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Home My WebLink About14-3789 Supreme Court of Pennsylvania Court'o Com44`1mon Pleas s . For Prothonotary Use Only: C1vIl;COVek.Sheet CU I County Docket No: r ,y The information collected on this form is used solely for court administration purposes. This,form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules of court. Commencement of Action: S ❑x Complaint ❑ Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: FEDERAL NATIONAL Lead Defendant's Name: GEOFFREY S. YUDA C MORTGAGE ASSOCIATION("FANNIE MAE"),A T CORPORATION ORGANIZED AND EXISTING UNDER I THE LAWS OF THE UNITED STATES OF AMERICA Dollar Amount Requested: ❑ within arbitration limits 0 Are money damages requested? ❑ Yes ❑x No (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes Z No A Name of Plaintiff/Appellant's Attorney: Michael Dingerdissen,Esq., Id.No.317124,Phelan Hallinan,LLP ❑ 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 ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑Motor Vehicle ❑Debt Collection: Other ❑ Board of Elections ❑Nuisance ❑ Dept. of Transportation ❑Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability(does not S include mass tort) ❑Employment Dispute: ❑ Slander/Libel/Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑ Ejectment ❑Common Law/Statutory Arbitration B ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑ Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations ®Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY El Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑Quiet Title ❑ Other: ❑Medical ❑ Other: 0 Other Professional: 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 this 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 tp 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 claimed in the Complaint or 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, 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File 4: 800354 li1"'1 27 Fars 6a k° CUNiBERLANO CCJi; T`( PENNSYLVANIA PHELAN HALLINAN,LLP Michael Dingerdissen,Esq:,Id.No.317124 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 Michael.Dingerdissen@phelanhallinan.com. 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"),A CORPORATION ORGANIZED COURT OF COMMON PLEAS AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA CIVIL DIVISION 14523 SW MILLIKAN WAY, SUITE 200 BEAVERTON, OR 97005 TERM Plaintiff NO. i4-3'784 �w�l IErm V. CUMBERLAND COUNTY GEOFFREY S.YUDA, in his capacity as Executor of the Estate of SARA D. STRONG 1201 RED HILL RD DAUPHIN,PA 17018-9431 DAVID M. STRONG,in his capacity as Devisee of the Estate of SARA D. STRONG 405 WALNUT BOTTOM ROAD CARLISLE,PA 17013-3743 Defendants CIVIL ACTION-LAWS COMPLAINT IN MORTGAGE FORECLOSURE -4 1D3.r7 5 Pty Rrt File a: 800354 0(`Y3J-J5`7 �#3oTAo 9 1. Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION("FANNIE MAE"),A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA 14523 SW MILLIKAN WAY, SUITE 200 BEAVERTON,OR 97005 2. The name(s)and last known address(es) of the Defendant(s) are: GEOFFREY S.YUDA, in his capacity as Executor of the Estate of SARA D. STRONG 1201 RED HILL RD DAUPHIN,PA 17018-9431 DAVID M. STRONG,in his capacity as Devisee of the Estate of SARA D. STRONG 405 WALNUT BOTTOM ROAD CARLISLE,PA 17013-3743 who is/are the real owner(s) of the property hereinafter described. 3. On 03/09/2004 SARA D. STRONG made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. AS A NOMINEE FOR NBANK,N.A.,which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1857, Page 1262. By Assignment of Mortgage recorded 02/14/2014 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No.201403236.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File#: 800354 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2012 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 06/12/2014: Principal Balance $88,955.15 Interest $5,846.05 03/01/2012 through 06/12/2014 Late Charges $45.96 Property Inspections $247.50 Property Preservation $646.06 Escrow Deficit $6,367.55 TOTAL $102,108.27 7. Plaintiff is not seeking a judgment of personal liability (or an in person am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s)has/have received a discharge of personal liability in a bankruptcy proceeding,this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy,but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974,Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s)on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s)has/have failed to File#: 800354 meet with the Plaintiff or an authorized consumer credit counseling agency,or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9., The mortgage premises are vacant and abandoned. 