HomeMy WebLinkAbout14-1761 Supreme Court of Pennsylvania
COurf Of CO. mdn lam Pleas For Prothonotary Use Only:
� „` � � '.
C>tvil, Cover Sheet
'q b Docket No:
UMR .R AN C011Ilty yr 6 I/l L
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S M Complaint Writ of Summons El Petition
E] Transfer from Another Jurisdiction Declaration of Taking
E
Lead Plaintiff's Name: Lead Defendant's Name:
C MIDFIRST BANK TRACY L. BRETZ
T I Dollar Amount Requested: Dwithin arbitration limits
I Are money damages requested? 0 Yes 0 No (check one) i3outside arbitration limits
0
N Is this a Class Action Suit? Yes U No Is this an MDJAppeal? 0 Yes ® No
A Name of Plaintiff/Appellant's Attorney: Leon P. Haller / Jill M. Wineka
Check here if you have no attorney (are a Self - Represented (Pro Se] :Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
Intentional [3 Buyer Plaintiff Administrative Agencies
Malicious Prosecution 0 Debt Collection: Credit Card El Board of Assessment
Motor Vehicle 0 Debt Collection: Other Board of Elections
Nuisance Dept. of Transportation
E] Premises Liability El Statutory Appeal: Other
S Product Liability (does not include
mass tort) El Employment Dispute:
E Discrimination
0 Slander/Libel/ Defamation
0 Other:
Other: Employment Dispute: Other Zoning Board
El Other:
I Ej Other:
MASS TORT
El Asbestos
E] Tobacco
0 Toxic Tort - DES
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste Ejectment [3 Common Law /Statutory Arbitration
B 0 Other:
Eminent Domain/Condemnation [3 Declaratory Judgment
Q Ground Rent [3 Mandamus
Landlord/Tenant Dispute Non - Domestic Relations
Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY E3 Mortgage Foreclosure: Commercial Quo Warranto
Dental El Partition Replevin
Legal E] Quiet Title El Other:
Q Medical E] Other:
Other Professional:
Updated 11112011
•r
Leon P. Haller, Esquire �� �f
Purcell, Krug & Haller
1719 North Front Street RLA14f' COU 'S'
Harrisburg, PA 17102 {, EIV E.{ 1 S Y LVA U41 A
717.234.4178
mtg @pkh.com
MIDFIRST BANK IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
TRACY L. BRETZ, SULTAN A. JOHNSON AND ACTION OF MORTGAGE FORECLOSURE
THE SECRETARY OF HOUSING AND URBAN
DEVELOPMENT
Defendants
/ e-R
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action
within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so
the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money
claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE _...
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717- 249 -3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA
Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE
USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED
PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE
ABOGADOS), (215) 238 -6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
"�a 3 X31
MIDFIRST BANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION LAW
TRACY L. BRETZ, SULTAN A. JOHNSON AND ACTION OF MORTGAGE FORECLOSURE
THE SECRETARY OF HOUSING AND URBAN
DEVELOPMENT
Defendants
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.C. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within -thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor. --
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234 -4178
Attorney I.D.# 15700
Attorney for Plaintiff
MIDFIRST BANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
TRACY L. BRETZ, SULTAN A. JOHNSON AND ACTION OF MORTGAGE FORECLOSURE
THE SECRETARY OF HOUSING AND URBAN
DEVELOPMENT
Defendants
COMPLAINT IN MORTGAGE FORECLOSURE
1. The Plaintiff is MIDFIRST BANK, a Federally Chartered Savings Association, whose address is 999
N.W. GRAND BOULEVARD, OKLAHOMA CITY, OK 73118.
2. The Defendants., TRACY L. BRETZ and SULTANA. JOHNSON, are adult individuals whose -last
known address is 17B WEST GLENWOOD, DRIVE CAMP HILL, PA 17011.
3. Defendant, THE SECRETARY OF HOUSING AND URBAN DEVELOPMENT (hereinafter referred
to as HUD), is an instrumentality of the United States of America with an address of 451 SEVENTH
STREET, SW, WASHINGTON, DC 20410.
4. HUD holds a Mortgage against the below property pursuant to Mortgage dated May 17, 2013 and
recorded October 30, 2013 as Instrument Number 201335177 in the amount of $21,449.97. A copy of
said Mortgage is attached hereto as Exhibit "A ".
5. On or about, December 11, 2006, the Defendants executed and delivered a Mortgage Note in the sum of
$104,139.00 payable to 1 ST PREFERENCE MORTGAGE CORPORATION, which Note is attached
hereto and marked Exhibit `B ".
6. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment the same, the Defendants made, executed, and delivered to Mortgage Electronic
Registration Systems, Inc. as Nominee for 1 St Preference Mortgage Corporation, a certain real estate
Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth
on December 19, 2006 in Mortgage Book 1976, Page 3443 conveying to original Mortgagee the subject
premises. On February 13, 2009, the Plaintiff and Mortgage Electronic Registration Systems, Inc. a
Nominee for The Plaintiff and the Defendants executed a Loan Modification Agreement changing the
amount of the Unpaid Principal Balance to $103,057.63, changing the monthly payment amount and
changing the Maturity Date. The Loan Modification Agreement was recorded April 7, 2009 as
Instrument Number 200910806. The Mortgage was subsequently assigned to MIDFIRST BANK and
was recorded on October 21, 2010 in the aforesaid County as Instrument Number 201030193. On
January 19, 2011, the Plaintiff and the Defendants executed a Loan Modification Agreement changing
the amount of the Unpaid Principal Balance to $117,923.73, changing the monthly payment amount,
changing the Maturity Date and changing the Interest Rate to 5.25 %. The Loan Modification
Agreement was recorded March 2, 2011 as Instrument Number 201107013. The said Mortgage and
Assignment are incorporated herein by reference.
7. The land subject to the Mortgage is: 17B WEST GLENWOOD, DRIVE CAMP HILL, PA 17011 and is
more particularly described in Exhibit "C" attached hereto.
8. The Defendants are the real owners of the property.
9. The Mortgage is in default due to the fact that the Mortgagors have failed to pay the installment due on
September 01, 2013 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE $113,550.43
Interest at $12.06 per day $2,929.39
From 08/01/2013 To 04/01/2014
( based on contract rate of 3.8750 %)
Accumulated Late Charges $241.68
Good through 03/10/2014
Escrow Deficit $584.28
Corporate Advance $226.45
Attorney's Fee at 5% of Principal Balance $5,677.52
TOTAL $123,209.75
* *Together with interest at the per diem rate noted above after April 01, 2014 and other charges and
costs to date of Sheriff's Sale.
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the
Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually.
incurred by Plaintiff.
10. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendants by letters
dated January 13, 2014 as required by Pennsylvania Act No. 6 of 1974, as amended. Copies of the
January 13, 2014 Act 6 Notices are attached hereto and marked Exhibit "D ".
11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
12. The Defendants are not members of the Armed Forces of the United States of America, nor engaged in
any way which would bring them within the Service Members Civil Relief Act, as amended. Copies of
the website reports from the Department of Defense Manpower Data Center, confirming non - active
military duty are attached as Exhibit "E ".
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 3.8750% ($12.06 per diem), together with other charges
and costs including escrow advances incidental thereto to the to heriff's Sale and for foreclosure and sale
of the property within described.
