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HomeMy WebLinkAbout14-0445 Supreme Court of Pennsylvania Court of Common Pleas ForProthonornrt• Use Only: r Civil Cover Sheet Docket No: Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or rep lace the filing and service of pleadin s or• other a Hers as required by law or rules of court. S l Commencement of Action: E x Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Takin Lead Plaintiff's Name: FEDERAL NATIONAL Lead Defendant's Name: LAURENCE P. KENNEY, III AKA T MORTGAGE ASSOCIATION LAWRENCE P. KENNEY, III AND LISA M. KENNEY 1 0 N Are money damages requested? : ❑ Yes X No Dollar Amount Requested: within arbitration limits A (Check one ) outside arbitration limits Is this a Class Action Suit? 0 Yes 0 No Is this an MDJA eal? ❑ Yes ❑X No Name of Plaintiff/Appellant's Attorney: Martha Von Rosenstiel, Esq. o Check here if you are a Self-Represented (Pro Se ) Litigant Nahtre of the Case Place an `=X'' to the left of the ONE case categotj! that most accurately describes your PRI URPC'ASE. If you are making more than one type of claim. check the one that you consider most important. TORT (do no; include.-Wass Ion) CONTRACT (donor fnclude3udgmenrs,t CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance ❑ Dept. of Transportation Premises Liability ❑ Statuttoty Appeal: Other S ❑ Product Liability (does nor include. fort} ❑Employment Dispute: mass E ❑ SlauderiLibel Defamation Discrimination C ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other` 1 ❑ Other: 0 MASS TORT ❑ Asbestos \. ❑ Tobacco Toxic Tort - DES Toxic Tort - Inn>lant REAL PROPERTY \IISC•ELLANEOTUS Toxic NVaste Outer: El Ejectment E] Common Laxu�tStatutot7- Arbitration B ❑ Eminent Dontain'Condetunation ❑ Declaratory Jud_gmeut ❑ Ground Rent -mandannts Lamdlor&Tenant Dispute e Non- Domestic Relations ❑'Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL. LIABLITY []'Mortgage Foreclosure: Conu iercial ❑ Quo Warranto Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other. Medical ❑ Other: ❑ Other Professional: L'pdalerl1 /1/3011 d- 1 MARTHA E. VON ROSENSTIEL, P.C. I'f s r °ftt t f 0 ©d; T' 33557CFC -AB Martha E. Von Rosenstiel, Esquire / No. 52634�� ,J 2� ��: , Heather Riloff, Esquire / No. 309906 Se9aneuPA 1901 g' Suite 7 P ENNS " C (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016 -2892 Plaintiff � l U1 V. NO. "1 - LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants CIVIL ACTION — MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le han demandado a usted en la cone. Si usted quiere defenderse de set forth in the following pages, you must take action within twenty estas demandas expuestas en las paginas siguientes, usted tiene (20) days after this complaint and notice are served, by entering a veinte (20) dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la cone en fonna escrita sus You are warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende, la corte toma ra medidas y further notice for any money claimed in the complaint or for any other puede continuar la demanda en contra suya sin previo aviso o claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas, la cone puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW. THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A WITH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO, LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717- 249 -3166 800 - 990 -9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. 33557CFC -AB Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016 -2892 Plaintiff V. NO. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Federal National Mortgage Association, organized and existing under the laws of the United States of America, with offices for the conduct of business at 3900 Wisconsin Avenue, NW, Washington, DC 20016 -2892. 2. Defendants, Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney are the mortgagors and real owners of premises 32 State Road, Mechanicsburg, PA 17050, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Mortgage Electronic Registration Systems, Inc. as Nominee for Mortgage Lenders Network USA, Inc. on June 16, 2006, which mortgage was recorded on June 26, 2006 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1956, Page 0195, secured on premises 32 State Road, Mechanicsburg, PA 17050 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage was then assigned to Bank of America, NA, successor by merger to BA.0 Home Loans Servicing, LP, fka, Countrywide Home Loans Servicing, LP by written assignment dated August 24, 2012 and recorded on August 31, 2012 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 201226771. 5. The mortgage has since been assigned to Federal National Mortgage Association by written assignment dated December 5, 2012 and recorded on December 27, 2012 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Instrument No. 201240158. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates theirs herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from March 2013 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 147,939.29 Interest from 2/1/2013 to 12/19/2013 at $27.87 per diem $ 8,944.75 Accrued Escrow deficit $ 1,362.41 Attorney's Fee $ 1,650.00 Legal /Attorney $ 726.00 Property Inspections $ 225.00 Suspense $ (1,060.31 ) Total $ 159,787.14 9. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $159,787.14, plus per diem interest at $27.87 from December 20, 2013 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENST L, P.C. BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff VERIFICATION J Jennette Hall hereby states that he /she is the !Foreclosure. Specialist of Seterus, Inc., Servicing Agent for Federal National Mortgage Association, plaintiff herein; that he /she is duly authorized to make this Verification on behalf of Federal National Mortgage Association and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Association v. Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney relating to the property located at 32 State Road, Mechanicsburg, PA 17050 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: e Title: F re Iosure ; Specialist Seterus, I . as servicer for Federal National Mortgage Association Dated Z014- EXHIBIT I LEGAL DESCRIPTION ALL THOSE CERTAIN pieces or parcels of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: LOT #1 BEGINNING at a spike on the center line of the public road leading from Mechanicsburg to the New Kingston Road at corner of lands now or late of the Laura C. Gross Estate; thence by the center line of said road, South 82 degrees West, one hundred five (105) feet to a spike; thence by other lands now or late of Tolbert L. and Pearl M. Bricker, North 00 degrees 45 minutes East, two hundred fifty -seven (257) feet to a pin; thence by the same, North 82 degrees East one hundred five (105) feet to a pin; thence by lands now or late of the Laura C. Gross Estate, South 00 degrees 45 minutes West, two hundred fifty -seven (257) feet to a spike, the place of BEGINNING. CONTAINING .62 acres HAVING thereon erected a brick ranch type dwelling This description is in accordance with a survey made November 24, 1958 by W.G. Rachel, Registered Surveyor LOT #2 BEGINNING at a point in the center of the public road leading from Mechanicsburg to the New Kingston Road at corner of other lands now or late of Paul J. Hess and Mildred E. Hess; thence by other lands now or late of Paul J. Hess and Mildred E. Hess, North 00 degrees 45 minutes East, two hundred