HomeMy WebLinkAbout14-4508 Supreme Court of Pennsylvania
Court of Common Meas - ForProthonotaly Use Only:- -
Civil Cover Sheet
Docket No:
CUMBERLAND Count �!
777e information collected on this form is used solely for court administration purposes. This form does not
.supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S 0 Complaint ❑ Writ of Summons 0 Petition
Transfer from Another Jurisdiction ❑ Declaration of Taking
E
Lead Plaintiff s Name: U.S. BANK NATIONAL Lead Defendant's Name:
C ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA WILLIAM M. WILHELM
T
Are money damages requested? El No Dollar Amount Requested: within arbitration limits
I
(check one) E]outside arbitration limits
O
N Is this a Class Action Suit? El Yes E No Is this an MDJAppeal? El Yes 0 No
A Name of Plaintiff/Appellant's Attorney: Leon P. Haller, Esquire/Jill Wineka, Esquire
C.heel!.:l,�re it'ys�u lta��e no auto::��.ey(a�•e a�sAf-�.eresentecl [Pro S•e� 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
El Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment
0 Motor Vehicle ❑ Debt Collection: Other 0 Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability El Statutory Appeal: Other
S 0 Product Liability(does not include
E mass tort) El Employment Dispute:
❑ Slander/Libel/Defamation Discrimination
❑
C ❑ Other: Employment Dispute: Other ❑ Zoning Board
,I, Other:
I ❑ Other:
O MASS TORT
El Asbestos
N E] Tobacco
❑ Toxic Tort-DES
Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: El Ejectment [I Common Law/Statutory Arbitration
B ❑ Eminent Domain/Condemnation ❑Declaratory Judgment
0 Ground Rent ❑ Mandamus
Landlord/Tenant Dispute ❑Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LLABLITY 0 Mortgage Foreclosure: Commercial ❑Quo Warranto
Dental ❑ Partition El Replevin
Legal ❑ Quiet Title ❑Other:
Medical ❑ Other:
El Other Professional:
Updated 111/2011
F'1 �O'OC���—
OF THE PROTHONOTARY
Leon P. Haller, Esquire 29h JUL 31 AM gs 55
Purcell, Krug&Haller CUMBERLAND COUNTY
1719 North Front Street PENNSYLVANIA
Harrisburg, PA 17102
717.234.4178
mtg@pkh.com
U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS
TRUSTEE FOR THE PENNSYLVANIA HOUSING OF CUMBERLAND COUNTY, PENNSYLVANIA
FINANCE AGENCY
Plaintiff CIVIL ACTION-LAW
vs. ACTION O/F M,OrRTGAGE FORECLOSURE
//
WILLIAM M. WILHELM, !'7 — `? go& (!?t,u l,C
Defendant --Te-(I"
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,you must take action
within.twenty(20)days after the Complaint and notice are served,by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so
the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money
claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
717-249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS,ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE
SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED,O SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA,EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
CONTRA LAS QUEJAS EN ESTA DEMANDA,
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES,LA COUTE PUEDE, SIN NOTIFICARIO,DECIDIR A FAVOR DEL DEMANDANTE Y
REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA
DECISION,ES POSSIBLE QUE USTED PUEDA PERDER DINERO,PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO,LLAME AL"LAWYER REFERENCE SERVICE"(SERVICIO DE REFERENCIA
DE ABOGADOS),(215)238-6300. 0 d
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 113 7s-oW 4�
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET /6/�yoCARLISLE,PA 17013 `�
717-249-3166 #JQ Q?? 2 0
U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS
TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA
FINANCE AGENCY,
Plaintiff
CIVIL ACTION LAW
vs. ACTION OF MORTGAGE FORECLOSURE
WILLIAM M. WILHELM,
Defendant
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.C. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor.
PURCELL, KRUG& HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorney I.D.# 15700
Attorney for Plaintiff
U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS
TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA
FINANCE AGENCY,
Plaintiff CIVIL ACTION - LAW
vs. ACTION OF MORTGAGE FORECLOSURE
WILLIAM M. WILHELM,
Defendant
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA
HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 and as
amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through the Pennsylvania
Housing Finance Agency ("Agency"), its appointed Limited Power of Attorney, with an address of 211
North Front Street, Harrisburg, Pennsylvania 17101. The Limited Power of Attorney executed October
4, 2006 between the Plaintiff and the Agency is recorded in the Recorder of Deeds Office of the within
County and Commonwealth on October 11, 2006 in Book 0731, Page 0421. The Limited Power of
Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g).
