.70 Return Receipt Fee 2-70 Restricted Delivery 5.05 Restricted Delivery 5.05 Total Postage&Fees Total Postage&Fees 7 USPS POSTMARK OR DATE i USPS POSTMA6K gWDATE Receipt for o,;, Receipt for " Certified MailTwCertified Mail'" \ i No Insurance Coverage Provided it No Insurance Coverage Provided �y Do Not Use for International Mad f Do Not Use for International Mail �°%q�!s • PENNSYLVANIA HOUSING FINANCE AGENCY v. JILLIAN SCHREFFLER Cumberland County Sale 9/3/2014 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: JILLIAN SCHREFFLER 2455 JONES LANE WHEATON, MD 20902 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: JILLIAN SCHREFFLER 146 FAITH CIRCLE CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street ; +, Carlisle, PA 17013 f% rC`�:. h •- � Q 14 Q r NG; GSL $ 01-300 MAILED FROM 2#R coDE ' 710 2 PENNSYLVANIA HOUSING FINANCE AGENCY v. JILLIAN SCHREFFLER Cumberland County Sale 9/3/2014 U.S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 146 FAITH CIRCLE CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug& Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Pennsylvania Housing Finance Agency 211 North Front Street P. O. Box 15057 Harrisburg, PA 17105-5057 U 4 4 `, ✓ `21'Gti�T.&6P 4>IIM1i/Y ft()4VES • : n 2 , $ 02.60° ',004284324 MsY^7 2n14 MAILED FROM ZtP CODE 1 717 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY !LEO -OFFICE THE PRCTHvNQT F ,/ y, of C SUE 2014 OCT 21 NI 2: 57 OPF,.CEI ES!FF CUMBERLAND COUNTY PENNSYLVANIA U.S. Bank National Assocation vs. Jillian Schreffler Case Number 2013-6211 SHERIFF'S RETURN OF SERVICE 06/16/2014 06:07 PM - Deputy Shawn Harrison, 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 146 Faith Circle, Carlisle, PA 17013, Cumberland County. 09/03/2014 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 17013, on Wednesday, September, 3, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Leon P. 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: $824.91 SO ANSWERS, September 17, 2014 (c) f;ountySu:te Sheriff, Tekrosoft. Inc. RONO R ANDERSON, SHERIFF On May 8, 2014 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Known and numbered as, 146 Faith Circle, Carlisle, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: Pik a 8, 2014 By: Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-6211 Civil U.S. BANK NATIONAL ASSOCATION vs. JILLIAN SCHREFFLER Atty.: Leon P. Haller ALL THAT CERTAIN 1ot or piece of ground situate in North Middle- ton Township, Cumberland County, Pennsylvania, BEING Lot No. 25, Plan of Kingsbrook, Section 3, Cum- berland County Plan Book 27, Page 3, containing 10,000 square feet and having thereon erected a semi- detached brick and aluminum siding dwelling house known as: 146 FAITH CIRCLE, CARLISLE, PA 17013. ASSESSMENT NO. 29-14-0868- 074. Reference Cumberland County Instrument No. 2009-28505. TO BE SOLD AS THE PROP- ERTY OF JILLIAN SCHREFFLER ON JUDGMENT NO. 2013-06211. 90 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: July 11, July 18 and July 25, 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. L� arie Coyne, Ed tor SWORN TO AND SUBSCRIBED before me this 25 da of Jul 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. 1900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he patriotNews 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 Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 1900 Patriot Drive, 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. 2013.6211 Civil Term U.S. BANK NATIONAL ASSOCIATION vs. JILLIAN SCHREFFLER Any: Leon P. Haller ALL THAT CERTAIN lot or piece of groundsituate berland North Middleton County, Township, , Pennsylvania, BEING Lot No. 25, Plan of Kingsbrook, Section 3, Cumberland County Plan Book 27, Page 3, containing 10,000 square feet and having thereon erected a semi- detached brick and aluminum siding dwelling house known as: 146 FAITH CIRCLE, CARLISLE, PA 17013 ASSESSMENT NO. 29-14-0868-074 Reference Cumberland County Instrument No. 2009-28505. TO BE SOLD AS THE PROPERTY OF JILLIAN SCHREFFLER JUDGMENT NO.2013-06211 ON This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 'WO Sworn to and subscribed before me this 20 day of August, 2014 A.D. .+AlL_A N•tary I bli COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which U.S. Bank, NA as Trustee for the Pennsyvlania Housing Finance Agency is the grantee the same having been sold to said grantee on the 3rd day of September A.D., 2014, under and by virtue of a writ Execution issued on the 30th day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 6211, at the suit of U.S. Bank, NA as Trustee for the Pennsyvlania Housing Finance Agency against Jillian Schreffler is duly recorded as Instrument Number 201424036. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a/ , A.D. Gi ,./ • ecord l eeds, Cumberland County, Carlisle, PA My Corn fission Expires the First Monday of Jan. 2018 day of Recorder of Deeds