fifty -seven (257) feet to a point; thence by the same, North 82 degrees east, one hundred five (105) feet to a point; thence by lands now or late of the Laura Gross Estate, North 00 degrees 45 minutes East, thirty -five and six tenths (35.6) feet to a point; thence by other lands now or late of Tolbert L. Bricker and Pearl M. Bricker, his wife, South 00 degrees 45 minutes West, two hundred ninety -two and six tenths (292.6) feet to a point in the center of the aforesaid public road; thence by the center line -of said road, North 82 degrees East, ten (10) feet to a point, the place of BEGINNING. BEING a strip of land shown on the land of Tolbert L. Bricker PARCEL IDENTIFICATION NO: 38 -23- 0571 -015 EXHIBIT II seterus Physical Address 14523 SW Millikan Way; Suite 200; Beaverton, OR 97005 Business Hours (Pacific Time) Monday- Thursday 5 a.m. to 8 p.m. Friday 5 a.m. to 6 p.m. Payments October 17, 2013 PO Box 11790 Newark, NJ 07101 -4790 Correspondence PO Box 2008; Grand Rapids, MI 49501 -2008 VIA CERTIFIED AND FIRST CLASS MAIL Phone 866.570.5277 L178R Fax KENNEY, LAWRENCE P 866.578.5277 32 STATE RD Website MECHANICSBURG, PA 17050 -3154 www.seterus.com Loan number:�serviced by Seterus, Inc. Please read the following important notice about your loan. If you receive or have received a discharge of this debt in a bankruptcy proceeding and the debt is not reaffirmed in the bankruptcy proceeding, you will not be personally responsible for the debt. However, the lien against the property securing this debt may remain on the property until the amount owing on the loan is paid. In addition, we may commence a foreclosure proceeding against the property that secures this loan: Sincerely, Seterus, Inc. Enclosures: Act 91 Notice, PHFA list of HEMAP- approved agencies, How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW. COLORADOATTORNEYGENERAL.GOV /CA. Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 250, Lakewood, CO 80228. The office's phone number is 888.738.5576. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. Page 1. of 6 Date: October 17, 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 that the lender /servicer 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 to 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 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 NOTIFICACION 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 REDEMM SU HIPOTECA. Page 2 of 6 HOMEOWNER'S NAME(S): KENNEY, LAWRENCE P KENNEY, LISA M PROPERTY ADDRESS: 32 STATE RD MEECHA_NICSBURG, PA 17050 -3154 LOAN ACCT. NO.: ��� ORIGINAL LENDER: MORTGAGE LENDERS NETWORK USA, INC. CURRENT LENDER/SERVICER: Seterus, Inc. 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 time 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 /servicer 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 properly 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 /servicer 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 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 /servicer 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/SERVICER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." Page 3 of 6 YOU HAVE'THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER/SERVICER 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 /servicer on your property located at: 32 STATE RD MECHANICSBURG, PA 17050 -3154 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE REGULAR MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payments: March 1, 2013 through October 1, 2013 in the amount of $1,333.82 each Total: $10,670.56 Past Due Installments: $10,670.56 Other Open Charges: Prior Servicer Charges Seterus, Inc. Charges Late Charges 106.16 0.00 106.16 Property Inspections 30.00 165.00 195.00 Total Past Due Installments & Charges $10,971.72 Less Suspense (Balance) 1,166.47 TOTAL AMOUNT PAST DUE $9,805.25 Page 4 of 6 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/SERVICER, WHICH IS $9,805.25, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: -" Seterus, Inc. PO Box 11790 Newark, NJ 07101 -4790 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 / servicer 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 regularly scheduled installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender /servicer also intends to instruct its attorneys to start legal action to foreclose upon your mortmed 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 /servicer refers your case to its attorneys, but you cure the delinquency before the lender /servicer 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 / servicer even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender /servicer, 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/SERVICER 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 THE 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 Sheriffs Sale. You may do so by paving 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 Sheriffs Sale as specified in writing by the lender / servicer and by performing and other requirements under the mortage. 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 Sheriffs Sale of the mortgaged property could be held would be approximately five (5) 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 /servicer. Page 5 of 6 HOW TO CONTACT THE LENDER/SERVICER: Name of Lender /Servicer: Seterus, Inc. Address: PO Box 2008 Grand Rapids, MI 49501 -2008 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Shannon Stock or Nathan Wetzel E -Mail Address: ExternalCommunications @seterus.com EFFECT OF SHERIFF'S SALE - -You should realize that a Sheriffs 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 /servicer at any time. ASSUMPTION OF MORTGAGE - -You _ may or X may not sell or transfer your home to a buyer or transferee who will asuume 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. 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. • 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/SERVICER. • TO SEE PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Page 6 of 6 seteru Physical Address 14523 SW Millikan Way; Suite 200; Beaverton, OR 97005 "� Business Hours (Pacific Time) Monday - Thursday 5 a.m. to 8 p.m. Friday 5 a.m. to 6 p.m. Payments October 17 , 2013 PO Box 11790; Newark, NJ 07101 -4790 Correspondence VIA CERTIFIED AND FIRST CLASS MAIL PO Box 2008 Grand Rapids, MI 49501 -2008 Phone 866.570.5277 L178R Fax KENNEY, LISA M 866.578.5277 32 STATE RD Website MECHANICSBURG, PA 17050 -3154 www.seterus.com Loan number serviced by Seterus, Inc. Please read the following important notice about your loan. If you receive or have received a discharge of this debt in a bankruptcy proceeding and the debt is not reaffirmed in the bankruptcy proceeding, you will not be personally responsible for the debt. However, the lien against the property securing this debt may remain on the property until the amount owing on the loan is paid. In addition, we may commence a foreclosure proceeding against the property that secures this loan. Sincerely, Seterus, Inc. Enclosures: Act 91 Notice, PHFA list of HEMAP- approved agencies, How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS ,A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW. COLORADOATTORNEYGENERAL.GOV /CA. Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 250, Lakewood, CO 80228. The office's phone number is 888.738.5576. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board.of the Department of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR. P age] ofG Date: October 17, 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 that the lender /servicer 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 to 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 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 NOTIFICACION 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 REDEVIIR SU HIPOTECA. Page 2 of 6 HOMEOWNER'S NAME(S): KENNEY, LISA M PROPERTY ADDRESS: 32 STATE RD MECHANICSBURG, PA 17050 -3154 LOAN ACCT. NO.: ORIGINAL LENDER: MORTGAGE LENDERS NETWORK USA, INC. CURRENT LENDER/SERVICER: " Seterus, Inc. 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 time 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 /servicer 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 /servicer 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 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 /servicer 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/SERVICER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." Page 3 of 6 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER/SERVICER 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 /servicer on your property located at: 32 STATE RD MECHANICSBURG, PA 17050 -3154 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE REGULAR MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payments: March 1, 2013 through October 1, 2013 in the amount of $1,333.82 each Total: $10,670.56 Past Due Installments: $10,670.56 Other Open Charges: Prior Servicer Charges Seterus, Inc. Charges Late Charges 106.16 0.00 106.16 Property Inspections 30.00 165.00 195:00 Total Past Due Installments & Charges $10,971.72 Less Suspense (Balance) 1,166.47 TOTAL AMOUNT PAST DUE $9,805.25 Page 4 of 6 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/SERVICER, WHICH IS $9,805.25, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Seterus, Inc. PO Box 11790 Newark, NJ 07101 -4790 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 /servicer 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 regularly scheduled installments. If full payment of the total amount past due is not made within THIRTY (3 0) DAYS, the lender /servicer 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 /servicer refers your case to its attorneys, but you cure the delinquency before the lender /servicer 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 /servicer even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender /servicer, 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/SERVICER 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 THE 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 an time to one hour before the Sheriffs 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 Sheriffs Sale as specified in writing by the lender /servicer and by performing any other requirements under the mortal 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 Sheriffs Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs 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 /servicer. l:'age 5 of 6 HOW TO CONTACT THE LENDER/SERVICER: Name of Lender /Servicer: Seterus, Inc. Address: PO Box 2008 Grand Rapids, MI 49501 -2008 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Person(s): Shannon Stock or Nathan Wetzel E -Mail Address: ExternalCommunications @seterus.com EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender /servicer at any time. ASSUMPTION OF MORTGAGE - -You _ may or X may not sell or transfer your home to a buyer or transferee who will asuume 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. 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. • 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/SERVICER. • TO SEE PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Pa <ae 6 of 6 FORM 1 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY, , 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016 -28921 Plaintiff" _ i f;'S " C � ff vs. NO. q qq J c" - f 2 c LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY etU� 32 State Road E5 "`} Mechanicsburg, PA 17050 --- > Defendants 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 Mid Penn 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 AN TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Res tfully submitted: January 9, 2014 Date igna re of Counsel for Plaintiff FORM 2 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: APPLICATI CUSTOMERIPRIMARY Borrower name (s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: _ Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? C O-BORRO WER Mailing Address: City: _ State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? 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: 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. T Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support /Alim. Spending Money Day /Child Care /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 Fj No 0 If yes, please indicate the status of the application: _ Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): _ _ Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION 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 o deed FORM 3 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016 -2892 Plaintiff vs. NO. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants 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 FORM 4 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016 -2892 Plaintiff vs. NO. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants CASE MANAGEMENT ORDER AND NOW, this day of 20 the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the Plaintiff /(ender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case .shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter, offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Ll u xelts atar¢i�rre l i'�C! T}i�`�' U t , Jody S Smith Chief Deputy 2014 FEB 28 PM 3: 3E1 Richard W Stewart Solicitor ,,F,':_ ,;w CUMBERLAND OUNTY Y PENNSYLVANIA Federal National Mortgage Association vs. Case Number Laurence P Kenney, Ill (et al.) 2014-445 SHERIFF'S RETURN OF SERVICE 01/31/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Laurence P Kenney, Ill, 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 32 State Road, Silver Spring Township, Mechanicsburg, PA 17050. Property is vacant. To this date, the Mechanicsburg Postmaster has been unable to provide an updated address and the Writ has since expired. 01/31/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lisa M Kenney, 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 32 State Road, Silver Spring Township, Mechanicsburg, PA 17050. Property is vacant. To this date, the Mechanicsburg Postmaster has been unable to provide an updated address and the Writ has since expired. SHERIFF COST: $65.30 SO ANSWERS, February 24, 2014 RONISY R ANDERSON, SHERIFF MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION PLAINTIFF VS. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY DEFENDANTS { F._ rep 2014 KIR 10 P,`, 2: 19 CUP3 TR1_4ND COUNTY PENNS MANIA #33557CMS -MB : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14 -445 Civil MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Complaint and all subsequent notices upon the above captioned Defendants by regular mail and certified mail at the last known address, 32 State Road, Mechanicsburg, PA 17050 and by posting of the premises located at 32 State Road, Mechanicsburg, PA 17050 (hereinafter "Subject Premises ") and in support thereof avers the following: 1. The Plaintiff filed its Complaint in Mortgage Foreclosure against Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney on or about January 24, 2014, for the Defendants' failure to make monthly mortgage payments from March 1, 2013 for the property located at 32 State Road, Mechanicsburg, PA 17050 (hereinafter "Subject Premises "). 