2. Defendant, WILLIAM M. WILHELM, is an adult individual whose last known address is 4316 ALLEN
ROAD, CAMP HILL, PA 17011.
3. On or about, January 28, 2011, the said Defendant executed and delivered a Mortgage Note in the sum
of$88.00 payable to MEMBERS FIRST FEDERAL CREDIT UNION, which Note is attached hereto
and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain
real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth on February 3, 2011 in Instrument No. 201104275 conveying to original Mortgagee the
subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING
FINANCE AGENCY and was recorded in the aforesaid County on February 3, 2011 in Instrument No.
201104276. The Mortgage was further assigned to U.S. BANK, NATIONAL ASSOCIATION,
TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording,
which Assignment is attached hereto and marked Exhibit"B". The said Mortgage and Assignment are
incorporated herein by reference.
5. The land subject to the Mortgage is: 4316 ALLEN ROAD, CAMP HILL, PA 17011 and is more
particularly described in Exhibit "C" attached hereto.
6. The said Defendant is the real owner of the property.
7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on
February 01, 2014 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE $83,777.88
Interest at $8.73 per day $1,850.76
From 01/01/2014 To 08/01/2014
(based on contract rate of 3.7500%)
Accumulated Late Charges $41.00
Late Charges $20.56 $123.36
From 02/01/2014 to 08/01/2014
Escrow Credit ($120.81)
Attorney's Fee at 5% of Principal Balance $4,188.89
TOTAL $89,861.08
"Together with interest at the per diem rate noted above after August 01, 2014 and other charges and
costs to date of Sheriff's Sale.
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the
Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. The Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 which
contained amendments to Act 91 of 1983 (35 P.S. 1680.401c et. seg) and Pennsylvania Act 57 of 2008
which contained amendments to Act 6 of 1974 (41 P.S. 101 et. seg.) by sending to each Defendant, by
certified and regular mail, a copy of the Combined Act 6/91 Notice. A true and correct copy of the
Combined Act 6/91 Notice dated April 16, 2014 is attached hereto as Exhibit"D".
9. The Defendant has either failed to meet the time limitations as set forth under the Combined Act 6/91
Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for
Mortgage Assistance.
10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in
any way which would bring him within the Service Members Civil Relief Act, as amended. A copy of
the website report from the Department of Defense Manpower Data Center, confirming non-active
military duty is attached as Exhibit"E".
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 3.7500% ($8.73 per diem), together with other charges and
costs including escrow advances incidental thereto to the date of Sheriffs Sale and for foreclosure and sale of
the property within described. 7
By:
2
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
I.D. # 15700
Jill M. Wineka
I.D. #58802
Attorneys for Plaintiff
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
NOTE LOAN #:WZL241343
PA
MECHANICSBURG [State]
,7ANUARY 28TH, 2011 [City]
[Date]
4316 ALLEN ROAD, CAMP HILL, PA 17011
[Property Address]
1. BORROWER'S PROMISE TO PAY 88,800.00 (this amount is called"Principal"),
Lender is
In return for a loan that I have received,I promise to MEMBERS 1ST FEDERAL CREDIT UNION
plus interest,to the order of the Lender.The
I will make all payments under this Note in the form of cash,check or money order.
I understand that the Lender may transfer this Note.The Lender or anyone who takes this Note by transfer and who is entitled
to receive payments under this Note is called the"Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a year y rate
of 3.750 %.
n 2 is the rate I will pay both before and after any default described in Section 6(B)
of
The interest rate required by this Sectio
this Note.
3. PAYMENTS
(A)Time and Place of Payments a a ment every month.
I will pay principal and interest by making P y
I will make my
evf each mo
erylmon h until I have paid all of the principal and interest and any otnthbeginningon her charges described below that I
make these payments will be applied as of its scheduled due date and will be applied to interest before
may owe under this Note.Each monthly payor
Principal. If,on FEBRUARY 1sT,2041 ,I still owe amounts under this Note,Ient will pay those amounts in full on that date,
which is called the"Maturity Date."