By:
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
I.D. # 15700 _ n
Jill M. Wineka
I.D. #58802
Attorneys for Plaintiff
1719 N. Front Street
Harrisburg, PA 17102
(717- 234 -4178)
�' r S S x } �� ~ ! W� lip ��
OOUXG
When recorded rnaH to: #:8266539
First Arrmerican Title
Loss Mitigation Title Services 1348.1
P "O. Box 27670
Santa Ana, CA 92709
RE: BRETZ - RG REG SVC
D00UMent Prepared by:
Patricia Edwards
Midland Mortgage - A Division of MidFirst Bank
999 NW Grand Boulevard, Suite 10
Oklahoma City, OK 7911 "116
1 -8t}9 552 -3000
- 1311111'1
FHA Case Number: 441.7889745793
SUBORDINATE MORTGAGE
THIS SUBORDINATE MORTGAGE (Security Instrument ") is given on May 17, 2013.
The mortgagors are TRACY L BRETZ & SULTAN A JOHNSON (Borrower "). This Security
Instrument is given to the Secretary of Housing and Urban Development, which is organized
and existing under the laws of the United States of America, and whose address is 451
Seventh Street, Slits, Washington, DEC 20419 ('Lender). Borrower oyes Lender the principal
sum of twenty dollars and ninety-seven cents (US
$21,449.97). This debt is evidenced by Borrower's note dated the same date as this Security
Instrument ( "Note "), which provides for the full debt, if not paid earlier, due and payable on
W1=43. This Security Instrument secures to Lender: (a) the repayment of the debt evidenced
by the Nate, and all renewals, extensions and modifications of the Note; (b) the payment of all
other sums advanced to protect the security of this Security Instrument* and (c) the performance
of Borrower's covenants and agreements under this Security Instrument and the Note. For this
Page 1 of the Subordinate Mortgage o r I nitial Urtes
NR -
Pleats add t ignatory aver 4
appropriate number at in7tial lines each 5"
. e f
SMN6: E 6353 d3
purpose, Borrower does hereby mortgage, grant and convey to Lender the following described
property located in CUMBERLAND County, Pennsylvania:
See Exhibit "A' attached hereto and made a part hereof.
Being the same property conveyed to TRACY L bAEIZ AND SULTAN A JOH* NSON by peen
of Trust recorded 1211912006 and recorded in Book 278 on Page 175 in CUMBERLAND.
County, Pennsylvania.
Tax ID # 09161 050285
which has the address of: 17 B WEST GLENiIk OOD DRIVE CAMP HILL, PA 17011 ("Property
Address " );
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances and fixtures now or hereafter a part of the property. All
replacements and additions shall also be covered by this Security Instrument. All of the
foregoing is referred to in this Security Instrument as the "Property"
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and
has the right to mortgage, grant and convey the Property and that the Property is
unencumbered, except for encumbrances of record. Borrower warrants and will defend
generally the title to the Property against all claims and demands, subject to any encumbrances
of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument
covering real property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1, Payment of Principal
Borrower shall pay when due the principal of the debt evidenced by the Note.
2. Borrower Not Released: Forbearance ?y Lender Not a Waiver
Extension of the time of payment of the surds secured by this Security Instrument
granted by Lender to any successor in interest of Borrower shall not operate to
release the liability of the original Borrower or Borrower's successor in interest.
Lender shall not be required to commence proceedings against: any successor in
interest or refuse to extend time for payment or otherwise modify amortization of the
surds secured by this Security instrument by reason of any demand made by the
original Borrower or Borrower's successors in interest, Any forbearance by Lender in
Page 2 of the Subordinate Mortgage 3o ` ower Initial Lines
ok
Please add the appropriate number of initial lines for each signatory over 4
- , � 4bJAiP fiYEfi35YRi
s c
BY SIGNING BELOW, Sorrower accepts and agrees to the terms and covenants contained: in
this Security Instrument and in any riders) executed by Borrower and recorded with it. IN
WITNESS WHEREOF, Borrower has executed this Security Instrument.
B ORR OWER
- S - 1 3
dclY L BR Date
SULTANA JOHNSON - Date
Acknowledgement
STATE OF Pennsylvania )
� COUNTY OF CUMBERLAND SS:
On the -< day of 20j before me, the undersigned, a notary public in and
for said state, personally appeared TRACY L BRETZ & SULTAN A JOHNSON, personalty known to me
or proved to me on the basis of satisfactory evidence to be the Individuals) whose name(s) is (are)
subscribed to the within instrument and acknowledged to me that hetshetthey executed the same in
hisiherftheir capacity(ies), and that by histherAheir signature(s) on the instrument, the individual(s) or the
person upon behalf of which the individual(s) acted, executed the instrument.
In witness whereof, I hereunto set my hand and official seat.
County of Residence: e4261,6nbqtll
Notary Pub cc
.�— Commission Number. t2—�'3
Printed name of notary Idly Commission Expires:
.E tlx OF F� vANtA
NOTAWAL SEAL
DONALD TRAU
Nalary Public
LEMOM ROAOUQH, CUMBERLAND Copy
My Caaurd"IN Esping Jun 9, 2017
Page 6 of the Subordinate Mortgage
.1i9(18'aUE675267
• 'a
Exhibit "A°
BEGINNING AT A POINT ON THE WESTERLY LINE OF GLENWOOD DRIVE (WEST),
WHICH POINT IS 295.06 FEET NORTH OF THE NORTHWESTERLY CORNER OF
GLENWOOD DRIVE (WEST) AND ERFORD ROAD (WEST), AND AT DIVIDING LINE
BETWEEN LOTS 3X_ AND 4 BLOCK - H" ON THE HEREAFTER MENTIONED PLAN OF
LOTS; THENCE ALONG SAID DIVIDING LINE, NORTH 63 DEGREES 30 MINUTES WEST,
115 FEET TO A POINT; THENCE ALONG THE EASTERLY UNE OF LOTS 23X AND 23,
NORTH 26 DEGREES 30 MINUTES EAST, 37.5 FEET TO AA POINT AT THE DIVIDING LINE
BETWEEN LOTS 4 AND 4X, BLOCK 'H" ON SAID PLAN; THENCE ALONG SAID DIVIDING
LINE, SOUTH 63 DEGREES 30 MINUTES EAST AND THROUGH THE CENTER PARTITION
WALL AND BEYOND, 115 FEET TO A POINT ON THE WESTERLY LINE OF GLENWOOD
DRIVE (WEST), AFORESAID; THENCE ALONG SAME, SOUTH 26 DEGREES 30 MINUTES
WEST, 37.5 FEET TO A POINT, THENCE PLACE OF BEGINNING.
Page 7 of the Subordinate Mortgage
a YDtFl F.63 €63 5Q rd3
. i .artgage A Diukian of 11 dFi Ban
P 0. Box 268906 * 4kl4boma CiN OK. 73126
Tel: 840.SS2.3000 + Fax: 405.767.5815 * MyMfdtandMorteaRe.cOM
Certificate of Residence
ir��x7�1 NCB , do hereby certify that the correct address of
the within - named mortgagee is 451 Seventh Street', SW, Washington, DC 20410.
Witness my hand this day of ter M4 20J3.
gent of M gig Q—
Loaan fD: 8382
.I�..rt. ...er •vl.... ._�i.u.FiF' "+rr�.. M:,�... w..�... y.....,, .... r.. ....
ROBERT P. ZIEGLER
RECORDER.. OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE ' -
CARLISLE, PA 17013
717 -240 -6370 -' AA
Instrument; Number - 201335177
Recorded On 10/30/2013 At 11.10:12 AM *Total Wages 9
* Instrument Type - MORTGAGE
Invoice Number 150258 User ID - KW
* Mortgagor - JOHNSON, SULTAN A
* Mortgagee - HOUSING & URBAN DEV SEC
* Customer - FIRST AMERICAN TITLE Co
* FEES ..--.
STATE WRIT TAX $0 . 50 Certification Page
STATE JCS /ACCESS.TO $23.50
,JUSTICE DO NOT DETACH
RECORDING FEES $19.50
RECORDER OF DEEDS This c`t
PARCEL CERTIFICATION $15.40 g is now part
FEES of this legal document.