2. Plaintiff has been unable to complete service of its Complaint in Mortgage Foreclosure. The Sheriffs Return of Service is attached hereto made part hereof and marked as Exhibit A. 3. Pursuant to Pennsylvania Rules of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendants. 4. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefore is attached hereto, made part hereof, and marked as Exhibit B. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure and all subsequent notices by certified and regular mail at the last own address, 32 State Road, Mechanicsburg, PA 17050 and by posting of the Subject Pre ses. MARTHA E. VON ROSENS IEL, P.C. BY. artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: March 5, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY DEFENDANTS #33557CMS -MB BRIEF IN SUPPORT OF ITS MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire., moves this Honorable Court for an Order directing service of the Complaint and all subsequent notices upon the above captioned Defendants by regular mail and certified mail at the last known address, 32 State Road, Mechanicsburg, PA 17050 and by posting of the premises located at 32 State Road, Mechanicsburg, PA 17050 (hereinafter "Subject Premises ") and in support thereof avers the following: I FACTS The Plaintiff filed its Complaint in Mortgage Foreclosure against Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney on or about January 24, 2014, for the Defendants' failure to make monthly mortgage payments due March 1, 2013 for the property located at 32 State Road, Mechanicsburg, PA 17050 (hereinafter "Subject Premises "). II ARGUMENT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation, which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. The Court in Romeo v. Looks, 369 Pa. Super 608 (1982) stated that: Before resort to substituted service may be had, however, a plaintiff must have demonstrated a good faith effort to locate the Defendant through more direct means. Pa.R.C.P. 430 provides guidance as follows: An illustration of good faith effort to locate the Defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examination of local telephone directories, voter registration records, local tax records, and motor vehicle records. See also Kittanning Coal Co., Inc. v. International Mining Co.,Inc. 551 F. Supp. 834 (1982), Romeo v. Looks, 369 Pa. Super 608 (1987). As set forth in the Sheriffs Return of Service, marked Exhibit A, the Sheriff has been unable to serve the Complaint after several attempts. A good faith effort to discover the whereabouts of the Defendants has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit B. The Plaintiff submits that it has made a good faith effort to locate and serve the Defendants and has been unable to do so. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure and all subsequent notices by certified and regular mail at the last known address, 32 S . to Road, Mechanicsburg, PA 17050 and by posting of the Subject Premises. MARTHA E. VON ROSENST L, P.C. BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY DEFENDANTS #33557CMS -MB CERTIFICATE OF SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion for Special Service, Brief in support thereof, attached exhibits, and proposed Order in the above matter was made upon the following by regular first class mail, postage prepaid, deposited with the United States Postal Service on March 5, 2014: Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 This verification is made subject to the penalties of 18 Pa.C.S. §4904 re ating to unsworn falsification to authorities. MARTHA E. VON ROSENS IEL, P.C. BY: Dated: March 5, 2014 Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION PLAINTIFF VS. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY DEFENDANTS #33557CMS -MB : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14 -445 Civil VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, verifies that she is the attorney for the Plaintiff in the foregoing action; that she familiar with the facts in this matter; and that the statements made in the foregoing Motion for Special Service are true and correct to the best of her information and belief. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to u : orn falsification to authorities. Dated: March 5, 2014 MARTHA E. VON ROSENSTI : L, P.C. BY: ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff -4 . ' SHER "FF"S OFFICE OF CUMBERLAND COUNTY No r�«�= �~~~'^K .-- Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF ICE QF THE $HERIFF Federal National Mortgage Association vs. Laurence P Kenney, Ill (et al.) Case Number 2014-445 SHERIFF'S RETURN OF SERVICE 01/31/2014 Ronny R Anderson, Sheriff, being duy sworn according to Iaw, states he made diligent search and inquiry for the within named Defendant to wit: Laurence P Kenney, III, 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 32 State Road, Sflver Spring Township, Mechanicsburg, PA 17050. Property is vacant. To this date, the Mechanicsburg Postmaster has been unable to provide an updated address and the Writ has since expired. 01/31C2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lisa M Kenney, 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 32 State Roed, Silver Spring Township, Mechanicsburg, PA 17050. Property is vacant. To this date, the Mechanicsburg Postmaster has been unable to provide an updated address and the Writ has since expired. SHERIFF COST: $85,3O SO ANSWERS, February 24, 2014 s - LARRY DEL VECCHIO PROCESS SERVER FOR MARTHA E. VON ROSENSTIEL, P.C. P,O. BOX 344 CHALFONT, PA 18914 (215) 491 -4469 (215) 491 -4473 FAX Federal National Mortgage Association COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. LAURENCE P. KENNEY, III A/K/A LAWRENCE P. KENNEY, III LISA M. KENNEY NO. LAST KNOWN ADDRESS: 32 State Rd., Mechanicsburg, PA 17050 FILE NUMBER: 33557 AFFIDAVIT OF GOOD FAITH EFFORT TO LOCATE DEFENDANT (S) I hereby certify that on December 2, 2013, a good faith effort was made to discover the correct address of said defendant (s), by: 1. Inquiry of Postal authority; Postal authority has not responded after several written requests. 2. Examination of local telephone directories, 411 assistance and Internet records; Laurence P. Kenney, 32 State Rd., (717) 766 -7712, disconnected 3. Neighbor Contacts: Martin Sheely, 34 State Rd., (717) 766 -0568, adult male stated the defendants have separated and moved out of the property. He had no information as to where either defendant moved to. 4. Tax Information: - Tax office has mailing address same as property, 32 State Rd. 5, Death Records: Social Security has no death records for defendant(s) name(s). 