10. Mortgagor SARA D. STRONG died on 06/13/2009, leaving a Last Will and Testament dated 05/14/2009. Letters Testamentary were granted to GEOFFREY S. YUDA on 09/22/2011 in CUMBERLAND COUNTY,No. 2011-00984. The Decedent's surviving heir at law and next-of-kin is DAVID M. STRONG. 11. Plaintiff does not hold the named Defendants, GEOFFREY S. YUDA and DAVID M. STRONG,personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendants in the aforesaid real estate only,and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). WHEREFORE,Plaintiff demands an in rem judgment against the Defendant(s)in the sum of $102,108.27,together with interest, costs, fees, and charges collectible-under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP s By Michael Dingerdissen,Esq., Id.No.317124 Attorney for Plaintiff Reg: 800354 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land Iocated on the North side of the Walnut Bottom Road in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the North side of the Walnut Bottom Road,which point is fifteen (15) feet West of the line dividing Lots 10 and 11 on the Plan of East Hill; thence along the Walnut Bottom Road,North fifty-six(56)degrees Seven(7)minutes East, one hundred five (105)feet to a point in the center of Lot No. 12 on said Plan;thence through the center of Lot 12, North thirty-three (33) degrees fifty-three (53) minutes West,one hundred forty-eight (148) feet, more or less,to a point on the line dividing Lots 12 and 13 from Lot 14;thence along said dividing, South forty-one (4 1) degrees twelve (12) minutes twenty (20) seconds West,thirty-one and forty-five hundredths (31.45) feet to a point on the line dividing Lots 10 and 11 from Lots 15 and 16; thence along said last mentioned dividing line, South fifty-six(56) degrees seven(7) minutes West, seventy-eight and thirty-one hundredths(78.31)feet to a point fifteen(15)feet West of the line dividing Lots 10 and 11;thence through Lot 10, South thirty-three (33) degrees fifty-three (53)minutes East, one hundred forty (140) feet to the place of BEGINNING. The tract above described is composed of the Eastern fifteen(15) feet of Lot 10, all of Lot 11, and the Western thirty 930)feet of Lot 12 as appears on the aforesaid Plan of East Hills. PROPERTY ADDRESS: 405 WALNUT BOTTOM ROAD,CARLISLE,PA 17013-3743 PARCEL#04-22-0481-121 File 4: 800354 M VERIFICATION 1„Shawann Hampton ,hereby state that I am Foreclosure Specialist of SETERUS,INC.,mortgage servicing agent for Plaintiff in this matter. The Plaintiff has delegated the mortgage servicing responsibility to SETERUS, INC. for the mortgage loan which is the subject of this action. Plaintiff lacks sufficient information to make this verification because Plaintiff is not the entity which maintains the business records for the mortgage. SETERUS, INC. is in possession and control of all documents and records supporting the statements in the foregoing complaint and therefore the servicer,rather than the Plaintiff, is the appropriate entity to make this verification. I have reviewed the business records relating to this account, and am authorized to make this verification. I hereby verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: Int fit ' Name:Shawann H"ton 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. File#: 800354 Name: YUDA File 4: 800354 Pa.R.C.P. 205.5 Updated 01/01/2011 FORM 1 IN THE COURT OF COMMON PLEAS FEDERAL NATIONAL MORTGAGE OF CUMBERLAND COUNTY, PENNSYLVANIA ASSOCIATION("FANNIE MAE"),A CORPORATION ORGANIZED AND EXISTING r, UNDER THE LAWS OF THE UNITED STATES c ro 41 OF AMERICA Plaintiff(s) 37v/ NaTeolM cn vs. <r -_r v , r--M —_?cl CD GEOFFREY S.YUDA,in his capacity as Executor > y CD CD-rr of the Estate of SARA D. STRONG C DAVID M. STRONG,in his capacity as Devisee of .�.. T.. the Estate of SARA D. STRONG o Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be albe 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)2439400 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 represerftative,you must promptly meet with that 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 canbe 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 a Request for Conciliation Conference with the Court,which must be filed with the Cou-t 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 arrangenents 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 woksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed 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 arguments 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: dr Date Michael Dingerdissen,Esq., Id.No.317124 Attorney for Plaintiff FORM Z 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 counseling agency. Please provide the following information to the best of your knowledge: ER/PRICUSTOM . . Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State:__Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? CO-BORROWER 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 & 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: $ $ 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: I. 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 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 Su ort/Alim. Spending Mone Da /Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income &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? Yes ❑ No ❑ If yes,please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and 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 counseling services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement(if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff . of Comber/ Jody S Smith Chief Deputy f ij J1J! 17 �� 'G' Richard W Stewart 'jMBE RLAk,1 _.. _ 1 Solicitor = F r 1 Federal National Mortgage Assocation Case Number vs. Geoffrey S Yuda (et al.) 2014-3789 SHERIFF'S RETURN OF SERVICE 06/27/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Geoffrey S Yuda, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/02/2014 01:25 AM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Geoffrey S Yuda, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 405 Walnut Bottom Road, Carlisle Borough, Carlisle, PA 17013. Residence is vacant. 07/02/2014 01:25 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David M Strong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 405 Walnut Bottom Road, Carlisle Borough, Carlisle, PA 17013. Residence is vacant. 07/14/2014 07:39 AM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Geoffrey S Yuda, personally, at 1201 Red Hill Road, Dauphin, PA 17018. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $76.78 SO ANSWERS, July 14, 2014 RONR ANDERSON, SHERIFF :ot;^!i$U �Sher!:',ielaosett +-+c. it*fi l � c, 4crifre Auk, AAA �: Shelley Ruhl �E _ Jack Duignan Real Estate Deputy ;a11v' % Chief Deputy 'ffiMatthew L. Owens ��+'�� ''�� ...� �- Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), ET AL VS GEOFFREY S. YUDA, IN HIS CAPACITY County of Dauphin AS EXECUTOR OF THE ESTATE OF SARA D. STRONG Sheriffs Return No. 2014-T-1941 OTHER COUNTY NO. 2014-3789 And now: JULY 7, 2014 at 7:39:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon GEOFFREY S. YUDA, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF SARA D. STRONG by personally handing to GEOFFREY YUDA 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at POE: 111 STATE STREET HBG PA 17101 Sworn and subscribed to So Answers, before me this 8TH day of July, 2014 +� Sheriff of P 6r. eeOr k, r COMMONWEALTH OF PENNSYLVANIA Deputy Sheriff " NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public Sheriffs Costs: $49.25 7/1/2014 City of Harrisburg,Dauphin County My Commission Expires January 8,2018 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.lobb@phelanhallinan.com 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff vs. I E PRO HONQ ( 8 .. 014 AUG -4 AtlIC: 16 CUMBERLAND COUNTY PENNS YLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY GEOFFREY S. YUDA, in his capacity as : No. 14-3789 CIVIL Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /mig, Svc Dept. File# 800354 PHELAN HALLINAN, LLP Jona/ Lobb, Esq., Id. No.312174 Attorney for Plaintiff ctivt I).'vc 0.y CAJk 14413 H PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY GEOFFREY S. YUDA, in his capacity as : No. 14-3789 CIVIL Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /nru, Svc Dept. File# 800354 PHELAN HALLMAN, LLP Jonlern Lobb, Esq., Id. No.312174 Attorney for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r- LE�0y 0FFICL THE PF1V TH0NO iARit 2014 OCT 24 PM 3:35 CUMBERLAND COUNTY PENNSYLVANIA OFF r:;EO,. E $HERiF Federal National Mortgage Assocation vs. Geoffrey S Yuda (et al.) Case Number 2014-3789 SHERIFF'S RETURN OF SERVICE 08/05/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David M Strong, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 10/22/2014 The Sheriff of Allegheny County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David M Strong, but was unable to locate the Defendant in his bailiwick. The Allegheny County Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Served" at 403 Commerce Street, Apt. 23, Wilmerding, PA 15148. SHERIFF COST: $37.00 SO ANSWERS, October 22, 2014 (c) CountyS.uite Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF f1 Oct. 7. 