AFFORDABLE ROUSING $11.50
COUNTY ARCF.IMS FEE $2.00
ROD ARCHIVES FEE $3.40
TOTAL PAID $75.00
I Certify this to be recorded
in Cumberland County PA
RECORDER Q 'DS� .
* Information denoted by an asterisk may change during
the verification process and may not be reflected on this page:
NOTE
OR87Z
i - Loan 0; 36400230
MIN:100002200364002309
CwcN; 441- 7099745 -703
DECEMBER 11, 2006 I HARRISBURG PENNSYLVANIA
[Date] I [City] [State]
j
17 B WEST GLENWOOD DRIVE, CAMP HILL, PA 17011
[Property Address]
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender"
means 1ST PREFERENCE MORTGAGE CORP. and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
in return for a loan received from Lender, Borrower promises to pay the pnncipal sum of ONE.. HUNDRED FOUR
THOUSAND ONE HUNDRED THIRTY- MINE "AND 007100 Dollars (U.S. 5104 ,139. 00), plan Interest, to the order of
Lender. Interest -will be charged on unpaid principal. from the date of disbursement of the loan proceeds by Lender. at the rate
of SIX AND THREE - FOURTHS percent (6. 7 '50 %) per year until the full amount of principal has been paid.
t t
3. PROMISE TO PAY SECURED r
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same
date as this Note and called the "Security Instrument." Tliat Security instrument protects the Lender from losses which might
result if Borrower defaults under this Note.
i
4. MANNER OF PAYMENT i
(A) Time
Borrower shall make a payment of "principal and interest to Lender on the first day of each month beginning on
FEBRUARY 1. 2007. Any principal and inic(cst retraining on the first day of JANUARY, 2022, will be due on that date,
which is called the "Maturity Date." I"
(B) Place
Payment shall be made at 9423 BELAIR ROAD - . BALTIMORE, MD 21236 or at such place as Lender may
designate in writing by notice to Borrower. I
(C) Amount
Each monthly payment or principal and interest will be in the amount 017 U.S. 5921.54. This amount will be pan o(n
larger monthly payment required by the Security instrument, that shall be applied to pnncipal, interest and other items in the
order described in the Security Instument. i
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Nate, the covenants of the
allonge shall be incorporated into and shall aniend and supplement the covenants of this Note as if the allonge were a pan of
this Note. [Check applicable box.] j
❑ Graduated Payment Allonge ❑ Growing Equity Allonge ❑ Other [Specify] i
i,
5. BORROWER'S RIGHT TO PREPAY
i
Borrower has the right l0 pay the debt evidenced by this Note, in whole or in pan, without charge or penalty, on the i
first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount
prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If
Borrower makes a partial prepayment, there will be no changes In the due date or in the amount of the monthly payment unless
Lender agrees in writing to those changes.
6. BORROWER'S FAILURE TO PAY l
V 36J4 page t ort FHA Mul Fixed Rule Note - 12N1
oals is
EA . ........
n
X,
L:
l_.
(A) Laic Charge for Overdue P2ytnentS
If Lender has not received the full monthly payment required by ilia Security Instrument, as described in Panigruph
4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect n late charge in the amount
of POUR percent (4, 000 %) of the overdue amount of each payment.
I '
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and
all accrued interest. Lender may choose not'to exercise this option without waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in
fun m ilia case of payment defaults. This Note does not authorize acceleration when not. permitted by HUD regulations. As
used in this Note, "Secretary" means the Secretary of (lousing and Urban Development.or his or her designee.
I (C) Paymcnt of Costs and Expense's >
If Lender tins required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary, attorneys' fees for enforcing this Note to the extent not prohibited by applicable
law. Such fees and costs shall bear interest froin'the date of disbursement at lie same rate as the principal of this Note.
I
7, WAIVERS
Borrower and any other person tvhd has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentiment" means the right to require Lender to demand payment ofamounts due. "Notice of dishonor" means the
right to requite Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by lirsdclass mail to Borrower at the property address above or at o different address if
Borrower has given Lcndcr a notice of Borrower's different address.
Any notice that must be given to Lender under this Note wilt be given by first class mail to Lender at the address
stated in Paragraph 4(B) or at a difT'ercnt address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE `
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made
in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note
is also obligated to do these things, Any person who takes over these obligations, including the obligations of a guarantor,
surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights
under this Note against each person individually or against all signatories together. Any one person signing this Note may be
required to pay, all of the amounts owed under this Note,
i.
BY SIGNING EL W, Borrower accepts and agrees to the terns and covenants contained in this Note.
t.
-2 f:Q6, I
BORROWER - TRACY 1091
TZ
BORROWER - SULTAN JORNSOt7 - -!DATE -
. i
PAY TO THE ORDER OR i [Sign O+ignial Ontr j
WITHOUT RECOURSE
1 STPREFERENCE MORTGAGE CO MON
WILD �JfI WL DENT
36.74 I Pagc ] of ] FHA Ylultistate FNed Rate Note — 13Nt
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.� ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in
the Township of East Peniisl oro in _the County of C.ti hbeilaiid and Commonwealth of
.:ed as follows;
Pennsylvania, mP. : ore: articiilarl � . descnb
• -Y
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is
295.06 feet north of the :northwesterly comer of Glenwood Drive (West) and Erford Road
(West), dhd at dividing line: between Lots 3X and 4, Block 'V on the hereafter
mentioned Plan of Lots; thence along said dividing.line, North 63 degrees 30 minutes
West, 1.15 feet to a pointy thence along the easterly line of Lots 23X and 23,.North 26
degrees 30 minutes East, 37.5� to a point at the dividing line between Lots 4 and 4X,
Block "II' on said plan; thence•along said dividing line,, South 63 degrees -30 inuiiites east
and thiough the center partition WA and beybnd,.115. feet to a point on the westerly line
of Glenwood Driye (West), afores aid ;__ thence along.s@xnp, South. 26 degrees 30 minutes
West; 37.5 feetto a point, the nce place of BEGINNING.
BEING known 17 -B Glenwood Drive�(West), Camp Hill Peiinsyivania 1:7011.
BEING lot no. 4, Block "H ";`Plan No' 10, Ridley Park, recorded in Cumberland County
Plan Book 18, page 47.
BEING Parcel No. 09 -16 -1056 =285:
c .
....R..aE...B.P. oft
IhV Mi Mo rtg ag e
A Division ofMidFirst Bank
01/13/14
M0441 R128E12881 P1 of
TRACY L BRETZ
e 17B W GLENWOOD DR
CAMP HILL PA 17011 -1356
NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
UNDER SECTION 403 OF PENNSYLVANIA ACT NO. 6 OF 1974
RE: 17 B WEST GLENWOOD DRIVE
CAMP HILL PA 17011
Loan Number 0052923382
Dear Borrower:
The MORTGAGE held by MidFirst Bank (Lender), serviced by Midland Mortgage, on your property located
at the address above IS IN SERIOUS DEFAULT because you have not made monthly payments totaling
$3,898.41 for the months of 09/01/13 through 01101/14. Late charges and other charges have also accrued
to this date in the amount of $256.69. 1'he total amount now required to cure the default (or in other words,
to get caught up on your payments), as of the date of this letter, is $4,155.10.
You may cure this default within THIRTY-FIVE '(35) DAYS of the date of this letter, by paving to M idland
Mortgage the above payment of $4,155.10, plus any additional monthly payments and late charges which
may fall due during this period. Such payment must be made either by cashier's check, certified check or
money order, and made to Midland Mortgage at P.O Box 268888, Oklahoma City, OK 73126 -8888.