6. Voter Registration: Defendants are registered at property, 32 State Rd. I certify that this information is true and correct to the best of my knowledge, information and belief. NOTARY PUBLIC: Sworn to and described before me this ?./,-; day COMMONV7EALTH OF PENNSYLVANIA M iAF {Y SEAL DAWN M. U:CIOTTI Warrington Twp., uucks County, My Commission Expires March 20, 2015 BY: Larry Del Vecchio, Process Server FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14 -445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. : KENNEY DEFENDANTS ORDER GRANTING MOTION FOR SPECIAL SERVICE AND NOW, this 12. day of Mb-di , 2014, upon consideration of Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Laurence P. Kenney, III Aka Lawrence P. Kenney, III And Lisa M. Kenney by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail, no signature required, and regular, first class mail at the last known address, 32 State Road, Mechanicsburg, PA 17050 and by posting the premises of 32 State Road, Mechanicsburg, PA 17050. Copy Ltd 2//2//ft BY THE COURT: #3 3 5 5 7 MBCPG MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff •• • •.• 20 d1 1 7WIBEN L\' COUNTY PENNSYLVANIA FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY Plaintiff VS. : Case No: 14-445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M,: KENNEY Defendants PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECLOSURE To the Prothonotary: Kindly reinstate the Complaint in Mortgage Foreclosure in the above matter. MARTHA E. VON ROSENSTIEL, P.C. BY: DATED: March 17, 2014 Martha E. Von Rosenst 1, Esquire Heather Riloff, Esquire Attorneys for Plaintiff $ll. 'is 7L p4,Li exit 4.32Y/ p* 3�3.c7 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. LAURENCE P. KENNEY, III AKA : CASE NO: 14 -445 Civil LAWRENCE P. KENNEY, III AND LISA M. : KENNEY Defendant(s) 33557 -SS CSV MAR 28 PH 1: 58 atitfL3ERLAND COUNTY : COURT OF COMMON PLEAS : CUMBERLAND COUNTY CERTIFICATION OF SERVICE Martha E. Von Rosenstiel, Esquire, hereby certifies that she is the attorney for the plaintiff herein and that service of the Civil Action in Mortgage Foreclosure Complaint in the above matter was made upon the defendants Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney by certified mail and by regular mail, pursuant to Court Order on March 25, 2014 . This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL. ' .C. BY: DATED: March 25, 2014 Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14-445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. : KENNEY DEFENDANTS ORDER GRANTING MOTION FOR SPECIAL SERVICE, OS emoted Order ,per .sex v -< AND NOW, this /244day of ftvigsk , 2014, upon consideration of Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Laurence P. Kenney, III/ Aka Lawrence P. Kenney, III And Lisa M. Kenney 1# mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriffs sale, by certified mail, no signature required, and regular, first class mail at the last known address, 32 State Road, Mechanicsburg, PA 17050:and by posting the premises of 32 State Road, Mechanicsburg, PA 17050. BY THE COURT: N r4 _n N m a fU rU 0 O O a P- 1-4 m r9 0 N U.S,Postal ServiceTM °CERTIFIED. MAJLTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided). For delivery information visit our website at www.usps.come 11.82 Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees sentTqLAURENCF P KPNNPY,JI AKA LAWRENCE P. KENNEY, III Street,g Mae road or PO � FiGSburgc-PA- 1.7050- City, S ate, + $3,30 $2.70 $0.00 $7.82 PS Form 3800, mir ee Reverse for Instructions N m Z- 1=3 ru fU 17 L7 17 r1 N m r9 CO N U.S. Postal Service TM CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come 'f' ,., Certified Fee Return Receipt Fee $2. 11 i (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total PostaWiebsil IKENN8482.1 Sent To Mechanicsburg, .Pq l 7D5Q Street, Apt. No.; or PO Box No. etoz��� PostmatRV HeldINIANdc'4) 03/25/2014 32 State Road City, State, ZIP +4 U.S. POSTAL SERVICE CERTIFICATE OF MAY BE USED FOR DOMESTIC AND INTERNA1 PROVIDE FOR INSUR ANCE— POSTMASTER Received From: I LI j $SEST frix fee here in stamps F, $O ,, meter poste d Z o-In, NUN of 7 ''-` m` astRttlltir effltotoVftnt f'esAA1 1110 MARTHA VON ROSENSTIEL, P.C. 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY. III 32 State Road Mechanicsburg, PA 17050 U.S, POSTAL SERVICE CERTIFICATE OF 1v1 ILIN .10P MAY BE USED FOR DOMESTIC AND INTER NA"l$ o PROVIDE FOR INSURANCE — POSTMASTER ) y ^ES - Received From: MARTHA VON ROSENSTIEL, P.C. 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: LISA M. KENNEY 32 State Road Mechanicsburg, PA 170bU I'S Form 3817, Mar.1989 ',Via fee here in stamps ( F"metostage_aO p t m ±7itqutr of "'Parfrrasietafontantat re� nnl ')nn a a. tee :'-verse for Instructions Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'F THE PROTRUNO`/\i`' 'Zak APR ~2 P11 4: |� CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Laurence P Kenney III (et sdj Case Number 2014-445 SHERIFF'S RETURN OF SERVICE 03/27/2014 01:35 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wft: Laurence P Kenney, 111, pursuant to Order of Court by "Posting" the premises located at 32 State Road, Silver Spri g Township, Mechanicsburg, PA 17050 with a true and correc copy according to Iaw. CLINE, DEPUTY 03/27/2014 01:36 PM - Deputy VVilliam Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit Lisa M Kenn pursuant to Order of Court by "Posting" the premises located at 32 State Road, Silver Spring Township, Mechanicsburg, PA 17050 with a true and correct copy according to Iaw. SHERIFF COST: $61.7Q SO ANSWERS, March 28, 2014 RONNYR ANDERSON, SHERIFF (c) CountySeite Sheriff, Teleosoff, MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / I.D. No. 52634 Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 Attorneys for Plaintiff A Y 30 P!i 2: f ,. N sERLAHJ PEN -fSYLVA,IA FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016 -2892 Plaintiff vs. LAURENCE P. KENNEY, III AKA : No. 14 -445 Civil LAWRENCE P. KENNEY, III AND LISA M. : KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, Federal National Mortgage Association by and through its undersigned counsel, Martha E. Von Rosenstiel, P.C., Martha E. Von Rosenstiel, Esquire, hereby respectfully requests that this Honorable Court enter an Order granting its Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and in support thereof, avers as follows: 1. This matter has been assigned to the Honorable Kevin A. Hess, P.J. for matters concerning the Residential Mortgage Conciliation Program. 2. This is a residential mortgage foreclosure action. 3. On or about March 27, 2014, service of the Mortgage Foreclosure Complaint was completed in this action by way of Motion for Alternative Service and the 60 day stay of proceedings went into effect pursuant to the February 28, 2012 Administrative Order. 4. As of May 28, 2014, 60 days after service of the Complaint and Notice, Plaintiff has not received notice of a Conciliation Conference date, nor a Diversion Program Financial Worksheet 5. Neither Plaintiff nor its undersigned counsel has received any communication from a housing counselor on the Defendants' behalf. 