1 will snake my monthly payments at 5000 LOUISE DRIVE, MECHANICS PA 17055he Note Holder.
or at a differentent place if required by
(B)Amount of Monthly Payments 411.25
My monthly payment will be in the amount of U.S.$
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due.A payment of Principal only is known as a
"Prepayment."When I make a Prepayment, I will tell the Note Holder in writing that I am doing so.1 may not designate a payment
as a Prepayment if I have not made all the monthly payments due under the Note. Prepayment to
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge.The Note Hold y r will use my
Prepayment to reduce the Principal amount of the
Prepayments to reduce the amount of Principal that I owe under this Note.However,the Note Holder ma a my
the accrued and unpaid interest on the Prepayment amount before applying my
Note. If I make a partial Prepayment,there will be no changes in the due date or in the amount of my monthly payment unless the
Note Holder agrees in writing to those changes.
Form 7200 vol
MULTISTATEFIXED FATENOTE•Single Family•Fannie Mae/Freddie Mac UNIFORM INSTRUMENT
VMP5NP1100a 1 017
VMP
Wolters Kluwer Finantw Services
��i
5. LOAN CHARGES
If a law,which applies to this loan and which sets maximum loan charges, is finally interpreted so that y such loan charger
loan charges collected or to be collected in connection with this loan exceed the permitted limits, sums already collected from me
shall be reduced by the amount necessary to reduce the charge to the permitted limit;and(b) y
which exceeded permitted limits will be refunded o me.The Note Holder may choose to make this refund by reducing the
me. If a refund reduces Principal,the reduction will be treated as
Principal I owe under this Note or by making a direct payment to
a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A)Late Charge for Overdue Payments the end 15 calendar days
If the Note Holder has not received the full amount of any monthly payment by
after the date it is due,I will pay a late charge to the Note Holder.The amount of the charge willll
be 5.0 00 %of
my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B)Default
If I do not pay the full amount of each monthly payment on the date it is due, [will be in default.
(C)Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount y a
certain date,the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the
interest that I owe on that amount.That date must be at least 30 days after the date on which the notice is mailed to me or delivered
by other means.
(D)No Waiver By Note Holder
Even if, at a time when I am in default,the Note Holder does not require me to pay immediately in full as described above,
the Note Holder will still have the right to do so if I am in default at a later time.
(E)Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above,the Note Holder will have the right to e
paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law.Those
expenses include,for example,reasonable attorneys' fees.
7. GIVING OF NOTICES
applicable law requires a different method,any notice that must be given to me under this Note will be given y
Unless appby first class mail to me at the Property Address above or at a different address if I give the Note
delivering it or li mailing r
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
ove or at a different address if I am given a notice of that different
mail to the Note Holder at the address stated in Section 3(A)ab
address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note,each person is fully and personally obligated surety keep all of the promises made al this
is a
on
Note,including the promise to pay the
do these things. Any person who takes oweamount d.An pers tionso including the obligaons of a guaranoror endorser of s uretyrorlso
obligate
endorser of this Note,is also obligated to keep all of the promises made in this Note.The Note Holder may enforce its rights under
this Note against each person individually or against all of us together.This means that any one of us may be required to pay all of
the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment"means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor"means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
Form 3200 1101
MULTISTATE FIXED PATE NOTE•Single Family•Fannie Mae/Freddie Mac UNIFORM INSTRUMENT
VMPS'4190602c(3 '
VMP
Wolters Kluwer Financial Services
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions.In addition to the protections given to the
Note Holder under this Note,a Mortgage, Deed of Trust, or Security Deed(the"Security Instrument"),dated the same date as this
Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note.
That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all
amounts I owe under this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is
not a natural person and a beneficial interest in Borrower is sold or transferred)without Lender's prior written
consent,Lender may require immediate payment in full of all sums secured by this Security Instrument.
However,this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option,Lender shall give Borrower notice of acceleration.The notice shall
provide a period of not less than 30 days from the date the notice is given in accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument, If Borrower fails to pay these
sums prior to the expiration of this period,Lender may invoke any remedies permitted by this Security
Instrument without further notice or demand on Borrower.
WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED.