2014 2:15PM Cumberland County Sherrif EKING, PA 161 EXP: 09103/2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy No. 1i634. 2112 SHERIFF'S OFFICE OF CUMBERLAND COUNTY _�t9 n� LItU ki.a., 4e O=FICE OF rr,6.$'.1P1F= Richard W Stewart Solicitor Federal National Mortgage Assocation vs. Geoffrey S Yuda (et al.) Case Number 2014-3789 SERVICE COVER SHEET ' "'<�4;'�,�"',":.i"Irfi`a ;'r,y;�9;:''•C"•i I`..� I"'i !l "I5�?t, Category: 'Civil Action - Complaint in Mortgage Foreclosure Manner: Notes: 403 COMMERCE STREET, APT. 0 o• Now, August 05, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to execute service of the documents herewith and make return thereof according to law. 7J" !1.1!!1. ��l'IJJ�..�_.xi_ir��.'MIi1LU�fI1��I��I��.1,:11:J••,i.wl�J�.r.n_• �.vy1w, �!f,��' 1 Zone: l I Deputize Expires: 09/03/2014 1 Warrant: ;,,><.�I.�C� s :{fit �'l;�, 'iii: !' 1!I Ittl1�i ; •��' -' ame: !David M Strong WIHWIINIMMINWIJ Served: Personally • Adult Irlf Charge • Posted • Other r.1- 7;? l? i!Iii?Ai. t I,P>?7Kji(1 rimary 403 Commerce Street, Apt. 23 Adult In ddress: Wilmerding, PA 15145 Charge: hone: , s. Alternate Address: Phone: DOB: Relation: Date: Deputy: A#to(rie`'y .., , , .'tiq,t P upp li' 1 1111E < RVERV RENT Name: Joseph Schalk I Phone: 215-563-7000 Sengee Date: Time: Mileage: Deputy: Time: Mileage_ . f:..;.f..: . . , . „,.• 01111113 e.• `� ''��;:I•,!;i,i7,l.:'•aaa: ,,i,,r, ,I ,I>t:: „I •,r(;i:)?:,,,�I�.. ;'+i!'! ��r =:tr'i hr � _ � "r;;1' .. .per•'111....•. ,..�. ,.,�..:�.,., w�,u�,l.�i�..'{,r°I�'.�l_,Ir�iUl,��i� .,,.,�,�.: �...��.!....; ,u��,�7. ��..Irl,u,ii�li�l��i,��li;�:r•i<.�is�I,..�� : _ ;;�_�� •. �� '- - I COMMONWEALTH• OF PENNS�V 400 Notarial Seal Eda Jean Woodward. Notary P City of P Ceburgh, Allegheny Cou NIA ab is my —.---My-Canamiyunn Fxplras May 28. 2016 MEMBER, PENNSYUANIA ASSOCIATION OF NOTARIES • r s%Specrahig:_iwo f ` ;;1,. i=r'!+:'°`' O ( ` o NcftCCdy-oyt_s -`U n , c��ioce /5'7 pReturn To: !Y Cumberland County Sheriffs Office w One Courthouse Square Carlisle, PA 17013 •... -.• lilt 1. Fonny R Anderson, Sheriff Case Details Page 1 of 1 [Service Attempt History] [Account Information] [Payment Input] [Home] Case No 2014-3789 Notice and Complaint/Mort.Foreclosure Service Address Entry Date: 08/18/2014 Service Address Entry Time: 02:50 PM Parties Desc Defendant -- Plaintiff -- , -- Defendant -- David M. Strong Federal National Mortgage Association Service Date Services Service Attempt Histor4 Desc Defendant Person Served Served By Type Service Date Service Date Status Notice and Complaint- Mortgage Foreclosure David M. Strong 121 Brinton Avenue Pitcaim, PA 15140 Pitcairn Boro I Notice and — Ready to serve Complaint - Mortgage Foreclosure Notice and Complaint- Mortgage Foreclosure David M. Strong 403 Commerce Street Wilmerding, PA 15148 Wilmerding Boro Dan Macioce Notice and 9/3/2014 15:23 NSM - Defendant (s) refusal to respond to notifications left Complaint- Mortgage Foreclosure http://dcr,alleghenycounty.us/SheriffCases/OtherCaseDetails.asp?CaseID=2014-3789 10/7/2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F//Fo-oFFtcL 7614NOV17 P� ��D� � _ .� CUMBERLAND COUNTY PENNSYLVANIA �� "wu*�^ OFFICE Of Ti-tf. $1.4 RIFF Federal National Mortgage Assocation vs. Geoffrey S Yuda (et al.) Case Number 2014-3789 SHERIFF'S RETURN OF SERVICE 09C26/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to witDavid M Strong, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/16/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Allegheny County upon David M Strong, personally, at 121 Brinton Avenue #2, Pitcairn, PA 15140. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST$37.00 SO ANSWERS, November 06, 2014 RONNYRANDERSON, SHERIFF EXP: 10/24/2014 y R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY IT CI( 01\1 4).ted OFFICE Or THE SRERIFF Richard W Stewart Solicitor Federal National Mortgage Assocation vs. Geoffrey S Yuda (et al.) Case Number 1--201-4=3789 [ervice Details: Category: Manner: Notes: a. [erve To: SERVICE COVER SHEET Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Deputize Expires: 10/24/2014 Zone: Warrant: Name: David -M Strong Primary Address: Phone: Alternate Address: Phone: 121 Brinton Avenue #2 Pitcairn, PA 15140 DOB: [Final Service: Served: Adult In Charge: Relation: Date: Deputy: dult In Charge • Posted • Other /6 --/-ft/ Time: Mileagth- 3 Attorney / Originator: Name: Joseph Schalk [Service Attempts: Date: Time: co • Mileage: • Deputy: •gr Deputy: STRONG, DAVID M Phone: *.c-• 215-563-7000 itlotes 1 Special lnstr ctions: L4A4-- 464W4k40 " Da LL.1 Aete<-/eNce /57 4481( • Now, September 26, 2014 I, Sheriff of Cumberland County, Pennsylvania do he to execute service of the documents herewith and make return thereof according to I Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 (c) CountyStree Sheriff. TeIensoll, Inc ize the Sheriff of Allegheny County Ronny R Anderson, Sheriff COMMANWThO: ENNSY VAN Notarial -Ed )C3fl City of Pittsburgh, flits -MyeenialisE4sa-Expres LIV BER, PENNSYLVANIA AO seni , Notary Public -pony County :IATION OFirTARIES itlotes 1 Special lnstr ctions: L4A4-- 464W4k40 " Da LL.1 Aete<-/eNce /57 4481( • Now, September 26, 2014 I, Sheriff of Cumberland County, Pennsylvania do he to execute service of the documents herewith and make return thereof according to I Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 (c) CountyStree Sheriff. TeIensoll, Inc ize the Sheriff of Allegheny County Ronny R Anderson, Sheriff OF f ti _ ;i\U (ciJi;U BAR PHELAN HALLINAN, LLP [ 9 ! DEC 1 1 f.tl 10: 05 Michelle J. Stranen, Esq., Id. No.208793 1617 JFK Boulevard, Suite 1400 (' _Ii• ;; ;1/ {FJ COUNTY One Penn Center Plaza F E S i; Y `S Y LVJA N I A Philadelphia, PA 19103 michelle.stranen@phelanhallinan.com 215-563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA vs. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Attorney for Plaintiff : CUMBERLAND COUNTY • • • • COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14-3789 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against GEOFFREY S. YUDA, in. his capacity as Executor of the Estate of SARA D. STRONG, and DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $102,108.27 TOTAL $102,108.27 I hereby certify that (1) the Defendants' last known addresses are 1201 RED HILL RD, DAUPHIN, PA 17018-9431, 405 WALNUT BOTTOM ROAD, CARLISLE, PA 17013-3743, 111 STATE ST, HARRISBURG, PA 17101-1025, and 121 BRINTON AVE # 2, PITCAIRN, PA 15140-1501, and (2) that notice has been given in accordance with ul- Pa.R.C.P 237.1. Date 121101 I Mi helle J. Str.' en, Esq., Id. No.2087 Attorney DAMAGES AR HEREBY ASSESSED AS INDICATED. DATE: Il 1� I Ulnt 41140-Pdwr arkt �G 800354 800354 NArilce 44tw 31Yyl04 PHELAN HALLINAN, LLP Michelle J. Stranen, Esq., Id. No.208793 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 michelle.stranen@phelanhallinan.com 215-563-7000 FEDERAL NATIONAL MORTGAGE . ASSOCIATION ("FANNIE MAE"), A . CORPORATION ORGANIZED AND . EXISTING UNDER THE LAWS OF THE : UNITED STATES OF AMERICA vs. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 14-3789 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG's Social Security Number is not available because he is not the borrower on the loan, and thus, we are unable to determine whether or not GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG is in military service. (b) that the defendant DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG's Social Security Number is not available because he is not the borrower on the loan, and thus, we are unable to determine whether or not DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG is in military service. (c) that defendant GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG, the Plaintiff is without sufficient information to determine whether the defendant is over 18 years of age and resides at 1201 RED HILL RD, DAUPHIN, PA 17018-9431, 405 WALNUT BOTTOM ROAD, CARLISLE, PA 17013-3743, and 111 STATE ST, HARRISBURG, PA 17101-1025. 800354 (d) that defendant DAVID M. STRONG, in his capacity as Deviseeof the Estate of SARA D. STRONG, the Plaintiff is without sufficient information to determine whether the defendant is over 18 years of age and resides at 121 BRINTON AVE # 2, PITCAIRN, PA 15140-1501 and 405 WALNUT BOTTOM ROAD, CARLISLE, PA 17013-3743. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date (Z (0.14 Ph an Hallin, LLP Michelle J. Stranen, Esq., Id. No.208793 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 800354 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: STRONG First Name: SARA Middle Name: D Active Duty Status As Of: Dec -10-2014 Results as of : Dec -10-2014 12:05:23 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 'f +, \15r.' ._ ..--+w.-V ..rr No\ NA This response reflects the individuals' active duty status based on the Active Duty Status Date r Left Active Duty Within 367 Da s of Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA IV. r.NA� _ .c^- ..f\ ` 'i 1 X.