6. Plaintiff respectfully requests that it be permitted to proceed with its foreclosure action. WHEREFORE, Plaintiff, Federal National Mortgage Association, respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. MARTHA E. VON ROSEN .TIEL, P.C. BY; Dated: May 28, 2014 artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328 -2887 VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action and that the statements made in the forgoing Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, are true and correct to the best or her information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROS STIEL, P.C. artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorney for Plaintiff Date: May 28, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / I.D. No, 52634 Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff vs. LAURENCE P. KENNEY, III AKA : No. 14-445 Civil LAWRENCE P. KENNEY, III AND LISA M. : KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants CERTIFICATION OF SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and proposed order in the above matter was made upon the Defendants and Attorney as follows: Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney c/o Kara Katherine Gendron, Esquire Law Office of Dorothy L. Mott 125 State Street Harrisburg, PA 17101 by regular first class mail, postage prepaid, deposited with the United States Posta Service on 51)014 . This verification is made subject to the penalties of 18 P .C.S. §4904 relating to unsworn falsification to authorities. Dated: May 28, 2014 BY: artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW ' Washington, DC 20016-2892 Plaintiff vs. LAURENCE P. KENNEY, III AKA : No. 14-445 Civil LAWRENCE P. KENNEY, III AND LISA M. : KENNEY 32 State Road Mechanicsburg, PA 17050 Defendants ORDER OF COURT AND NOW, this 10 ` day of T14-4 , 2014, the Defendants having failed to comply with the requirements of the Cumberland County Administrative Order dated February 28, 2012, it is hereby ORDERED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. The temporary stay on this matter is terminated. BY THE COURT: #33557CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff V. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY -rt -0,-c3 Defendant(s) y''`-�' `-` or PRAECIPE FOR DEFAULT JUDGMENT -c -11 LG3 S+ : NO. 14-445 Civil To the Prothonotary: x , N...v (XX) Enter judgment in favor of Plaintiff and against: Laurence P. Kenney, III a s co _. Lawrence P. Kenney, III and Lisa M. Kenney for want of an answer. (X) Assess Damages as Follows Debt Interest from 12/20/2013 to 6/25/14 At $ $27.87 per diem Total $ 159,787.14 $ 5,239.56 $ 165,026.70 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to le this Praecipe was mailed or delivered to the party against whom judgment is to be entered . nd to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Thisa 1 day of uttl , 2014 jud MART E. VON ROSENS ' IEL, P.C. artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff t is entered in favor of the Plaintiff and against Defendant(s), Laurence P. Kenney, III aka Lawence P. Kenney III and Lisa want of an answer and damages assessed at the s�j n of $ enney by default for ove certification. Protirivp y, • . rl County Qvvw 1(4.Sopeig &-k 1#S7, 3 1 12 tt 30-77 "y MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff v. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY Defendants #33557CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-445 Civil TO: Laurence P. Kenney, III aka Lawrence P. Kenney, III 32 State Road Mechanicsburg, PA 17050 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 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 NOTICE TO A 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 6/13/14 a E. Von R Heather Riloff, Es Attorneys for Plain el, Esquire MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA I9018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff v. LAURENCE P KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY Defendants #33557CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-445 Civil TO: Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY 13E ENTERED AGAINST. YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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 SERVICES TO ELIGIBLE PERSONS ATA REDUCED FEE QR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 t .. 717-249-3166. 800-990-9108. Dated: 6/13/14 MARTHA E. VON ROSENSTIEL, P.C. BY: _-+- Martha E. Von Rose Heather Riloff, Esqu Attorneys for Plaintiff 1. I, Esquire #33557CFJ-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY Plaintiff vs. : No: 14-445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. : KENNEY, III AND LISA M. KENNEY Defendant(S) NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, P.C. by the undersigned hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent •r a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S. . Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswo falsification to authorities. MAR ' E. VON ROSENST L, P.C. Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff Dated: June 25, 2014 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Laurence P. Kenney, III aka Lawrence P. Kenney, III 32 State Road Mechanicsburg, PA17050 FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. LAURENCE P. KENNEY, III AKA : NO: 14-445 CIVIL LAWRENCE P. KENNEY, III AND LISA M. : KENNEY DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $165,026.70 on June 25, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY PLAINTIFF VS. LAURENCE P. KENNEY, III AKA : NO: 14-445 CIVIL LAWRENCE P. KENNEY, III AND LISA M. : KENNEY DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $165,026.70 on June 25, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION v. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY 33557CWE-DN COURT OF COMMON PLEAS DOCKET NO. 14-445 Civil ATTORNEY I.D. #52634 ATTORNEY I.D. #309906 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 6/26/2014 to 12/3/2014 At6% TOTAL* *Plus costs to be endorsed PREM: 32 State Road, Mechanicsburg, PA 17050 c rn rn c. Nr $ 165,02 $ 436' $ 169,3943% MARTHA E. VON ROSENSTi EL, P.C. BY ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff baso,Pe)2w s�w&Y t/GY d �. C���sia3 #33557 -DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-445 CIVIL LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. : KENNEY Defendant(s) LEGAL DESCRIPTION ALL THOSE CERTAIN pieces or parcels of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: LOT #1 BEGINNING at a spike on the center line of the public road leading from Mechanicsburg to the New Kingston Road at corner of lands now or late of the Laura C. Gross Estate; thence by the center line of said road, South 82 degrees West, one hundred five (105) feet to a spike; thence by other lands now or late of Tolbert L. and Pearl M. Bricker, North 00 degrees 45 minutes East, two hundred fifty-seven (257) feet to a pin; thence by the same, North 82 degrees East one hundred five (105) feet to a pin; thence by lands now or late of the Laura C. Gross Estate, South 00 degrees 45 minutes West, two hundred fifty-seven (257) feet to a spike, the place of BEGINNING. CONTAINING .62 acres HAVING thereon erected a brick ranch type dwelling This description is in accordance with a survey made November 24, 1958 by W.G. Rachel, Registered Surveyor LOT #2 BEGINNING at a point in the center of the public road leading from Mechanicsburg to the New Kingston Road at corner of other lands now or late of Paul J. Hess and Mildred E. Hess; thence by other lands now or late of Paul J. Hess and Mildred E. Hess, North 00 degrees 45 minutes East, two hundred fifty-seven (257) feet to a point; thence by the same, North 82 degrees east, one hundred five (105) feet to a point; thence by lands now or late of the Laura Gross Estate, North 00 degrees 45 minutes East, thirty-five and six tenths (35.6) feet to a point; thence by other lands now or late of Tolbert L. Bricker and Pearl M. Bricker, his wife, South 00 degrees 45 minutes West, two hundred ninety-two and six tenths (292.6) feet to a point in the center of the aforesaid public road; thdnce'by the center line of said road, North 82 degrees East, ten (10) feet to a point, the place of BEGINNING. BEING a strip of land shown on the land of Tolbert L. Bricker PARCEL IDENTIFICATION NO: 38-23-0571-015 