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HomeMy WebLinkAbout14-3554 ` Supreme Court of Pennsylvania Court of Common Pleas ForProthonotaty Use Ont Civil Cover Sheet Docket No: Cumberland County 14-36sq NdTem The information collected on this form is used solely_for court administration purposes. This form does not sup olement or replace thefiling and service ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: E x Complaint ❑ Writ of Summons ❑Petition C ❑Transfer from Another Jurisdiction ❑ Declaration of Takia Lead Plaintiff's Name:FEDERAL NATIONAL Lead Defendant's Name:KIMBERLY L.LENKER T MORTGAGE ASSOCIATION("FANNIE MAE") I , O N Are money damages requested? : ❑ Yes X No Dollar Amount Requested: within arbitration limits A (Check one) outside arbitration limits Is this a Class Action Suit? 0 Yes 0 No Th this an MDJA eal? ❑ Yes OX No Name of Plaintiff/Appellant's Attorney:Martha Von Rosenstiel,Esq. ❑ Check here if you are a Self-Represented Pro Se Litigant Nature of the C:,Ise: Place an"ti'' to the left of the ONE case category that most accurately describes your PRIA14R I'CASE. If you are making more than one type of claim.check the one that you consider most important. j TORT(do no;include Mass ion) CONTRACT talo nor fnclude hid'gmenis) CIVIL APPEALS ❑ Intentional ❑Buyer Plaintiff Administrative Agencies El Malicious Prosecution ❑Debt Collection:Credit Card ❑ Board of Assessment Motor Vehicle ❑Debt Collection;Other ❑ Board of Elections Nuisance ❑ Dept.of Transportation Preunises Liability El Statutory Appenl:Other S ❑ Product Liability {does nor inchu'c mass tort} ❑Employment Dispute: E ❑ SlanderiLibell Defamation Discrimination C ❑ Other: ❑Employment Dispute:Other ❑ Zoning Board .I- _ ❑ Other I ❑Other: O DI-=>LSS TORT Asbestos Tobacco Toxic Tort-DES Tomc Tort-Itnplant REAL PROPERTY N11SC£LLANEOi:S Toxic Waste ❑C'onnnon Law/StatutoryArbitration © Other: [I Ejectment B ❑Eminent DoinainlCondeinnation ❑Declaratory Judgment ❑Ground Rent Mandamus ❑Landlord/Tenant Dispute e Non-Domestic Relations x❑Mortgage Foreclosure:Residential Restraining Order L, PROFESSIONALIABLITY ❑Mortgage Foreclosure:Conuuercial ❑Quo\Varrarnto Dental ❑Partition ❑Replevin ❑ Legal ❑Quiet Title ❑Other. Medical ❑Other: Other Professional: Updated 1/I,.s011 FORM 1 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 Plaintiff vs. NO. 14-3-5sq Oivi[Term KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 T' Defendant `'� ' - r- -77 NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE �" c DIVERSION PROGRAM r-::: 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 submitted: June 6, 2014 Date Si re of Coun laintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMERIPRIMARY APPLICATION Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes❑ No❑ Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied: Yes❑ No❑ Mailing Address(if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? Mailing Address: City: State: _ Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy?Yes❑ No❑ If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ A_ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1:Model: Year: Amount awed: Value: Automobile#2: Model: _ Year: Amount owed: Value: Other transportation(automobiles, boats, motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. _ Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other Prop.Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/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: AUrHORIZArION 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 3 FORM 3 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 Plaintiff vs. NO. KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 Defendant REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is. defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date 5 FORM 4 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW , PENNSYLVANIA Washington, DC 20016-2892 Plaintiff VS. NO. KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 Defendant CASE MANAGEMENT ORDER AND NOW, this day of 20 the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in _at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the G Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; z entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. MARTHA E. VON ROSENSTIEL, P.C. 34441CFC-AB Martha E. Von.Rosenstiel, Esquire/No. 52634 �( �� ''� `: �`,1 q 21, Heather Riloff, Esquire/No. 309906 rit siLsa[ CGIiYT° 649 South Avenue, Suite 7 � ; C C��J I Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff V. NO. 4- 355 �tvd—&11 KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 Defendant CIVIL ACTION—MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le han demandado a usted en la corte. Si usted quiere defenderse de set forth in the following pages,you must take action within twenty estas demandas expuestas en las paginas siguientes,usted tiene (20)days after this complaint and notice are served,by entering a veinte(20)dias de plazo al partir de la fecha de]a demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la corte en forma escrita sus You are warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende,]a corte toma ra medidas y further notice for any money claimed in the complaint or for any other puede continuer la dernanda en contra suya sin previo aviso o claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas,la corte puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW.THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A WITH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO,LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE p CARLISLE, PA 17013 717-249-3166 4103.'75 Ap Ate/ 800-990-9108 � � 307145 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL-BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. 