If you do not cure the default. within THIRTY -FIVE (35) DAYS, the Lender intends to exercise its right to
accelerate the mortgage payments This means that whatever is owing on the original amount borrowed will
be considered due immediately and you may.lose the chance to pay off the original mortgage in monthly
installments. If full payment of the amount of default is not made within THIRTY -FIVE (35) DAYS, the
Lender also intends to instruct its attorneys to start a lawsuit to foreclose Your mortgaged property. If the
mortgage is foreclosed your mortgaged property will be sold by the °Sheriff to pay off the: mortgage debt If
the Lender refers your case to its attorneys; but you cure thedefault before before they begin legal
proceedings against you, you will still have•to pay the reasonable attorney's fees, actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's
fees even if they are over $50.00. Any:attorney's fees will be added to whatever you owe, which may also
include reasonable costs. If you cure the default within the thirty -five day period you will not be required to
Pay attorney's fees
The Lender may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage.
'If you have received a bankruptcy discharge of the debt secured by the Mortgage /Deed of Trust or you are currently in bankruptcy
under the protection of the autorr ic.stay, this letter is,not an attempt to collect the debt, but any default VAI need to be cured to avoid
foreclosure. If your loan was in default at the time MldFiist Bank acquired the servicing of your loan and you have not filed bankruptcy
or received a discharge of the debt secured by the Mortgage/Deed of Trust, we are required to advise you that this communication is
from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose.
Midland Mortgage Delinquency Assistance center
P.O. Box 268806 Oklahoma City, OK 73126 -8806 • Tel 1-800-552-3000 Fax 1-405- 767 -5815 - www.MyMidlandMortgage.com
Qualified Written Requests, Notice of Errors, Information Requests, and credit Disputes must be sent to;
P.O. Box 268959.Oklahoma City, OK 73126.89S9
�I
"D
hW Midlan* d. Mortgages// ............
A Division of MidFirst Bank
If you have not cured the default within-: the thirty-five day period and foreclosure proceedings have begun,
you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's
foreclosure sale You may do so by paving the total amount of the unpaid monthly payments plus any late or
other charges then due as well as the reasonable attorney's fees and costs connected with the foreclosure L.
sale and by performing any other requirements, if any, under the mortgage It is estimated that the earliest:
date that such a Sheriffs sale could be held would be approximately six months from the date of this letter.
A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to
cure the default will increase the longer you. wait.. You may find out at any time exactly what the required
payment will be by calling Midland Mortgage at the following number 1- 800 - 552 -3000. This payment must
be made by cashier's check, certified check .ormoney order and made payable to Midland Mortgage at the
address stated above.
You should realize that a Sheriffs sale Will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL
THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY
FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO
SELL OR TRANSFER THE PROPERTY SUBJECT' TO THE MORTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE
OUTSTANDING PAYMENTS; CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO
OR AT THE SALE, AND ANY OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED.
CONTACT MIDLAND MORTGAGE TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RiGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF:
If you cure the default the mortgage will be restored to the same position as if no default had occ urred.
However, you are not entitled to this right to cure your default more than three times in any calendar year.
It is important that you call our office as soon as possible to discuss.the options available to you. Our Loan
Counselors may be reached toll -free at 1- 800 - 552 -3000, Monday through Friday, 8:00 a.m. to 9:00 P.M.
(Central Time).
Sincerely, _
Delinquency Assistance Center
Midland Mortgage, a Division of MidFirstBank
Loan Number 0052923382
T.
*If you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently In bankruptcy
under the protection of the automatic stay, this letter is not an attempt to collect the debt, but any default ViII need to be cured to avoid
foreclosure. If your loan was in default at the time MidFirst Bank acquired the servicing of your loan and you have not filed bankruptcy
or received a discharge of the debt secured by the MortgageiDeed of Trust, we are required to advise you that this communication is
from a debt collector, this is an attempt to collect a debt; and any information obtained will be used for that purpose.
Midland Mortgage Delinquency Assistance Center
P.O. Box 268806.Oklahoma City, OK 73126.8806 • Tel 1. 890- 552 -3000 Fax 1405.767 -5815 • www.MyMidlandMortgage.com
Qualified Written Requests, Notice of Errors, information Requests, and Credit Disputes must be sent to:
P.O. Box 268959.Oklahoma City, OK 73126 -8959
A4V Moaartt2sstxeetvtwe
midland Mortgage
A Division of MidFirst Bank
01/13/14
W3l
MD441R129E129B1PIof2 -
SULTAN A JOHNSON
17B W GLENWOOD DR -
CAMP HILL PA 17011 -1356
_NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
UNDER SECTION 403 OF PENNSYLVANIA ACT NO.6 OF 1974
RE: 17 B WEST GLENWOOD DRIVE
CAMP HILL PA 17011
Loan Number 0052923382
Dear Borrower:
The MORTGAGE. held by MiCIFlrst Bank_ (Lender), serviced by Midland Mortgage, on your property located
at the address above IS IN SERIOUS DEFAULT because you have not made monthly payments totaling
$3,898.41 for the months of 09/01/13 though 01/01/14. Late charges and other charges have also accrued
to this date in the amount of $256.69. The total amount now required to cure the default (or in other words,
to get caught up on your payments), as of the date of this letter, is $4,155.10.
You may cure this default within THIRTY -FIVE (35) DAYS of the date of this letter, by paving to Midland
Mortgage the above payment of $4,155,10, plus any additional monthly payments and late charges which
may fall due during this period. Such payment must be made either by cashier's check, certified check or
money order, and made to Midland Mortgage at.P.O Box 268888, Oklahoma City, OK 73126 -8888.
If you do not cure the default within THIRTY -FIVE (35) DAYS, the Lender intends to exercise its right to
accelerate the mortgage Dayments This means that whatever is owing on the original amount borrowed Will
be considered due immediately and you may lose the chance to pay off the original mortgage in monthly
installments. if full payment of the amount -of default is not made within THIRTY -FIVE (35) DAYS, the
Lender also intends to instruct its attorneys to_ - start a lawsuit to foreclose your mortgaged property. If the
mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If
the Lender refers your case to its attorneys,. but you cure the default before before they begin legal
proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
$50.00. However, if legal proceedings are started against you', you will have to pay.the reasonable attorney's
fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe, which may also
include reasonable costs. If you cure the default within the thirty -five day period • you will not be required to
pay attorney's fees
The Lender may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage.
"If you have received a bankruptcy discharge of the debt.secured by the Mortgage /Deed of Trust or you are currently In bankruptcy
under the protection of the automatic stay, this Ietter is not an attempt to collect the debt, but any default will need to be cured to avoid
foreclosure. If your loan was in default at the time MidFirst Bank acquired the servicing of your loan and you have not filed bankruptcy
or received a discharge of the debt secured by the Mortgage /Deed of Trust, we are required to advise you that this communication is
from a debt collector, this Is an attempt to collect a d any information obtained will be used for: that purpose.
Midland Mortgage Delinquency Assistance Center
P.O. Box 268806.Oklahoma City, OK 73126.8806 • Tel 1- 800.552 -300D • Fax 1.405- 767 -5815 www.MyMidlandMortgage.com
Qualified Written Requests, Notice of Errors, Information Requests, and Credit Disputes must be sent to:
P.O. Box 268959.Oklahoma City, OK 73126 -8959
AW M id , a n � J1. Y .R o'� tgage: uDNI R 120 r 1190 1 D 7 a14
"
A Division of MidFirst Bank:
If you have not cured the default within the thirty -five day period and foreclosure proceedings have begun,
you still have the right to cure the default and prevent the sale at anytime uo to one hour before the Sheriffs
foreclosure sale You may do so by owAng_the total amount of the unpaid monthly payments plus any late or v.
other charges then due as well as the reasonable attorney's fees and costs connected with the foreclosure
sale and by performing any other requirements ;if any, under the mortgage It is estimated that the earliest 0072
da #e that such a Sheriff's sale could be held would be approximately:six months from .the date of this letter,
A of the date of the Sheriff sale will tie sent to you before tfie sale: Of course, the 'amount needed to
cure the default will increase the longer you wait. You -may find . otit, `at any time exactly what the required
payment will be by calling Midland Mortgage at the following numbe 1 -800- 552 -3000. This payment must
be made by cashier's check; certified check or money order and made payable to Midland Mortgage at the
address stated above.