IMPROVEMENTS: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Laurence P. Kenney, III and Lisa M. Kenney, his wife, by Deed from Laurence P. Kenney, III and Lisa M. Kenney, his wife, dated 06/16/2006, recorded 06/26/2006 in Book 275, Page 1446. #33557CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-445 CIVIL LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. : KENNEY Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 32 State Road, Mechanicsburg, PA 17050: 1. Name and address of owners(s) or reputed owner(s) Laurence P. Kenney, III aka Lawrence P. Kenney, III 32 State Road Mechanicsburg, PA 17050 Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 2. Name and address of defendant(s) in the judgment: Laurence P. Kenney, III aka Lawrence P. Kenney, III 32 State Road Mechanicsburg, PA 17050 Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE z 4. Name and address of the last recorded holder of every mortgage of record: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 Occupant 32 State Road Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct upon infcrmation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. . Section 4904 relating to unsworn falsification to authorities. Dated: June 24, 2014 BY. MARTHA E. VON ROSENST L, P.C. a E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff 33557CAM-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. KENNEY Defendant(s) r apt, l L Eo t, Tyc PS OFFi EQI 801710):14 14 juk C1M8E: I AlyC PENNSYC VA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14-445 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 32 State Road Mechanicsburg, PA 17050 will be sold by the Sheriff of Cumberland County on Date of Sale: December 03, 2014 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 14-445 Civil in the Court of Common Pleas of Cumberland County by Federal National Mortgage Association, Plaintiff against Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney, Defendant(s). Judgment was entered on June 25, 2014 in the amount of $165,026.70. The property was seized and taken in execution as the property of Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney. The property to be sold at Sheriff's Sale is described as follows: ALL THOSE CERTAIN pieces or parcels of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: LOT #1 BEGINNING at a spike on the center line of the public road leading from Mechanicsburg to the New Kingston Road at corner of lands now or late of the Laura C. Gross Estate; thence by the center line of said road, South 82 degrees West, one hundred five (105) feet to a spike; thence by other lands now or late of Tolbert L. and Pearl M. Bricker, North 00 degrees 45 minutes East, two hundred fifty-seven (257) feet to a pin; thence by the same, North 82 degrees East one hundred five (105) feet to a pin; thence by lands now or late of the Laura C. Gross Estate, South 00 degrees 45 minutes West, two hundred fifty-seven (257) feet to a spike, the place of BEGINNING. CONTAINING .62 acres HAVING thereon erected a brick ranch type dwelling This description is in accordance with a survey made November 24, 1958 by W.G. Rachel, Registered Surveyor LOT #2 BEGINNING at a point in the center of the public road leading from Mechanicsburg to the New Kingston Road at corner of other lands now or late of Paul J. Hess and Mildred E. Hess; thence by other lands now or late of Paul J. Hess and Mildred E. Hess, North 00 degrees 45 minutes East, two hundred fifty-seven (257) feet to a point; thence by the same, North 82 degrees east, one hundred five (105) feet to a point; thence by lands now or late of the Laura Gross Estate, North 00 degrees 45 minutes East, thirty-five and six tenths (35.6) feet to a point; thence by other lands now or late of Tolbert L. Bricker and Pearl M. Bricker, his wife, South 00 degrees 45 minutes West, two hundred ninety-two and six tenths (292.6) feet to a point in the center of the aforesaid public road; thence by the center line of said road, North 82 degrees East, ten (10) feet to a point, the place of BEGINNING. BEING a strip of land shown on the land of Tolbert L. Bricker PARCEL IDENTIFICATION NO: 38-23-0571-015 Tax ID #38-23-0571-015 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 14-445 Civil. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schede of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY PLAINTIFF VS. : NO: 14-445 Civil LAURENCE P. KENNEY, III AKA LAWRENCE P. KENNEY, III AND LISA M. : KENNEY DEFENDANTS ORDER GRANTING MOTION FOR SPECIAL SERVICE 3355# oR..s 6 rant ed 06er- ,Poc r v 'c_.a G=.3 47- AND NOW, this /2416ay of Paap_r_ , 2014, upon consideration of Plaintiff's Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Laurence P. Kenney, III Aka Lawrence P. Kenney, III And Lisa M. Kenney by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail, no signature required, and regular, first class mail at the last known address, 32 State Road, Mechanicsburg, PA 17050 and by posting the premises of 32 State Road, Mechanicsburg, PA 17050. BY THE COURT: 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 FEDERAL NATIONAL MORTGAGE ASSOCIATION Vs. NO 14-445 Civil Term CIVIL ACTION — LAW LAURENCE P. KENNEY, III A/K/A LAWRENCE P. KENNEY, III AND LISA M. KENNEY 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: $165,026.70 L.L.: $.50 Interest FROM 6/26/2014 TO 12/3/2014 AT 6% - $4,367.93 Atty's Comm: Atty Paid: $287.59 Plaintiff Paid: Date: 6/27/14 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff VS. #33557CAM -AIN 0/4j/j � ��` /fr. e y r�, Pr 4 3 , ��©C j : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-445 CIVIL LAURENCE P. KENNEY, III AKA LAWRENCE : P. KENNEY, III AND LISA M. KENNEY Defendant(s) AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned for the Plaintiff in the above action, hereby verifies that on , true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authorities. BY MARTHA E. VON ROSENS r L, P.C. Ma ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff For Accountable Mall Name and MARTHA E. VON ROSENSTIEL, P.C. Address AttorneyAt Law❑With of 649 South Avenue, Unit 7 Sender 33557 Secane, PA. 19018 DN Indicate type of mail 0 Registered 0 Return Receipt for Merchandise 0Insured 0 COD 0 Intl Recorded Del. 0 Certified 0 Express Mail Check appropriate block for Registered Mail: Postal Insurance 0 Without Postal Insurance Affix stamp here if issued as certified of mailing or for additional copies of this itt.SPossl. s. �'It. t�,e -1, ;, . e Re 'P - - -- - f gym. .4 ? SII------..- . PITNEY BOWES t. _ -4.. 02 1P $ 005.17° n, Line Article Name of Addresses, Street, and •Number Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value SD der e If COD a Fi R. R. Fee S. D. Fee MAILED S. H. Fee FROM Begte@IDad9018 Remarks 1# Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA. 17013 .48 2 Cumberland Register of Wills County Courthouse Carlisle, PA. 17013 .48 3 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC. 20044 .48 4 PA Department of Revenue Inheritance Tax Division, P.O. Box 280601 Harrisburg, PA 17128 .48 5 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA. 17013 .48 6 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 .48 7 Department of Public Welfare P.O. Box 2675 Harrisburg, PA. 17105 .48 8 Occupants/Tenants 32 State Road Mechanicsburg, PA 17050 .48 9 PA. Department of Revenue Bureau of Individual Taxes P.O. Box 280603 Harrisburg, PA. 17128 .48 _ 10 > Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 Laurence P. Kenney, Ill aka Lawrence P. Kenney, Ill 32 State Road Mechanicsbur•, PA 17050 .48 .48 purl POS? y�C F o y� 9 8 . 