�� c�
(Seal)
�AAn (Seal)
Borrower
WILLIAM M. WILHELM -Borrower
(Seal) (Seal)
-Borrower -Borrower
[Sign Original Only]
[] Refer to the attached Signature Addendum for additional parties and signatures.
WVTHOUT RCOURSE,PAY TO THE
PENNSYMem ers I s Feder i Capt!t Unronl�CY BY
5000 Louisa De-VO
McChanlCgburg,PA V055
C/CS/115 t CIO•CC�/�'!!
Form 3200 7101
MULTISTATE FIXED RATE NOTE-Single Family•Fannie MaelFreddie Mac UNIFORM INSTRUMENT VMP5N(100%00
VMP® Page 3 o1 3
Wolters Kluww Financial Servide
Prepared by,&Return to:
U.S.Bank National Association
c/o PHFA-Loan Servicing Division
211 North Front Street,P.O.Box 15057
Harrisburg,Pennsylvania 17105-5057
717-780-3800 or 1-800-346-3597
PIN/ID Number: 13240797092 2402790
Above space is intentionally left blank for recording data.
ASSIGNMENT OF MORTGAGE
For value received,PENNSYLVANIA HOUSING FINANCE AGENCY("PHFA"),hereby grant,sell,convey,
assign and deliver unto the U.S.BANK NATIONAL ASSOCIATION,(Trustee for the Pennsylvania Housing
Finance Agency,pursuant to a Trust Indenture dated as of April 1, 1982),its successors and assigns,the following
described Mortgage,together with the Note secured thereby
Name of Original Mortgagor(s): WILLIAM M.WILHELM
Secured by the real property located at: 4316 ALLEN ROAD,CAMP HILL,PA 17011
Municipality of: LOWER ALLEN
Original Mortgagee: MEMBERS 1 ST FEDERAL CREDIT UNION
Original Principal Amount: $88,800.00 County Recorded in: CUMBERLAND
Mortgage Recorded: February 3,2011 Instrument#: 201104275
Last Assignment to: PA Housing Finance Agency Instrument#: 201104276
IN WITNESS WHEREOF,the said Pennsylvania Housing Finance Agency,has caused this Assignment of
Mortgage to be executed by its duly authorized officer. (Series: 112) FISSEL
DATED: May 22,2014 By: PENNSYLVANIA HOUSING FINANCE AGENCY
MWS ,
Thomas F.Brzana,Jr.
Director of Loan Servicing Division
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DA %1N
On this,the Vit- y of 2014,before me,the undersigned officer,personally appeared Thomas
F.Brzana,Jr.,Director of Loan Servicing ivision,an authorized officer of the Pennsylvania Housing Finance
Agency,and acknowledged that he,being authorized to do so,executed the foregoing instrument for the purposes
therein contained.
In witness whereof,I have hereunto set my hand and official seal.
Notary Public
commoNWEN H Cif-PeNNSYLvANIA
Notarial Seal
Kimberley A.Ayala,Notary Public
CERTIFICATE OF RESIDENCE OF ASSIGNEE y c of
mHarrisburg,Dauphin County
My Commission Expires Jan.15,2015
I certify that the principal business and mailing address for this assignment and assignee is: MEMBER,PENNSYLVANIA ASSOCIA-TION of NC'rAR'ES
U.S.Bank National Association,c/o PHFA-Loan Servicing Division
211 North Front Street,P.O.Box 15057,Harrisburg,Pennsylvania 17105-5057
*"—tow /OW—a3a44:!!�t=
Authorized Officer
ALL THAT CERTAIN piece or parcel of land situate in Cumberland Park,Lower Allen Township,
Cumberland County,Pennsylvania,bounded and described as follows,to wit:
BEGINNING at a stake,said stake being on the north side of a forty(40)foot wide avenue at the division
line between Lot Nos. 17 and 18;thence by said division line,North 31 degrees 39 minutes West,one
hundred twenty(120)feet to a stake at Lot No.3;thence along Lot Nos.3 and 4,North 58 degrees 21
minutes East,sixty(60)feet to a stake on the division line of lot Nos. 16 and 17;thence along said
division line,South 31 degrees 39 minutes East,one hundred twenty(120)feet to a stake on the north
side of a forty(40)foot wide avenue;thence along said avenue,South 58 degrees 21 minutes West,
sixty(60)feet to a stake,the place of BEGINNING,
BEING Lot No. 17,Block"B",on a Plan of Lots Identified as"Plan of Park of Block"B",Cumberland Park",
surveyed for Allen Park Development Corporation,and filed in the Cumberland County Recorder of Deeds
Office on July 21,1950,and of record in Plan Book 4,Page 112.