You should realize that a Sheriffs sale.will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started,to evict
you.
You have additlotial rights to >help protect yourinterest :the.,property. YOU HAVE THE RIGHT TO SELL
THE PROPERTY'TO OBTAIN MONEI TO PAYOFF THEW ORTGAGEZEBT, OR TO BORROW
'MONEY
FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT:.,YOU 'MAY HAVE THE RIGHT TO
SELL -OR TRANSFER THE PROPERTY SUBJECT TO THE:; MORTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME -THE. MORTGAGE DEBT, PROVIDED THAT ALL THE
OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYS FEES AND COSTS ARE PAID PRIOR TO
OR AT THE SALE, AND ANY OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED.
CONTACT MIDLAND MORTGAGE TO DETERMINE UNDER WHAT- CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO` HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF:
If you cure the default the mort- atie be'restored to the same oosition as If no default h o ccurred.
However, you are not entitled'to this right to cure'your default more than three times in any calendar year.
It is important that you call our office as soon,as:possible to. discuss 'the options available to you. Our Loan
Counselors may be reached toll -free at 1- 800 - 552 -3000, Monday through Friday, 8:00 a.m. to 9:00 p.m.
(Central Time).
Sincerely,
Delinquency Assistance Center
Midland Mortgage, a Division of MidFirstBank'
Loan Number 0052923382
'If you have received a bankruptcy discharge of(the debt secured by the Mortgage /Deed of Trust or you are currently in bankruptcy
under the protection of the automatic stay, this letter is not'an attempt to collect the debt, but any default will need to be cured to avoid
foreclosure, If your loan was in default at the time Mid First Bank acquired the servio(ng of your loan -and you have not flied bankruptcy
or received a discharge of the debt secured by "the Mortgage /Deed of Trust, we are required to advise you that this communication Is
from a debt oollectot, this is an attempt to collect a debt, and any information obtained will be used for that purpose.
Mtdland Mortgage Delinquency Assistance Center
P.O. Box 268806.Oklahoma City, OK 73126.8806 • Tel 1- 800.552 -3000 • Fax 1405.767 -SB15 • w".MyMidtandMortgage.com
Qualified Written Requests, Notice of Errors, information Requests; a nd Credit Disputes must be sent to:
P,O. Box 268959. Oklahoma City, OK 73126 -8959
Department of Defense Manpower Data Center Results as of: Mar - 24.201406:45:25 AM
SCRA 3.0
Status Report.
Pursuant to Sm cemernbers Civil Relief Act
Last Name: JOHNSON
First Name: SULTAN
Middle Name: A
Active Duty Status As Of: Mar -24 -2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the Individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date -
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the Individual or his /her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
COMPANY NAME: MIDFIRST BANK
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct upon my
personal knowledge and upon information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated
By Lit_ Matt Kinders
Title Vice President
IN THE COURT OF COMMON PLEAS OF
MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS. r rI M
TRACY L. BRETZ, SULTAN A. JOHNSON AND qz si r=
THE DECRETARY OF HOUSING AND URBAN
DEVELOPMENT Defendants) / / f Civil F - c ;
>
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSUREF a
DIVERSION PROGRAM +
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717)243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative,
at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal
representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal
representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If
you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will
prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days
of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to
be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that
a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation
conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out
reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully s
3/25/14
Date Leon P. Haller / Jill M. Wineka
Attorney -for Plaintiff
Purcell, Krug and Haller
1719 North
g Front Street
PA
r ID s 1570a / 588001
r'
IN THE COURT OF COMMON PLEAS OF
MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS.
TRACY L. BRETZ, SULTAN A. JOHNSON
AND THE SECRETARY OF HOUSING AND
URBAN DEVELOPMENT
efendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court- supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Signature of Defendant's Counsel /Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your
Please provide the following information to the best of your knowledge:
CUST
Borrower name (s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied: Yes ❑ No ❑
Mailing Address (if different)
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
C O-BORRO WER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INF ORMATIO N
First Mortgage Lender:
Type of Loan:
Loan Number: Date'You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes and Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney:
Asset Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1 : Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
�- Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. Monthly Amount:
2. Monthly Amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently payingl
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 nd Mortgage Utilities
Car Payment(s) Condo /Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other Prop. Payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Day /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Please provide the following information, if know, regarding_ your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
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 of deed
MIDFIRST BANK
Plaintiff IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
No. 14-1761-CIVIL
TRACY L. BRETZ, SULTAN JOHNSON AND
THE SECRETARY OF HOUSING AND URBAN CIVIL ACTION - LAW
DEVELOPMENT, IN MORTGAGE FORECLOSURE
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P. 404
I, Leon P. Haller, hereby certify that a true and correct copy of the Complaint,Notice of
Residential Mortgage Foreclosure Diversion Program and Request for Conciliation Conference in the above
captioned action was served upon The Secretary of Housing and Urban Development as follows: Complaint
mailed by certified mail, return receipt requested,postage prepaid, on March 27, 2014 addressed to:
The Secretary of Housing and Urban Development
451 SEVENTH STREET, SW
WASHINGTON, DC 20410
Attached hereto is the original mailing receipt postmarked March 27, 2014 along with the United States
Postal Service Track and Confirm showing that certified mail #71969008911196099733 was delivered on
April 3, 2014
Leon P.
1719 N. Front St
Harrisburg, PA 17102
SWORN to d scribed
20
-
,zC
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
My commission expires: EHARP'SP�,'-R.,
r "L SEAL K
Public
C17y. DAUPHIN COUNTY
(SEAL) iss—Kn�or:Ex fres
NOTARIAL SEAL
BONITA E PRUSSACK
Notary Public
HARRISBURG CITY:DAUPHIN COUNTY
My Commission Expires Sep 26,2017
7.196 9008 9111 9609 9733
TO: The Secretaryof Housing
and Urban Development
451 SEVENTH STREET, SW
WASHINGTON, DC 20410
SENDER: MSH SVC
REFERENCE:MID/BRETZ
i
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MIDFIRST BANK IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. Na. 14-1761-CIVIL
TRACY L. BRETZ, SULTAN JOHNSON AND CIVIL ACTION -LAW
THE SECRETARY OF HOUSING AND URBAN IN MORTGAGE FORECLOSURE
DEVELOPMENT,
Defendants
AFFIDAVIT 171T nF SERVICE ]PURSUANT TO Pa.R.C.P. 404
1,Leon P. Haller,hereby certify that a true and correct copy of the Complaint,Notice of
Residential Mortgage Foreclosure Diversion Program and Request for Conciliation Conference in the above
captioned action was served upon The United States of America as follows: Complaint mailed by certified
mail,return receipt requested,postage prepaid,on March 27,2014 addressed to:
The United States of America
United States Attorney's Office M
Tenth and Constitution Avenue NW r-
C_
Main Justice Building,Room 5111 (f)3>
Washington, DC 20530
Attached hereto is the original Certificate of Mailing postmarked March 27, 2014 along wi% ori i nzLP,.t
Receipt for Certified Mail postmarked April 5,2014.