1.� 11 Total Number of Pieces Listed by Sender I / f Total Number ofs Pieces• Received at Postmaster, %- Name of Re iving Employee) ° /7 -`[/ Li \ FCA NE. ` �°j ? U.S. Postal ServiceTm CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delive motion visit our webs U.S. Postal Seri/ice,. ' CERTIFIED, MAIL. RECEIPT . (Domestic Mail Ony; No Insurance Coverage Provided) For deliveryntorma on visitour website at www.usps.comb 1710 0002 227 Postage edified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required Total Postage & Fees ru 05 Noo ru N/1.• ru re 0 c3 Return Receipt Fee p—I 41- ,..„11`3 (Endorsement Required) Restricted Delivery Fee 0 : c3,4 (Endorsement Required) 19 N Total Postage & Fees Postage Certified Fee t)71fY r • PS Form 3800, August 2006 See Reverse for Instructions U.S. POSTAL SERVICE CERTIFICATE OF MA MAY BE USED FOR DOMESTIC AND INTERNATIONAL PROVIDE FOR INSURANCE—POSTMASTER Received From: MARTHA VON ROSENSTIE 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: NG 0 Atm ree nere in stamps p.10 griatoostage and Post mark 4e of r4 (=If cps. PITNEY BOWES 02 1P L&.Kohne 3 L S-kt-e_rje)A 11/Itc,ktni e•A $ 001.300 •.• II A ED FROM ZIP CODE 19018 pOST \Co PS Form 3817, Mar.1989 3S'7 biu IJ S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE—POSTMASTER Received From: MARTHA VON ROSENSTIE 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: 02 — , MAI Mem6id C.ciefq Crth-l-a14106 566d L_Wi I ktelap'cs)fil rioss PS Form 3817, Mar.1989 Atrix tee nere in stamps Or meter postage and grAtPiRal;t7 Inquire of Postmastegior current Cifivels7=0% —PITNEY BOWES 1P $ 001.300 I • a. so • ED FROM ZIP CODE 1 33 SS'? b) See Reverse for Instructions PLAINTIFF: Federal National Mortgage Association DEFENDANT Laurence P. Kenney,111 aka Lawrence P. Kenney,111 and Lisa M. Kenney SERVE UPON: Lisa M. Kenney 32 State Road Mechanicsburg, PA 17050 SPECIAL INSTRUCTIONS: PLEASE POST PER COURT ORDER AFFIDAVIT OF SERVICE COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 14-445 Civil TYPE OF ACTION XX Notice of Sheriffs Sale Sheriffs Sale Date:12/3/2014 A, 'J SERVED r/V' Served and made known to LISA • W,G J#1 Ey Defendant, on the 143'day of 11=T0 o'clock, 4 . M., at q} 57 @ }ZD, /Irtce44-4Klcs$JRl- Commonwealth described below: P LED-OFF1Cr OF THE PROTHONOTARY 20IIf AUG -4 PM 3: 17 CUMBERLAND COUNTY PENNSYLVANIA 33557 -DN 1"14 L� , 20#4-, at of Penn ylvania, in the manner Defendant personally served. Manager/Clerk of place of lodging In which Adult family member with whom Defendant resides. Defendant resides. Agent or person In charge of Defendant's office Relationship is Adult in charge of Defendant's residence who or usual place of business. V Other refaced to give name/relationship. p6STe16• Description: Age Height Weight I, Ronald Moll Race Sex Other , a competent adult, being duly swom according to law, depose and state that I personally bonded to 32. ST1 'RD r M 6cµrNv res BA,R..6, PA a true and correct copy of the Notice of Sheriffs Sale issued In the captioned case on the date and at the address indicated above. Sworn to and subsc 'b before me this of Notary: NOT SERV l By: 20 at (4.14KIMBERLY G CURTY (,/ ID # 2295304 1 NOTARY PUBLIC STATE OF NEW JERSEY o'clock — M., Defendant Novlftiemellietign Expires March 7, 2015 No Answer Vacant Time of Attempt: Dale of Attempt: Result: Swom to and subscribed before me this day of , 200_ Notary: 1 ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 PLAINTIFF: Federal National Mortgage Association DEFENDANT • Laurence P. Kenney, III aka Lawrence P. Kenney, III and Lisa M. Kenney SERVE UPON: Laurence P. Kenney,111 aka Lawrence P. Kenney, Ili 32 State Road Mechanicsburg, PA 17050 AFFIDAVIT OF SERVICE FILED-DFFICL OE THE PROTHONOTARY 2014 AUG -4 PM 3:17 COURT OF COMMON PLEAS Cumbcrland .COUNTY CUMBERLAND COUNTY COURT NO. 14-445 Civil PENNSYLVANIA TYPE OF ACTION XX Notice of Sheriffs Sale 33557 -DN SPECIAL INSTRUCTIONS: please POST PER COURT ORDER Sheriffs Safe Date: 12/3/2014 L,qu9eAI P. YON& Cl 'ay ALA SERVED Served and made known toLpyBru /ce. P. I NNFy , Es Defendant, on the I4l'day of \ L Y , 2044 , at n:VO o'clock, j4- . M., at 31 Stare. P.oP.b,Mactohutc1J31426 , Commonwealth of Pennsylvania, in the manner described below: Defendant personally nerved. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Agent or person in charge of Defendant's office Relationship Is . Adult in charge of Defendant's residence who or usual place of business. _ Other n POSTE,* T* refused 10 give name/relationship. DescrlpUon: Age Height Weight Ronald Moll POSTEp I, a competent adult, being duty swom according to law, depose and state that I personally. ganded- to. 3t. 5 TitTE. RoAl) , ME,c4AivtcS. ugh- r P4 a true and correct copy of the Notice of Sheriffs Sate issued in the captioned case on the date and at the address Indicated above. Race Sex Other Sworn to and subscri before me this 14b d day of , 20 Notary: �l NOT SERV On the Move awn 20 . at o'clock _, M., Defendant NOT F No Answer Vacant KIMBERLY G CURT'Y ID # 2295304 NOTARY PUBLIC STATE OF NEW JERSEY My Commission Expires March 7, 2018 Time of Attempt: Date of Attempt: Result: Swom to and subscribed before me this of Notary: day 200 . By: ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 #33557CAM - CS MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff OF 7 1E 2014 SEP -8 Pig 2; 1 CtitIBERL,11) COUNT }/ PE.NNSA1YLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY 'VS. LAURENCE P. KENNEY, III AKA : NO: 14-445 CIVIL LAWRENCE P. KENNEY, III AND LISA M. : KENNEY Defendant(s) SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C., attorney for the Plaintiff in the above action, hereby verifies that on September 3, 2014, true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders listed below and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. 'Bureau of Compliance Dept. 280948 Harrisburg, PA 17128-0948 I verify that the statements made in this affidavit are true and correct 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. Dated: September 03, 2014 MARTHA E. VON ROSENST I , P.C. ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff .$. POTAL SERVICE CERTIFICATE OF MAIL NG MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, ampicv PROVIDE FOR INSURANCE —POSTMASTER Received From: A THA E. VON RO FCNF PA 1O1 One piece of ordinary mail addressed to: Affix fee here in stamps or 01010i peatage end post mark. Inquire of Postmaster for current sal' ovre0E7r o r o••• 001.300 001 /353 SEP 03 ILED FROM 41P.r Cs. PS Form 3817, Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY rIME3 Rl A/ f) COW J:Ji IU_1 �t�i� � Vlli 4 PENNSYLVANIA Federal National Mortgage Association Case Number vs. Laurence P Kenney aka Lawrence P. Kenney, Ill (et al.) 2014-445 SHERIFF'S RETURN OF SERVICE 09/29/2014 05:35 PM - Deputy Christopher Sharpe, 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 32 State Road, Silver Spring - Township, Mechanicsburg, PA 17050, Cumberland County. 12/03/2014 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, Carlisle, Cumberland County, Pennsylvania on December 03, 2014 at 10:00AM. He sold the same for the sum of $1.00 to Attorney Martha Von Rosenstiel, on behalf of Federal National Mortgage Association. Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $1,437.30. SHERIFF COST: $1,437.30 SO ANSWERS, January 12, 2015 RONNY R ANDERSON, SHERIFF 76 ci CouritySu: e Sheriff. Teleosoft, Inc