=,7:; -Z., -No?'" i�I.,% NA This response reflects where the individual left actio duty status within367days 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 S NA ''N. `'. `4_ • ... , T.,`,.;1101/ . .-` ,Y 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 (Rule of Civil Procedure No. 236) - Revised FEDERAL NATIONAL MORTGAGE CUMBERLAND COUNTY ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND : COURT OF COMMON PLEAS EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA vs. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG : CIVIL DIVISION • : No. 14-3789 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on Q111119 . If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Michelle J. Stranen, Esq., Id. No.208793 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** • 800354 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff V. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-3789 CIVIL CUMBERLAND COUNTY To: GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG 1201 RED HILL RD DAUPHIN, PA 17018-9431 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. DATE OF NOTICE: 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 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 er C7" PETER NIA Esq., Id. N�,31826 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff V. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendant(s) TO: GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG 405 WALNUT BOTTOM ROAD CARLISLE, PA 1701.3-3743 COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-3789 CIVIL CUMBERLAND COUNTY DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE IF YOU HAVE:PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS. CORRESPONDENCE 1,S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A 'DEBT; BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 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 01 -PER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETE R, Esq., Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff v. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-3789 CIVIL CUMBERLAND COUNTY Defendant(s) TO; GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG 111 STATE ST HARRISBURG, PA 17101-1025 DATE OF NOTICE:. ).(iF ff YIf I THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4- ,er- PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff v. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG COURT OF COMMON PLEAS CIVIL DIVISION NO, 14-3789 CIVIL CUMBERLAND COUNTY Defendant(s) TO: DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG 121 BRINTON AVE # 2 PITCAIRN, PA 15140-1501 DATE OF NOTICE: 2.4t t THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, 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 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 O1 -}ER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By; PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETER PNEEsq., A Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 d. No.3 8263 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff V. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendant(s) TO: DAVID M. STRONG, in his capacity as Devisee 405 WALNUT BOTTOM ROAD CARLISLE, PA 17013-3743 DATE OF NOTICE: THIS FIRM IS A - T.COLL.ECTaR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY., THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.. j COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-3789 CIVIL CUMBERLAND COUNTY of the Estate of SARA D. STRONG 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS 01 -1 -ICE 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 FT MIELE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 1 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA Plaintiff V. GEOFFREY S. YUDA, in his capacity as Executor of the Estate of SARA D. STRONG DAVID M. STRONG, in his capacity as Devisee of the Estate of SARA D. STRONG Defendant(s) TO: C/O GEORFFREY S. YUDA SUSAN J. HARTMAN, ESQ, ONE IRVINE ROW CARLISLE, PA 17013 10241 tf DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEB TEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. AAt. COURT OF COMMON PLEAS CIVIL DIVISION NO, 14-3789 CIVIL CUMBERLAND COUNTY 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 OBJECI IONS 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 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 800354 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 By: PETER WAPNER, Esq., Id. No. 8263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103