BEING PARCEL NO. 13-24-0797-092
Date: 4/16/2014
ACT 91 NOTICE
TAKE ACTION TO
YOUR HOME FROMFORECLOSURE
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 save your home. This Notice explains how
the Program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling
Agencies serving your county are listed at the end of this Notice. If you
have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call
717-780-1869.)
This Notice contains important legal information. If you have any
questions, representatives at the Consumer Credit Counseling Agency may
be able to help explain it. You may also want to contact an attorney in your
area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACI®N 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 CURL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
,C `f 1 ACT691LR/dtmdocs/ALSV/-��h I I , t
HOMEOWNER'S NAME(S): WILLIAM M. WILHELM
PROPERTY ADDRESS: 4316 ALLEN ROAD
CAMP HILL, PA 17011-6602
LOAN ACCOUNT NO.: 2402790
CURRENT LENDER/SERVICER: Pennsylvania Housing Finance Agency
211 North Front Street
P.O. Box 15057
Harrisburg, PA 17105-5057
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
Mortgage Assistance Program Application with one of the designated Consumer Credit Counseling
ACT691 LR/dtmdocs/ALSV/
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.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING
WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE
AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE
LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST
YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS.
A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE
ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A
SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION -- Available funds for Emergency Mortgage Assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that
time, no foreclosure proceedings will be pursued against you if you have met the time requirements set
forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on
your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property
located at: 4316 ALLEN ROAD, CAMP HILL, PA 17011-6602,
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months February, 2014 thru the
first of April, 2014 in the amount of $1 ,821.00 plus late charges that have accrued in the amount of
$82.12 and other charges (inspection fees and / or attorney fees and costs in the amount of $12.00) .
THE TOTAL AMOUNT DUE IS $1,915.12. This includes all payments, fees and expenses due, less
any funds we are holding in suspense.
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 $1,915.12
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE
THIRTY (30) DAY PERIOD. Payments must be made either by cash in our office, cashier's check,
certified check or money order made payable and sent to:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 N FRONT STREET
P.O. BOX 15057
HARRISBURG, PA 17105-5057
ACT691 LR/dtmdocs/ALSV/
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
Sheriff's 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 three 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:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 NORTH FRONT STREET
P.O. BOX 15057
HARRISBURG, PA 17105-5057
1-800-822-7375
717-614-2518 (FAX)
Contact Person: KIMBERLEY AYALA
Counseling Agencies: In addition to mailing Appendix B, Notice of Face-To-Face
Meeting, please notify PHFA (when we are the first lien holder) of the face-to-face
meeting and pending submission of application for HEMAP assistance by sending
an e-mail to: Kayala@phfa.org. If you do not have access to e-mail, please call
Kim Ayala at 717-780-1815 and advise of the face-to-face meeting.
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 may 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.
(This does not apply if your mortgage was originated under the Home Start Program.)
ACT691 LR/dtmdocs/ALSV/
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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Advantage Credit Counseling Service/CCCS of Wester Housing Alliance of York/Y Housing Resources
2000 Linglestown Road 290 West Market Street
Harrisburg,PA 17102 York,PA 17401
717-855-2752
Maranatha Community Action Commission of Capital Region
43 Philadelphia Avenue 1514 Derry Street
Waynesboro,PA 17268 Harrisburg,PA 17104
717-762-3285 717-232-9757
PA Interfaith Community Programs Inc PHFA
40 E High Street 211 North Front Street
Gettysburg,PA 17325 Harrisburg, PA 17110
717-334-1518 717-780-3940
PathStone Corporation PathStone Corporation
1625 North Front St 450 Cleveland Ave
Harrisburg, PA 17102 Chambersburg,PA 17201
717-234-6616 717-264-5913
ACT691 LR/dtmdocs/ALSV/
Pennsylvania
Mousing Finance Agency Accounting & Loan Servicing
211 North Front Street, P.O. Box 15057
Harrisburg, PA 17105-5057
(800) 346-3597 FAX(717) 780-3804
TTY(717) 780-1869
NOTICE
4/16/2014
WILLIAM M. WILHELM
4316 ALLEN RD
CAMP HILL, PA 17011
RE: Account #2402790
TO: WILLIAM M. WILHELM
4316 ALLEN ROAD
CAMP HILL, PA 17011-6602
FROM: PENNSYLVANIA HOUSING FINANCE AGENCY
The Federal Housing and Development Act of 1987 (as amended) directs creditors to
notify homeowners who are delinquent in their mortgage obligation of the availability of
homeownership counseling provided by nonprofit organizations approved by the Secretary of
the Department of Housing and Urban Development ("HUD") and experienced in the
provision of homeownership counseling.