1 MARTHA E. VON ROSENSTIEL, P.C. 34441CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff V. NO. KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 Defendant CIVIL ACTION -MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Federal National Mortgage Association ("Fannie Mae"), a corporation organized and existing under the laws of the United States of America, with offices for the conduct of business at 3900 Wisconsin Avenue, NW, Washington, DC 20016-2892. 2. Defendant, Kimberly L. Lenker is the mortgagor and real owner of premises 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Howard Hanna Financial Services, Inc. on June 12, 2000, which mortgage was recorded on June 15, 2000 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1618, Page 874, secured on premises 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage was then assigned to Homeside Lending, Inc by written assignment dated June 12, 2000 and recorded on November 27, 2000 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 661, Page 170. 5. The mortgage was then assigned to JPMorgan Chase Bank,NA by written assignment dated July 7, 2012 and recorded on July 25, 2012 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 201222190. 6. The mortgage has since been assigned to Federal National Mortgage Association by { written assignment dated February 7, 2014 and recorded on March 7, 2014 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 201404772. 7. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 8. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from October 2013 and each month thereafter, up to and including the present time. 9. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 10. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 42,357.37 Interest from 9/1/2013 to 5/29/2014 at $8.70 per diem $ 2,349.96 Accrued late charges $ 60.48 Accrued Escrow deficit $ 13.25 Attorney's Fee $ 1,650.00 Property Inspections $ 74.00 Total $ 46,505.06 9. Plaintiff sent to obligated defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit 11). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of$46,505.06, plus per diem interest at $8.70 from May 30, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENST L, P.C. BY• artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff P VERIFICATION Ardrew Fry hereby states that he/she is the Foreclosure Specialist of Seterus, Inc., as authorized subservicer for Federal National Mortgage Association("Fannie Mae"), a corporation organized and existing under the laws of the United States of America,plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Federal National Mortgage Association ("Fannie Mae") and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Association ("Fannie Mae")v. Kimberly L. Lenker relating to the property located at 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. B Title: Foreclosure Specialist Seterus, Inc., as authorized subservicer for Federal National Mortgage Association ("Fannie Mae"), a corporation organized and existing under the laws of the United States of America Dated: EXHIBIT I LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: ALL THAT CERTAIN Unit, being Unit No. 595-14 (the 'Unit'), of Sunguild III, A condominium, located in Upper Allen Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Sunguild III, A Condominium (the 'Declaration of Condominium') on Declaration Plats and Plans as recorded in the Recorder's Office of Cumberland County in Misc. Book 357, page 20 and Right of Way Plan Book 9, page 24. TOGETHER with an undivided 7.5218% interest in Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration and matters which a physical inspection and survey of the Unit and Common Elements would disclose. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs,personal representatives, successors and assigns,by the acceptance of this Deed, covenants and agrees to pay such charges for maintenance, repairs, replacements and other expenses in connection with the Common Elements and any Limited Common Elements appurtenant to said Unit, as may be assessed against him, her, them, it or said Unit, from time to time by the Executive Board of the Sunguild III Condominium Associates in accordance with the Uniform Condominium Act of Pennsylvania, and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a lien for all amounts so assessed except insofar as Section 3407(c) of said Uniform Condominium Act may relieve a subsequent Unit Owner of liability for prior unpaid assessments. This covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. PARCEL IDENTIFICATION NO: 42-24-0791-163.-U595-14, CONTROL#: 42000618 e EXHIBIT II CHASE i Chase(OH4-7399) P.O.Box 183205 Columbus,OH 43218 For Undeliverable Mail Only 12/03/2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 005752-1 of 4 NSPOHDLA-ZA J0463079 0000000 KIMBERLY L LENKER 595 -14 GENEVA DR MECHANICSBURG,PA 17055 Act 91 Notice Account: the "Loan") Property Address: 595 -14 GENEVA DR MECHANICSBURG,PA 17055 (the "Property") Dear KIMBERLY L LENKER: On the following page,you will find a notice regarding your home as required by Pennsylvania law. ' ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY-THREE (331 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies servingyourCounty are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 800-342-2397. (Persons with impaired hearing can call 717-780-1869.1 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): KIMBERLY L LENKER PROPERTY ADDRESS: 595 -14 GENEVA DR MECHANICSBURG, PA 17055 LOAN ACCOUNT NUMBER: igloo ORIGINAL LENDER: HOWARD HANNA FINANCIAL SERVICES,INC. CURRENT LENDER/SERVICER: JPMorgan Chase Bank,N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30)days from the date of this Notice (plus three (3)days for mailing). During that time,you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33)DAYS OF THE DATE OF THIS NOTICE.IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty (30)days after the date of this meeting. The names,addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting.Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign,and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30) days of your face-to-face meeting with the counseling agency. YOUSHO ULD FILE HEMAPAPPLICATION AS SOON AS POSSIBLE. IF YOUHAVE A MEETING WITH CO UNSELING A GENCY WITHIN THIRTY-THREE(33)DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICA TION WITH THE PHFA WITHIN THIRTY(3 0)DA YS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING A FORECL OS URE A CTION A GAINST YOUR PROPERTY,AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORAR Y STA Y OF FORECLOSURE." YOUHAVE THE RIGHT TO FILEA HEAL PAPPLICATION EVEN BEYOND THESE TIME PERIODS.A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)days to make a decision after it receives your application. During that time,no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The mortgage debt held by the above lender on your property located at: 595 -14 GENEVA DR,MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 10/01/2013 $520.17 11/01/2013 $520.17 12/01/2013 $522.03 Late Charges: $55.86 Insufficient Funds(NSF)Fees: $0.00 Other Fees: $0.00 Advances: $14.00 Amount Held in Suspense: $14.00 TOTAL AMOUNT PAST DUE: $1,618.23 HOW TO CURE THE DEFAULT --You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,WHICH IS $1,618.23, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)-DAY PERIOD. Payments must be made by cash,cashier's check,certified check or money order made payable and sent to: 11�..i ni<:I11 I .•aulcu 1\1a;! 1 liao • Columbus, OH 43219-6009 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30) DAYS of the date of this Notice,the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)DAYS,the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to $50.00.However,if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. If you cure the default within the THIRTY (30)-DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)-DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale.You may do so by paying the total amount then past due,plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE --It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Chase Address: Mail Code: OH4-7384 P.O.Box 41275 Jacksonville,FL 32203-1275 Telephone Number: 800-848-9380 Fax Number: 614-500-4605 Contact Person: Bruno Mejia E-mail Address: state.programs.intake@jpmchase.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff f i Jody S Smith w ` ' ,r ^f �.., _ Chief Deputy i k f Richard W Stewart INBEki_ANJ Solicitor :, E N S Y L `ANI A Federal National Mortgage Association Case Number vs. 2014-3554 Kimberly L Lenker SHERIFF'S RETURN OF SERVICE 06/16/2014 02:55 PM- Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally' handing a true copy to a person representing themselves to be the Defendant, to wit: Kimberly L Lenker at 595-14 Geneva Drive, Upper Allen Township, Mechanic ur A 17055. WILLIAM CLINE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, June 17, 2014 RONO R ANDERSON, SHERIFF ,:aunt u,.c She,.f -osc"�.... MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY vs. KIMBERLY L. LENKER : No. 14-3554 Civil Term 595 Geneva Drive, Apartment 14 a/k/a 595-14 : Geneva Drive Mechanicsburg, PA 17055 Defendant PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, Federal National Mortgage Association ("Fannie Mae") by and through its undersigned counsel, Martha E. Von Rosenstiel, P.C., Heather Riloff, Esquire, hereby respectfully requests that this Honorable Court enter an Order granting its Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and in support thereof, avers as follows: 1. This matter has been assigned to the Honorable Kevin A. Hess, P.J. for matters concerning the Residential Mortgage Conciliation Program. 2. This is a residential mortgage foreclosure action. 3. On or about June 16, 2014 service of the Mortgage Foreclosure Complaint was completed in this action and the 60 day stay of proceedings went into effect pursuant to the February 28, 2012 Administrative Order. 4. To date, 60 days after service of the Complaint and Notice, Plaintiff has not received notice of a Conciliation Conference date, nor a Diversion Program Financial Worksheet 5. Plaintiff respectfully requests that it be permitted to proceed with its foreclosure action. WHEREFORE, Plaintiff, Federal National Mortgage Association ("Fannie Mae"), respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: August 20, 2014 Heather Riloff, • re PA Attorney ID i . 