Leon P. Haller
1719 N. Front St
Harrisburg,PA 17102
SWORN to and subscribed
thA' 400
COMMONWEALTH OF PENNSYLVANIA
20/� NOTARIAL SEA—L
BONITA E PRUSSACK
Notary Public 6ar HARRISBURG CITY.DAUPHIN COUNTY
No MY commission Expires Sep 26,2017
My commission expires: COMMONWEALTH OF PENNSYLVANIA
NDTARIA_ COMMIONWEAtT!t OF PENNSYLVANIA
I
SONIIA E PRUSACK
(SEAL) NOTAk_
Notary Public BONITA E
HARRISBURG CITY:DAUPHIN COUNTY Notary Pt;,
My Commission Expires Sep 26,201 i HARRISBURG CITY,DAL;"'N COUNTY
MY commission Expires Sep 26,2017
• �f
r
7396 9008 9131 9609 9740
TO: The United States of America
j United States Attorney's Office
j Tenth and Constitution Avenue NW r
i Main Justice Building, Room 51 I 1
i Washington, DC 20530
SENDER: MSH SVC
i
REFERENCE:MID/BRETZ
1
i
PS Form 3800 January 2005
RETURN Postage _
RECEIPT Certified Fee 3.30
? SERVICE
Return Receipt Fee 2.70
?
Restricted Delivery 0.00
Total Postage&Fees
USP09f M.A
Receipt for Q
Certified Mail"
# No Irreuraric:e Coverage Provided
4
I Do Not Um for hitemeft"MU �0Nn e
:.............. ------
2. Article Number COMPLETE THIS SECTIONON DELIVERY
A. Rece ved by(Please Print Cleary) B. Date of Delivery
C. Signature
i
�
7196 9008 9111 9609 9740 Agent
aa asses
D. Is delivery address different fro
a t? I—]Yes
If YES.enter delivery address 6 ❑No
3. Service Type CERTIFIED MAILT' p `,'�t�4��,
4. Restricted Delivery?(Extra Fee) ❑Yes APR tJ 5 2014
1. Article Addressed to:
The United States of America
United States Attorney's Office
Tenth and Constitution Avenue NW
Main Justice Building; Room 5111
Washington; DC 20530
MID/BRETZ MS}i SVC
PS Form 3811,January 2005 Domestic Return Receipt
t
LEON P. HALLER, ESQUIRE
PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102-2392
(717)234-4178
ATTORNEY FOR PLAINTIFF
MIDFIRST BANK
Plaintiff
vs.
TRACY L. BRETZ, SULTAN A. JOHNSON
AND THE SECRETARY OF HOUSING AND
URBAN DEVELOPMENT
Defendant
FI EU JFF10E
OF THE PRGTHCUOM
2014 JUL 17 AM 11: i
CUMBERLAND CCUNTy
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 14-1761 CIVIL
: IN MORTGAGE FORECLOSURE
MOTION TO LIFT STAY IMPOSED BY THE MORTGAGE
FORECLOSURE DIVERSION PROGRAM
AND NOW comes Plaintiff, MidFirst Bank, through it's counsel, Leon P.
Haller, and in accordance with Paragraph (k) of the Order of February 28,
2012, establishing the Mortgage Foreclosure Diversion Program, represents as
follows:
1. The within foreclosure action was filed March 26, 2014
2. Service of the Complaint and Notice of Residential Mortgage
Foreclosure Diversion Program was made on March 28, 2014
3. Defendants have not opted to participate in the Mortgage
Foreclosure Diversion Program.
4. Plaintiff, in accordance with the provisions of the Mortgage
Foreclosure Diversion Program, requests that the stay be lifted.
WHEREFORE, Plaintiff requests that the stay imposed by the
Cumberland County Mortgage Foreclosure Diversion Program be lifted to allow
Plaintiff to proceed with the foreclosure action.
PURCELL, KRUG & HALLER
By:
Dated: July 15, 2014
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing
Petition to Lift Stay, are true and correct.
I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
Leon P. Halle
Dated: July 15, 2014
• ' 1
LEON P. HALLER, ESQUIRE
PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102-2392
(717)234-4178
ATTORNEY FOR PLAINTIFF
MIDFIRST BANK
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 13-2943 CIVIL
AMY J. BOYA : IN MORTGAGE FORECLOSURE
Defendant
CERTIFICATE OF SERVICE
I, Leon P. Haller, the undersigned, Attorney for
Plaintiff, hereby certify that I served on the 15TH day of July, 2014, a copy
of the Petition to Lift Stay Imposed by Mortgage Foreclosure Diversion Program
upon each of the following person at the addresses shown below:
Tracy L. Bretz
17B West Glenwood Drive
Camp Hill, PA 17011
Sultan A. Johnson
17B West Glenwood Drive
Camp Hill, PA 17011
Leon P. Haller
Dated: July 15, 2014 Attorney for Plaintiff
t
MIDFIRST BANK
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 14-1761 CIVIL
TRACY L. BRETZ, SULTAN A. JOHNSON : IN MORTGAGE FORECLOSURE
AND THE SECRETARY OF HOUSING AND •
URBAN DEVELOPMENT
Defendant
AND NOW, this /o ` day of
•
•
•
•
ORDER
, 2014, upon
consideration of Plaintiff Petition to Lift Stay, Notice of the Residential
Mortgage Foreclosure Diversion Program having been served on June 19, 2013,
and Defendant having not opted to participate in the Mortgage Foreclosure
Diversion Program, IT IS HEREBY ORDERED that the stay imposed by the Mortgage
Foreclosure Diversion Program be lifted and Plaintiff may proceed with its
mortgage foreclosure action.
BY THE COURT:
�• %14—
/
r
z - z
-sCil.
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) TRACY L.
BRETZ AND SULTAN A. JOHNSON for failure to plead to the above action within twenty (20) days
-71
from date of service of the Complaint, and assess Plaintiff's damages as follows:
Unpaid Principal Balance
Interest
Per diem of $12.06
From 08/01/2013
To 04/01/2014
Accumulated Late Charges
Corporate Advance
Escrow Deficit
5% Attorney's Commission
TOTAL
$113,550.43
$2,929.39
$241.68
$226.45
$584.28
$5,677.52
$123,209.75
1 :2
**Together with additional interest at the per diem rate indicated above from the date herein, based on
the contract rate, and other charges and costs to the date of Sheriffs Sale.
PURCELL, KRUG & HA
By
n P. Haller PA I.D. # 15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
MIDFIRST BANK,
PLAINTIFF
Vs.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on July 24, 2014 I served the Ten Day Notice required by Pa. R.C.P. on the
Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached
Notice.
By
Leo aller PA I.D. # 15700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
MIDFIRST BANK,
Plaintiff
VS.
TRACY L. BRETZ, SULTAN A. JOHNSON
AND THE SECRETARY OF HOUSING AND
URBAN DEVELOPMENT,
Defendants
DATE OF THIS NOTICE: July 24, 2014
TO:
TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 14 -1761 -CIVIL
CIVIL ACTION LAW
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (IQ)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PURCELL, i'G & - LLER
By
LEON P. HALLS' Attorney for Plaintiff
I.D. # 15700
1719 N. Front St., Harrisburg, PA 17102
(717) 234-4178
MIDFIRST BANK,
PLAINTIFF
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT, IN MORTGAGE FORECLOSURE
DEFENDANT(S)
AFFIDAVIT
COMMONEALTH OF PENNSYLVANIA:
SS
COUNTY OF DAUPHIN •
I, LEON P. HALLER, Attorney for the Plaintiff in the above matter, being duly
sworn according to law, hereby certify that the Mortgage in the above case is insured by
the Federal Housing Administration under Title 11 of the National Housing Act (12
U.S.C.A. Section 707 1715z11) and therefore does not fall within the provisions of PA
Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program).