30990 Attorney for Plainti 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY vs. KIMBERLY L. LENKER : No. 14-3554 Civil Term 595 Geneva Drive, Apartment 14 a/k/a 595-14 : Geneva Drive Mechanicsburg, PA 17055 Defendant CERTIFICATION OF SERVICE Heather Riloff, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and proposed order in the above matter was made upon the Defendant: KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 by regular first class mail, postage prepaid, deposited with the United States Postal Service on August 20, 2014 This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: Dated: August 20, 2014 Heather Riloff, E e Attorney for Plain • VERIFICATION HEATHER RILOFF, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action and that the statements made in the forgoing Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, are true and correct to the best or her information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Q Heather Riloff, E Attorney for Plain Date: August 20, 2014 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY vs. KIMBERLY L. LENKER : No. 14-3554 Civil Term 595 Geneva Drive, Apartment 14 a/k/a 595-14 : Geneva Drive Mechanicsburg, PA 17055 Defendant ORDER OF COURT G) N cr N) AND NOW, this 24. day of if*fr , 2014, the Defendants having failed to comply with the requirements of the Cumberland County Administrative Order dated February 28, 2012, it is hereby ORDERED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. The temporary stay on this matter is terminated. LA'314ES fiat LL y aawi Posgvsh K. 1,Qs kL BY THE COURT: #34441 CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FFDhKAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") (7,ria Plaintiff -0 _T V. NO. 14-3554 Civil Termrn;Y'is rn F— < C- r' (D. .._- r .p~ KIMBERLY L. LENKER Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT CD c � -r- To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Kimberly L. Lenker for want of an answer. (X) Assess Damages as Follows Debt Interest from 5/30/14 to 9/23/14 At $8.70 per diem $ 46,505.06 $ 1,017.90 Total $ 47,522.96 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 MARTHA E. VON ROSENSTIEL, P.C. BY: `_i, Martha E. Von Ro Heather Riloff, Es Attorneys for Plaint This2941 y of gar4Errt6L, , 2014 judgment is entered in favor of the Plaintiff and against Defendant(s), Kimberly L. Lenker by default for want of an answer and damages assessed at the sum of $47,522.96 as per the above certification. Prothono ry, Cts: .974.sc:ALigki cKFE L4A/`s Pi 3i 1 LG/ t MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather RiIoff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff v. KIMBERLY L. LENKER Defendant #34441 CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-3554 Civil Term TO: Kimberly L. Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MMAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.G. BY: Dated: 919/14 Martha E. Von Risen Heather Riloff, iesqui Attorneys for Pla'nti MARTHA E. VON ROSENSTIEL, P.C. Marina E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff vs. KIMBERLY L. LENKER Defendant(S) : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14-3554 Civil Term #34441 CFJ-DN NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, P.C. by the undersigned hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: September 23, 2014 Martha E. Von Rosensti Heather Riloff, Esquire Attorneys for Plaintiff ire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Kimberly L. Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA17055 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") PLAINTIFF VS. KIMBERLY L. LENKER DEFENDANT(S) : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-3554 CIVIL TERM Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $47,522.96 on September 23, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") v. KIMBERLY L. LENKER 34441CWE—DN COURT OF COMMON PLEAS DOCKET NO. 14-3554 Civil Term ATTORNEY I.D. #52634 ATTORNEY LD. #309906 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 9/24/2014 to 3/4/2015 At 6 % TOTAL* *Plus costs to be endorsed $ 47,522.96 $ 1,265.22 $ 48,788.18 MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rose Heather Riloff, Esqu Attorneys for Plainti PREM: 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055 .s'y -Pcf,_ Al IL/ 4- (03. 75cos.4-s s 31,30 g 5-0 ti 11 ld ed5- 45'1,50 apUS tell 2//(0/ G.") -77 koo. Esquire •••„--•••, ; • Commonwealth Of Pennsylvania COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 v KIMBERLY L. LENKER 595 Geneva Drive, Apartment 14 a/lc/a 595-14 Geneva Drive Mechanicsburg, PA 17055 COURT OF COMMON PLEAS DOCKET NO. 14-3554 Civil Term ATTORNEY I.D. #52634 ATTORNEY I.D. #309906 Writ Of Execution (Mortgage Foreclosure) TO THE SHERIFF OF CUMBERLAND COUNTY CWE34441-DN To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA17055 (see attached Exhibit I) AMOUNT DUE 47,522.96 INTEREST FROM 9/24/2014 to 3/4/2015 at 6 % 1,265.22 TOTAL* $ 48,788.18 *Plus costs to be endorsed David D. Buell, Prothonotary By. Deputy MARTHA- j. VON ROSENSTIEL, P.C. Martha E. iit41 1 osenstiel, Esquire / No. 52634 Heather Mat; Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff VS. KIMBERLY L. LENKER Defendant(s) #34441 -DN : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-3554 CIVIL TERM LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: ALL THAT CERTAIN Unit, being Unit No. 595-14 (the 'Unit'), of Sunguild III, A condominium, located in Upper Allen Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Sunguild III, A Condominium (the 'Declaration of Condominium') on Declaration Plats and Plans as recorded in the Recorder's Office of Cumberland County in Misc. Book 357, page 20 and Right of Way Plan Book 9, page 24. TOGETHER with an undivided 7.5218% interest in Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration and matters which a physical inspection and survey of the Unit and Common Elements would disclose. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successors and assigns, by the acceptance of this Deed, covenants and agrees to pay such charges for maintenance, repairs, replacements and other expenses in connection with the Common Elements and any Limited Common Elements appurtenant to said Unit, as may be assessed against him, her, them, it or said Unit, from time to time by the Executive Board of the Sunguild III Condominium Associates in accordance with the Uniform Condominium Act of Pennsylvania, and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a lien for all amounts so assessed except insofar as Section 3407(c) of said Uniform Condominium Act may relieve a subsequent Unit Owner of liability for prior unpaid assessments. This covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. PARCEL IDENTIFICATION NO: 42-24-0791-163.-U595-14, CONTROL #: 42000618 IMPROVEMENTS: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Kimberly L. Lenker, single individual, by Deed from Lisa A. Sullivan, nka, Lisa S. Rohrer and Curt R. Rohrer, h/w, dated 06/12/2000, recorded 06/15/2000 in Book 223, Page 461. #34441 CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 Sou ' Avenue, Suite 7 Secar; ;SIA 190}8 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS - =' ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY , c - _-,-- 7 Plaintiff z �` m rti rn ci)c— VS.ort 3 : NO: 14-3554 CIVIL TERM > c, = c' `'' KIMBERLY L. LENKER - = - Defendant(s)`3 c..a i• ,, AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055: 1. Name and address of owners(s) or reputed owner(s) Kimberly L. Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 2. Name and address of defendant(s) in the judgment: Kimberly L. Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sunguild III Condominium Association c/o Horst Property Management, PO Box 3330 Lancaster, PA 17604-3330 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person ofwhom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cugiberland County Tax Claim 1•Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Depaitinent of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 Occupant 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 verify that the statements made in this affidavit are true and correct upon information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY: Dated: September 22, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E Von Rose Heather Riloff, Esqui Attorneys for Plaintiff squire MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South. Avenue, Suite 7 Secant, AA 19018 (610)32S-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION ("FANNIE MAE") : CUMBERLAND CqUNTY Plaintiff vs. : No: 14-3554 Civil Term KIMBERLY L. LENKER Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: 34441CAM-DN rri -o The real estate and improvements, if any, located at and known as 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 will be sold by the Sheriff of Cumberland County on Date of Sale: March 04, 2015 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 14-3554 Civil Term in the Court of Common Pleas of Cumberland County by Federal National Mortgage Association ("Fannie Mae"), Plaintiff against Kimberly L. Lenker, Defendant(s). Judgment was entered on September 23, 2014 in the amount of $47,522.96. The property was seized and taken in execution as the property of Kimberly L. Lenker. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: ALL THAT CERTAIN Unit, being Unit No. 595-14 (the 'Unit'), of Sunguild III, A condominium, located in Upper Allen Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Sunguild III, A Condominium (the 'Declaration of Condominium') on Declaration Plats and Plans as recorded in the Recorder's Office of Cumberland County in Misc. Book 357, page 20 and Right of Way Plan Book 9, page 24. TOGETHER with an undivided 7.5218% interest in Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration and matters which a physical inspection and survey of the Unit and Common Elements would ' disclose. THE GRANTEE, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successors and assigns, by the acceptance of this Deed, covenants and agrees to pay such charges for maintenance, repairs, replacements and other expenses in connection with the Common Elements and any Limited Common Elements appurtenant to said Unit, as may be assessed against him, her, them, it or said Unit, from time to time by the Executive Board of the Sunguild III Condominium Associates in accordance with the Uniform Condominium Act of Pennsylvania, and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a lien for all amounts so assessed except insofar as Section 3407(c) of said Unifoini Condominium Act may relieve a subsequent Unit Owner of liability for prior unpaid assessments. This covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. PARCEL IDENTIFICATION NO: 42-24-0791-163.-U595-14, CONTROL #: 42000618 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 14-3554 Civil Term. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff Federal National Mortgage Association : COURT OF COMMON PLEAS ("Fannie Mae") : CUMBERLANDCOUNTY 3900 Wisconsin Avenue, NW Washington DC 20016-2892 Plaintiff vs. : No: 14-3554 Civil Term Kimberly L. Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 : Geneva Drive Mechanicsburg, PA 17055 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE Martha E. Von Rosenstiel, P.C. by the undersigned for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Kimberly L. Lenker 595 Geneva Drive, Apartment 14 alk/a 595-14 Geneva Drive Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. BY: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosensti 1, E ire Heather Riloff, Esquire Attorneys for Plaintiff #34441-CWE-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION ("FANNIE MAE") : CUMBERLAND COUNTY Plaintiff vs. KIMBERLY L. LENKER Defendant(s) : No: 14-3554 Civil Term CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA — Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit XX That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer,Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. MARTHA E. VON ROSENSTIEL, P.C. BY: C1111(43,--A-7- Martha E. Von Rosensti1,j1squire Heather Riloff, Esquire Attorneys for Plaintiff THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA • DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Vs. NO 14-3554 Civil Term CIVIL ACTION — LAW KIMBERLY L. LENKER 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: $47,522.96 L.L.: $.50 Interest FROM 9/24/14 TO 3/4/15 AT 6% - $1265.22 Atty's Comm: Atty Paid: $188.05 Plaintiff Paid: Date: 09/29/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotai Deputy REQUESTING PARTY: Name: HEATHER RILOFF, ESQ. Address: MARTHA E. VON ROSENSTIEL, P.C., 649 SOUTH AVENUE, SUITE 7, SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 309906 #34620CFJ-DN INflIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NRTn j&WIDE ADVANTAGE MORTGAGE COMPANY Plaintiff V. : NO. 14-3580 Civil TODD E. ANTHONY AND EVELYN R. ANTHONY : Defendant(s) PRAECIPE FOR DEFAULT. JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Todd E. Anthony and Evelyn R. Anthony for want of an answer. (X) A'ssess Damages as Follows Debt $ 145,532.02 Interest from 05/27/2014 to 9/23/2014 At $15.37 per diem. - $ 1,843.92 Total $ 147,375.94 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the 'intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if.any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 MARTHA E. VON ROSENSTIEL, P.C. BY: artha E. Von Rosen Heather Riloff, Esqui Attorneys for Plaintiff e This..of,9 Cm , 20l4judgment is entered in favor of the Plaintiffand against Defendant(s), Todd E. Anthony and Evelyn R. Anthony by default for want o assessed at the sum of $147,375.94 as per the ave ce n answer and damages ounty 111...SZkfid y ca4 (4747 Qth 3//1C)3 iOatikr- MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff TODD E. ANTHONY AND EVELYN R. ANTHONY Defendants #34620CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-3580 Civil TO: Evelyn. R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 9/9/14 Martha E. Von R Heather Riloff, Es Attorneys for Plaintiff Esquire MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff vs. No: 14-3580 Civil TODD E. ANTHONY AND EVELYN R. ANTHONY Defendant(S) #34620CFJ-DN NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, P.C. by the undersigned hereby certifies that: 1, I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: September 23, 2014 artha E. Von Rosens Esquire Heather Riloff, Esqui Attorneys for Plaintiff Todd E. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA17065 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. TODD E. ANTHONY AND EVELYN R. ANTHONY DEFENDANT(S) : NO: 14-3580 CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $147,375.94 on September 23, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. OFFICE OrTHE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Evelyn R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 David D. Buell, Prothonotary NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. TODD E. ANTHONY AND EVELYN R. ANTHONY DEFENDANT(S) : NO: 14-3580 CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $147,375.94 on September 23, 2014. David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. X 44' Commonwealth of Pennsylvania COUNTY OF CUMBERLAND NATIONWIDE ADVANTAGE MORTGAGE COMPANY v. TODD E. ANTHONY AND EVELYN R. ANTHONY 34620CWE-DN COURT OF COMMON PLEAS DOCKET NO. 14-3580 Civil ATTORNEY LD. #52634 ATTORNEY I.D. #309906 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 9/24/2014 to 3/4/2015 At 6 % TOTAL* *Plus costs to be endorsed $ 147,375.94 3,925.26 $ 151,301.20 MARTHA E. VON ROSENSTIEL, P.C. BY: artha E. Von Rose Heather Riloff, Esqui Attorneys for Plainti 4uire PREM: 77 Mountain Street Rear A ailc/a 77 Mountain Street, Mount Holly Springs, PA 17065 t02.8 . SO •Pc:C_ 3. 75--- 6,4.6 1) €1 di, al) 44-4-1't Cr.) OD Commonwealth Of Pennsylvania COUNTY OF CUMBERLAND .. NATIONWIDE ADVANTAGE MORTGAGE COMPANY 1100 LOCUST ST., DEPT. 2009 DES MOINES, IA 50391-2009. V TODD E. ANTHONY AND EVELYN R. ANTHONY 77 MOUNTAIN STREET REAR A A/K/A 77 MOUNTAIN STREET MOUNT HOLLY SPRINGS, PA 17065 COURT OF COMMON PLEAS DOCKET NO. 14-3580 Civil ATTORNEY I.D. #52634 ATTORNEY I.D. #309906 Writ Of Execution (Mortgage Foreclosure) TO THE SHERIFF OF CUMBERLAND COUNTY CWE34620-DN To satisfy the judgment, interest and costs in the above matter you are directed to levy, upon and sell the following described property: 77 Mountain Street Rear A a/k/a 77 Mountain Street, Mount Holly Springs, PA17065 (see attached Exhibit I) AMOUNT DUE INTEREST FROM 9/24/2014 to 3/4/2015 at 6 % $ 147,375.94 $ 3,925.26 TOTAL* $ 151,301.20 *Plus costs to be endorsed David D. Buell, Prothonotary By: Deputy #34620 -DN MARtHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-3580 CIVIL TODD E. ANTHONY AND EVELYN R. ANTHONY Defendant(s) LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Borough of Mount Holly Springs, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at an existing iron pin located in the North corner of land now or formerly of Kenneth and Sherry Anthony, recorded at Cumberland County Deed Book 31-T, page 743 and Plan Book 45, page 19; thence along land now or formerly of Hempt Bros., Inc., South 38 degrees 3 minutes 33 seconds East, a distance of 90.61 feet to a set iron pin; thence along the Northwest border of Lot No. 1 on the hereinafter Plan of Lots, South 43 degrees 59 minutes 21 seconds West, a distance of 236.24 feet to a set concrete monument; thence along land nowor formerly of Michael L. Gumby, North 43 degrees 38 minutes 48 seconds West, a distance of 90 feet to an existing iron pin; thence along land now or formerly of Hempt. Bros., Inc., North 43 degrees 59 minutes 21 seconds East, a distance of 241.93 feet to an existing iron pin, the place of BEGINNING. CONTAINING 0.4925 acres and being Lot No. 2 on a final subdivision plan for Kenneth Anthony by Eric L. Diffenbaugh, Professional Land Surveyor, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 68 page 7. HAVING THEREON erected a dwelling known and numbered as 77 Mountain Street- Rear A. UNDER AND SUBJECT, nevertheless, to all restrictions, reservations, conditions, covenants, easements and rights of way of prior record. PARCEL IDENTIFICATION NO: 23-32-2338-078., CONTROL #: 23000750 IMPROVEMENTS: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Todd E. Anthony and Evelyn R. Anthony, h/w, by Deed from Todd E. Anthony, married person, with the joinder of Kenneth C. Anthony and Sherry A. Anthony, h/w, dated 10/25/2005, recorded 11/02/2005 in Book 271, Page 3673. #34620CAM - DN MAWJ%Lt E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328=2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-3580 CIVIL TODD E. ANTHONY AND EVELYN R. ANTHONY Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 77 Mountain Street Rear A a/k/a 77 Mountain Street, Mount Holly Springs, PA 17065: 1. Name and address of owners(s) or reputed owner(s) Todd E. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Evelyn R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount.Holly Springs, PA 17065 2. Name and address of defendant(s) in the judgment: Todd E. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Evelyn R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Belco Community Credit Union 403 North 2nd Street 'Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the.property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O -Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 Occupant 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: 421 Martha E. Von Rosenst Heather Riloff, Esquire Attorneys for Plaintiff Dated: September 22, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE : COURT OF COMMON PLEAS MORTGAGE COMPANY : CUMBERLAND COUNTY Plaintiff vs. : No: 14-3580 Civil TODD E. ANTHONY AND EVELYN : R. ANTHONY Defendant(s) 34620CAM-DN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 will be sold by the Sheriff of Cumberland County on Date of Sale: March 04, 2015 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. Thissale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 14-3580 Civil in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against Todd E. Anthony and Evelyn R. Anthony, Defendant(s). Judgment was entered on September 23, 2014 in the amount of $147,375.94. The property was seized and taken in execution as the property of Todd E. Anthony and Evelyn R. Anthony. The property to be sold at Sheriffs Sale is described as follows: ALL THAT CERTAIN lot or piece of ground situate in Borough of Mount Holly Springs, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGIONING at an existing iron pin located in the North corner of land now or formerly of Kenneth and Sherry Anthony, recorded at Cumberland County Deed Book 31-T, page 743 and Plan Book 45, page 19; thence along land now or formerly of Hempt Bros., Inc., South 38 degrees 3 minutes 33 seconds East, a distance of 90.61 feet to a set iron pin; thence along the Northwest border of Lot No. 1 on the hereinafter Plan of Lots, South 43 degrees 59 minutes 21 seconds West, a distance of 236.24 feet to a set concrete monument; thence along land now or formerly of Michael L. Gumby, North 43 degrees 38 minutes 48 seconds West, a distance of 90 feet to an existing iron pin; thence along land now or formerly of Hempt. Bros., Inc., North 43 degrees 59 minutes 21 seconds East, a distance of 241.93 feet to an existing iron pin, the place of BEGINNING. CONTAINING 0.4925 acres and being Lot No. 2 on a final subdivision plan for Kenneth Anthony by Eric L. Diffenbaugh, Professional Land Surveyor, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 68 page 7. HAVING THEREON erected a dwelling known and numbered as 77 Mountain Street- Rear A. UNDER AND SUBJECT, nevertheless, to all restrictions, reservations, conditions, covenants, easements and rights of way of prior record. PARCEL IDENTIFICATION NO: 23-32-2338-078., CONTROL #: 23000750 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 14-3580 Civil. You should check with the Sheriffs Office by calling (717) 240- 6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff Nationwide Advantage Mortgage Company : COURT OF COMMON PLEAS 1100 Locust St., Dept. 2009 : CUMBERLANDCOUNTY Des Moines IA 50391-2009 Plaintiff vs. Todd E. Anthony and Evelyn R. Anthony : No: 14-3580 Civil 77 Mountain Street Rear A a/k/a 77 Mountain : Street Mount Holly Springs, PA 17065 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE Martha E. Von Rosenstiel, P.C. by the undersigned for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Todd E. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Evelyn R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY: MARTHA E. VON ROSENSTIEL, P.C. Mart a E. Von Rosens Heather Riloff, Esquire Attorneys for Plaintiff ire #34620-CWE-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY Plaintiff vs. TODD E. ANTHONY AND EVELYN R. ANTHONY Defendant(s) : No: 14-3580 Civil CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: XX FHA — Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenst Heather Riloff, Esquire Attorneys for Plaintiff re THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite]00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net NATIONWIDE ADVANTAGE MORTGAGE COMPANY Vs. TODD E. ANTHONY AND EVELYN R. ANTHONY 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: $147,375.94 L.L.: $.50 Interest FROM 9/24/14 TO 3/4/15 AT 6% $3.925.26 Atty's Comm: Atty Paid: $200.66 Plaintiff Paid: Date: 09/29/14 NO 14-3580 Civil Term CIVIL ACTION — LAW (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothono Deputy REQUESTING PARTY: Name: HEATHER RILOFF, ESQ. Address: MARTHA E. VON ROSENSTIEL, P.C., 649 SOUTH AVENUE, SUITE 7, SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 309906 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff VS, KIMBERLY L. LENKER Defendant(s) #34441CAM - DN : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-3554 CIVIL TERM --1:3 rn co zr'l cnr- , > AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Martha E. Von Rosenstiel, P.C. by the undersigned for the Plaintiff in the above action, / 1/ v-iy hereby verifies that on , true and correct copies of the Notice of rs.7 47;7, CZ) C=0 C-1 Sheriffs Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosens Heather Riloff, Esquire Attorneys for Plaintiff -r, For Accounta Name and MARTHA E. VON ROSENSTIEL, P.C. Address Attorney At Law of 649 South Avenue, Unit 7 Sender Secane, PA. 19018 34441 BP Indicate type of mail 0 Registered 0 Return Receipt for Merchandise 0 Insured 0 COD 0 Int'l Recorded Del. 0 Certified 0 Express Mail Check appropriate block for Registered Mail: 0 With Postal Insurance 0 Without Postal Insurance Affix stamp certified additional ,,. ' e4144- AIM-21348N .t.,. here it of mailing copies of .. • te.Sf-Receigt"--a,=jj: ge r C2 issued as or for thi0sP0s7. •c?- co , 1*-- 1P -'<es . _._ .. 7.,PITNEY BONES $ 005 170 Lin e Article Number ' Name of Addresses, Street, and Post Office Address Postage Fee Handling Charge(If Act. Value Regis.) Insured Value Due Send er If COD R. R. Fee C00173S253 - ' MAILED 1-110Pil F@g11151eZ0 ZIP CODE 190 13 S. D. Fee S. H. Fee Remarks 1 1 of 1 Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA. 17013 .48 2 Cumberland Register of Wills County Courthouse Carlisle, PA. 17013 .48 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC. 20044 .48 4 PA Department of Revenue Inheritance Tax Division, P.O. Box 280601 Harrisburg, PA 17128 .48 5 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA. 17013 .48 6 . PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 .48 7 Department of Public Welfare P.O. Box 2675 Harrisburg, PA. 17105 .48 8 Occupants/Tenants 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive Mechanicsburg, PA 17055 .48 _ .r. 9 PA. Department of Revenue Bureau of Individual Taxes P.O. Box 280603 Harrisburg, PA. 17128 .48 •e• J„, C) 0 VD 10 Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 .48 .•- 11 Kimberly L. Lenker 595 Geneva 595-14 Geneva Mechanicsburg, Drive, Apartment 14 a/k/a Drive .48 --. PA 17055 Total Number of Pieces Listed by Sender 11 Total Number of Pieces Received at Postmaster, P r (N , - o "e , m .11 o - N PU nJ ru O O O rR m r1 0 N U.S..Posta,I Service,. CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided)• For delivery information visit our website at www.usps.com® I5 C Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees ems•. MEWaQOST MEEPQM FF MEMa 8b, 49 r; ; eyI:_,.Leh vet Street, Apt. No.; /+� L Q vA or POBoxNo.71a� I4�� 11V 111 Snil%1G�ii F. Pi tiINefrt a A Pitos:3 See Revers.: f::f'•,structions PS For ,.3800; August 2006 U.S. POSTAL SERVICE CERTIFICATE OF NAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAID DOES NOT PROVIDE FOR INSURANCE—POSTMASTER 54 SES • • Received Front47(43- MARTHA VON ROS 649 SOUTH AV UNIT 7 SECANE, PA 19018 One piece of ordir mail addressed to: h ,Ai Id 111 CaIldoYli,h cq G `a Pc/ r‘4. eleoptir4y illkh4erhen Po /ci 22G 02 1P C Q 00017382 MAILED FRC La 6,418r, p,4 /ropey -g2 , PS Form 3817. Mar.1989 • V' Jo p Affix fee hen: in stamps 01 meter postage and Silos, mark. Inquire of tmaster for current =�Pr7alEY BOWES $ 001.300 3 OCT 06 2014 M ZIPCODE 19018 From: MVR Law To: 1-717-240-6397 Page: 1/1 Date: 10/23/2014 1:30:04 PM ovi1/4e--e (06,1- s_e_1(31 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, SUITE 6 SECANE, PA 19018 34441MSS CS Martha E. Von Roscnsticl, Esquirc Heather Riloff, Esquirc 10/23/2014 e' \\AI+ IN LA36-0 v\-ki-er— •e—ert-kafzt,e4 flea— 1:x_ Office of the Sheriff of Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 VIA FACSIMILE: 1-717-240-6397 RE: SALE DATE: PLAINTIFF: DEFENDANT: PREMISES: CRT/TRM #: Dear Sir/Madam: Phone: 610-328-2887, X-37 Fax: 610-328-2875 Email: connic@mvrlaw.com Ltkeu. w: pce, • OektAxil 03/04/2015 Federal National Mortgage Association ("Fannie Mae") Kimberly L.- Lenker 595 Geneva Drive, Apartment 14 a/k/a 595-14 Geneva Drive, Mechanicsburg, PA 17055 14-3554 Civil Term Please STAY the Sheriff's Sale on tqe above captioned matter as the Plaintiff is in receipt of payoff funds. The amount collected to staythis sale was $47,659.82. Kindly advise within 5 days if monies are owed as Plaintiff will not pay bills outside of that timeframe. • If monies are owed, please provide your outstanding costs to our office via fax at 610-328-2875 or via email at connie@mvrlaw.com. • If a refund is due, please mail to our office along with a breakdown showing amounts expended. Thank you for your assistance in this matter and please contact me if you have any questions. Sincerely yours, Connie Spross Connie Spross Paralegal Assistant Martha E. Von Rosenstiel, P.C.