Sworn to and subscribed
before this day
of
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
MARYLAND K. FERRETTI, Notary Public
Lower Paxton Twp., Dauphin County
My commission Expires August 08, 2018
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said Commonwealth and County,
LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the
Defendants above named are not on active duty in the Military Service nor engaged in any way which
would bring them within the Servicemembers' Civil Relief Act. A copy of the search through the
Defense Manpower Data Center website is attached.
Sworn to and subscribed
before me this 7 day
‘.;OMMONWFALTH F
NNSYLVANIA
NOTARIAL. SEAL
MARYLAND IC FERRETTI, Notary Public
Lowcr Paxton Twp., Dauphin County
jyCc&,on Expires August 08, 2018
HALLER, ESQUIRE
r
Department of Defense Manpower Data Center
Status Report
Pursuant to ,Servicenernbers Civil .l ,eiief Act
Last Name: BRETZ
First Name: TRACY
Middle Name: L
Active Duty Status As Of: Aug -29-2014
Results as o1: Aug -29-2014 06:50:53 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects Fhe Individuals' active duty status based on the Active Duly Status Dale
Left Active Duly Within 367 Days of Active Duty Status Dale
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No.
NA
This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This
response reflects whether the individual or his/her unit has received earty notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
r
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1),
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 4CG35B1DS000HEO
Department of Defense Manpower Data Center
Status Report
Pursuant to ,Servicemembers Civil Relief Act
Last Name: JOHNSON
First Name: SULTAN
Middle Name: A
Active Duty Status As Of: Aug -29-2014
Results as of : Aug -29.2014 06:52:12 AM
SCRA 3.0
On Active Duly On Active Duly Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects the Individuals' active duty status based on the Active Duty Status Dale
Da
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Date
Active Duty End Dale
Status
Service Component
NA
NA
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard), This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
y 1 b
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections, Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 0C4CXB6DL000940
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO. 14 -1761 -CIVIL
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
Cr
-7
0 -
CD --
_.,L Cr)
on
TO'THEOIONOTARY/CLERK OF SAID COURT:
CD
cD
Q }'
I.AECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE
Total Judgment Amount $123,209.75
Interest $2,965.55
Per diem of $12.06 to sale
date 12/3/2014
Late Charges $151.80
per month to sale date
12/3/2014
Escrow Deficit $2,161.49
TOTAL WRIT $128,488.59
*Plus additional interest, late charges and other costs
to date of sheriff's sale.
SALE DATE: Wednesday, December 03, 2014
(PROTHONOTARY'S USE)
Pltf. Paid
Deft. Paid
Due Proth/Clerk
Other Costs
Issue Writ of Execution in the above captioned case.
Date: August 29, 2014
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
eon P. Haller
PA I.D. #15700
WRIT OF EXECUTION - MORTGAGE FORECLO
ONWEALTH OF PENNSYLVANIA .
COUNTY OF CU
ND
SS
TO THE SHERIFF OF CUMBERLAN
To satisfy the judgment, inte
sell the property described in th
HILL, PA 17011
Date:
. S'Ci lRL.
92.94" &'si
163. 7S
14.4-Q
„2W.7(..) —
fI
11
4'2..25 - co
. -
Cleal 19763 y
and costs in the abo ' : a.tioned case, you are directed to levy upon and
ached description known as 17 : ST GLENWOOD DRIVE CAMP
PROTHONOTARY/CLERK CIVIL
BY
ION
DEPUTY
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of
East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 295.06 feet north
of the northwesterly corner of Glenwood Drive (West) and Erford Road (West), and at dividing line
between Lots 3X and 4, Block "H" on the hereafter mentioned Plan of Lots; thence along said dividing
line, North 63 degrees 30 minutes West, 115 feet to a point; thence along the easterly line of Lots 23X
and 23, North 26 degrees 30 minutes East, 37.5 feet to a point at the dividing line between Lots 4 and
4X, Block "H" on said plan; thence along said dividing line, South 63 degrees 30 minutes East and
through the center partition wall and beyond, 115 feet to a point on the westerly line of Glenwood Drive
(West), aforesaid; thence along same, South 26 degrees 30 minutes West, 37.5 feet to a point, the place
of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 17-B West Glenwood Drive, Camp Hill,
PA 17011.
BEING Lot No. 4, Block "H", Plan No. 10, Ridley Park, recorded in Cumberland County Plan Book 18,
Page 47.
PARCEL NO.: 09-16-1050-285.
BEING THE SAME PREMISES WHICH Steve A. Watts and Diana L. Watts by deed dated 12/11/06
and recorded 12/19/06 in Cumberland County Record Book 278 Page 175 granted and conveyed unto
Sulton A. Johnson and Tracy L. Bretz.
TO BE SOLD AS THE PROPERTY OF TRACY L. BRETZ AND SULTAN A. JOHNSON ON
JUDGMENT NO. 14-1761
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date
the praecipe for the writ of execution was filed, the following information concerning the real property
located at 17B WEST GLENWOOD DRIVE CAMP HILL, PA 17011:
1. Name and address of the Owner(s) or Reputed Owner(s):
TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1)
above: SAME
3. Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
4. Name and address of last recorded holder of every mortgage of record:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
Secretary of Housing and
Urban Development
451 Seventh Avenue S.W.
Washington, D.C. 20410
Secretary of Housing and
Urban Development
Albany Office — Region II
52 Corporate Circle
Albany, New York 12203-5121
U. S. Attorney's Office
Tenth and Constitution Avenue, N.W.
Main Justice Building — Room 5111
Washington., D.C. 20530
U. S. Attorneys Office
Secretary of Housing and
Urban Development
Federal Building — Suite 220
228 Walnut Street
Harrisburg, PA 17108
U. S. Attorneys Office
Secretary of Housing and
Urban Development
P. O. Box 117541
Harrisburg, PA 17108
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale: UNKNOWN
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated.)
I verify that the statements made in this Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authority
DATE:August 29, 2014
. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
TAKE NOTICE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, December 03, 2014
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
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THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property, together with a brief mention of the buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 14 -1761 -CIVIL JUDGMENT AMOUNT $123,209.75
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
TRACY L. BRETZ and SULTAN A. JOHNSON
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of
Common Pleas of the within County at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY
THE JUDGMENT
You may have legal rights to prevent your property from being taken away. A lawyer can advise
you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of
East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 295.06 feet north
of the northwesterly corner of Glenwood Drive (West) and Erford Road (West), and at dividing line
between Lots 3X and 4, Block "H" on the hereafter mentioned Plan of Lots; thence along said dividing
line, North 63 degrees 30 minutes West, 115 feet to a point; thence along the easterly line of Lots 23X
and 23, North 26 degrees 30 minutes East, 37.5 feet to a point at the dividing line between Lots 4 and
4X, Block "H" on said plan; thence along said dividing line, South 63 degrees 30 minutes East and
through the center partition wall and beyond, 115 feet to a point on the westerly line of Glenwood Drive
(West), aforesaid; thence along same, South 26 degrees 30 minutes West, 37.5 feet to a point, the place
of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 17-B West Glenwood Drive, Camp Hill,
PA 17011.
BEING Lot No. 4, Block "H", Plan No. 10, Ridley Park, recorded in Cumberland County Plan Book 18,
Page 47.
PARCEL NO.: 09-16-1050-285.
BEING THE SAME PREMISES WHICH Steve A. Watts and Diana L. Watts by deed dated 12/11/06
and recorded 12/19/06 in Cumberland County Record Book 278 Page 175 granted and conveyed unto
Sulton A. Johnson and Tracy L. Bretz.
TO BE SOLD AS THE PROPERTY OF TRACY L. BRETZ AND SULTAN A. JOHNSON ON
JUDGMENT NO. 14-1761
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
MIDFIRST BANK
Vs. NO 14-1761 Civil Term
CIVIL ACTION — LAW
TRACY L. BRETZ,
SULTAN A. JOHNSON
AND THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT
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: $123,209.75 L.L.: $.50
Interest PER DIEM OF $12.06 TO SALE DATE 12/3/2014 - $2,965.55
Atty's Comm: Due Prothy: $.50
Atty Paid: 5241.70 Other Costs: LATE CHARGES PER MONTH TO
SALE DATE 12/3/2014 - $151.80 ---- ESCROW D IT - $2,161.49
Plaintiff Paid:
Date: 9/4/2014
(Seal)
REQUESTING PARTY:
Name: LEON HALLER, ESQ.
Address: PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102
Attorney for: Plaintiff
Telephone: 717-234-4178
Supreme Court ID No. 15700
David D. B e , Prothonotary
By:
Deputy
MIDFIRST BANK,
PLAINTIFF
. VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on
9 lac JapI4 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA
R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail
(Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence),
and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are
as follows:
TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
Secretary of Housing and
Urban Development
451 Seventh Avenue S.W.
Washington, D.C. 20410
Secretary of Housing and
Urban Development
Albany Office — Region II
52 Corporate Circle
Albany, New York 12203-5121
rri Z-3
-
U. S. Attorney's Office
Tenth and Constitution Avenue, N.W.
Main Justice Building — Room 5111
Washington, D.C. 20530
U. S. Attorneys Office
Secretary of Housing and
Urban Development
Federal Building — Suite 220
228 Walnut Street
Harrisburg, PA 17108
U. S. Attorneys Office
Secretary of Housing and
Urban Development
P. O. Box 117541
Harrisburg, PA 17108
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
By
PUREE e...srUG & HA LE
orneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
Ai/xceil, gag
HOWARD B. KRUG
LEON P. HALLER
JOHN W. PURCELL JR.
JILL M. WINEKA
LISA RYNARD
TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
Secretary of Housing and
Urban Development
451 Seventh Avenue S.W.
Washington, D.C. 20410
Secretary of Housing and
Urban Development
Albany Office — Region II
52 Corporate Circle
Albany, New York 12203-5121
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FAX (717) 234-1206
U. S. Attorney's Office
Tenth and Constitution Avenue, N.W.
Main Justice Building — Room 5111
Washington, D.C. 20530
HERSHEY
(717)533-3836
U. S. Attorneys Office
Secretary of Housing and
Urban Development
Federal Building — Suite 220
228 Walnut Street
Harrisburg, PA 17108
U. S. Attorneys Office
Secretary of Housing and
Urban Development
P. 0. Box 117541
Harrisburg, PA 17108
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court
of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate
will be exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be
divested by the sale and that you have an opportunity to protect your interest, if any, by bein notified of
said Sheriffs Sale.
By:
eon P. Ha PA I.D.15700
Attorney for Plaintiff
er
MIDFIRST BANK,
PLAINTIFF
VS.
TRACY L. BRETZ , SULTAN A. JOHNSON AND
THE SECRETARY OF HOUSING
AND URBAN DEVELOPMENT,
DEFENDANT(S)
TAKE NOTICE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 14 -1761 -CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, December 03, 2014
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property, together with a brief mention of the buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 14 -1761 -CIVIL JUDGMENT AMOUNT $123,209.75
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
TRACY L. BRETZ and SULTAN A. JOHNSON
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office - Civil Division, of the within County Courthouse, 'before a presentation of the petition to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of
East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 295.06 feet north
of the northwesterly corner of Glenwood Drive (West) and Erford Road (West), and at dividing line
between Lots 3X and 4, Block "H" on the hereafter mentioned Plan of Lots; thence along said dividing
line, North 63 degrees 30 minutes West, 115 feet to a point; thence along the easterly line of Lots 23X
and 23, North 26 degrees 30 minutes East, 37.5 feet to a point at the dividing line between Lots 4 and
4X, Block "H" on said plan; thence along said dividing line, South 63 degrees 30 minutes East and
through the center partition wall and beyond, 115 feet to a point on the westerly line of Glenwood Drive
(West), aforesaid; thence along same, South 26 degrees 30 minutes West, 37.5 feet to a point, the place
of BEGINNING.
HAVING thereon erected a dwelling known and numbered as 17-B West Glenwood Drive, Camp Hill,
PA 17011.
BEING Lot No. 4, Block "H", Plan No. 10, Ridley Park, recorded in Cumberland County Plan Book 18,
Page 47.
PARCEL NO.: 09-16-1050-285.
BEING THE SAME PREMISES WHICH Steve A. Watts and Diana L. Watts by deed dated 12/11/06
and recorded 12/19/06 in Cumberland County Record Book 278 Page 175 granted and conveyed unto
Sulton A. Johnson and Tracy L. Bretz.
TO BE SOLD AS THE PROPERTY OF TRACY L. BRETZ AND SULTAN A. JOHNSON ON
JUDGMENT NO. 14-1761
9414 7266 9904 2019 6835 45
TO: TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SENDER: M02090/41074
REFERENCE: NOS 12/03/14
PS Form 3800, January 2005
RETURN
RECEIPT
SERVICE
Postage
Certified Fee
Return Receipt Fee
Restricted Dciivery
Total Postage & Fees
USPS'
Receipt for
Certified Mail""
No Insurance Coverage Provided
Do Not Use for International Mail
DATE
6_>
3.30
2.70
5.05
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9414 7266 9904 2039 6835 38
TO: SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
SENDER: M02090/41074
REFERENCE: NOS 12/03/14
PS Form 3800, January 2005
RETURN
RECEIPT
SERVICE
Postage
Certified Fee
Return Receipt Fee
3 30
2.70
Restricted Delivery
Total Postage & Fee
USPS•
Receipt for
Certified Mali
No Insurance Coverage Provl1ed
Do Not Use for International Mall
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MIDLAND MORTGAGE, a division of MidFirst Bank v. TRACY L. BRETZ SULTAN A. JOHNSON
Cumberland County Sale 12/3/2014
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
TRACY L. BRETZ
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
SULTAN A. JOHNSON
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Postage:
Postmark:
021M $01.300
0004284324 SEP29 2014
MAILED FROM ZIP CODE 1 710 2
'MIDLAND MORTGAGE, a division of MidFirst Bank v. TRACY L. BRETZ SULTAN A. JOHNSON
Cumberland County Sale 12/3/2014
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
TENANT/OCCUPANT
17B WEST GLENWOOD DRIVE
CAMP HILL, PA 17011
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
East Pennsboro Township
98 South Enola Drive
Enola, PA 17025
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
Secretary of Housing and
Urban Development
451 Seventh Avenue S.W.
Washington, D.C. 20410
Postage:
Postmark:
02 1M
$ 01.300
0004284324 SEP29 2014
MAILED FROM ZIP CODE 1 7102
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Secretary of Housing and
Urban Development
Albany Office — Region II
52 Corporate Circle
Albany, New York 12203-5121
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
U. S. Attorney's Office
Tenth and Constitution Avenue, N.W.
Main Justice Building — Room 5111
Washington, D.C. 20530
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
One piece of ordinary mail addressed to:
U. S. Attorneys Office
Secretary of Housing and
Urban Development
Federal Building — Suite 220
228 Walnut Street
Harrisburg, PA 17108
Postage:
Postmark:
eS �
4 _
1/ _ r�I®
`�7�ij�,// ®oIrnEv BOWES
021M $01.300
0004284324 SEP 29 2014
MAILED FROM ZIP CODE 1 7102
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
U. S. Attorneys Office
Secretary of Housing and
Urban Development
P. O. Box 117541
Harrisburg, PA 17108
Postage:
Postmark:
O2 1M 0
0004284324 SEP 29 2014
MAILED FROM ZIPCODE 1 7102