Attached is a current list of HUD-approved counseling agencies for Pennsylvania.
Attachment: Housing Counseling List
ACT691 LR/dtmdocs/ALSV/
HUD-APPROVED CREDIT COUNSELING AGENCIES
CCCS OF WESTERN PA-HARRISBURG NACA
2000 LINGLESTOWN RD, 1341 N DELAWARE AVE;SUITE 312
HARRISBURG,PA.17110 PHILADELPHIA,PA.19125
Phone:888-599-2227 Phone:888-297-5568
HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT
34 S.Duke St. ONE PENN CENTER;1617 JFK BLVD;SUITE 1550
York,PA 17401-1106 PHILADELPHIA,PA.19103-1828
Phone:800-864-4909 Phone:800-930-4663
TABOR COMMUNITY SERVICES
208 E King St.
Lancaster,PA 17608-1676
Phone:717-397-5182
ACT691 LR/dtmdocs/ALSV/
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AO-5--ra;SEP.wa 0 Certificate Offg9uM meter postage here.
This Certificate of Wailing provides evidence that mail has been presented to USPS® m
forailing.
This form may be used fondomestic and international mail. —
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From:
P.O. BOX 15057
HARMSBURG, PA 17105-5057 E>>
_ I
To: _
WILLIAM M WILHELM
a
4316 ALLEN ROADn
CAMP HILL, PA 17 011 +' s
2402790 FISSEL
PS Form 3317,April 2007 PSN 7530-02-000-9065
-------------------------------------------------------------- -- -------
2. Article NumberCOMPLETE THIS SECTION ON DELIVERY
A. Received by(Please Print Clearly) S. Date of Delivery
C. Signature.j
` 7196 9008 9111 3180 09 X I" ? �,( `t ❑Addressee
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B 5
D. Is delivery address different from item 1? LJ Yes
It YES,enter delivery address below: ❑No
3. Service Type CERTIFIED MAILTM _
4. Restricted Delivery?(Extra Fee) ❑Yes
1. Article Addressed to:
WILLIAM M WILHELM ;
4316 ALLEN ROAD
CAMP HILL, PA 17011
2402790 FISSEL
PS Form 3811,January 2005 Domestic Return Receipt
Department of Defense Manpower Data Center Results as of:Jul-30-207405:45:26 AM
SCRA 3.0
Status Report
,r Pursuant to Serviceme nbers Civil Relief Act
Last Name: WILHELM
First Name: WILLIAM
Middle Name: M
Active Duty Status As Of: Jul-30-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NCAA,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.
IA
A01 pq.
,_
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct upon my
personal knowledge and upon information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
PENNSYLVANIA HOUSING FINANCE AGENCY,
Attorney-in-Fact for U.S. BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR THE
PENNSYLVANIA HOUSING FINANCE AGENCY
Dated
By
Thomas F. Brzana, Jr., Director of Loan Servicing for
the Pennsylvania Housing Finance Agency, Attorney-in-
Fact for U.S. Bank National Association, as Trustee for the
Pennsylvania Housing Finance Agency
WILHELM
2402790
FSIl
r. -:i`F :C"
CIF i HE�Pkol Ii0t O li' Y
LC 14 JJL 3 l A?11 g; r
U.S. BANK NATIONAL ASSOCIATION AS CUMBERLAND COUNT YTRUSTEE FOR THE PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF
HOUSING FINANCE AGENCY : CUMBERLAND COUNTY,PENNSYLVANIA PENNSYLVANIA
Plaintiff(s)
VS.
WILLIAM M. WILHELM
Defendant(s) �LI Civil 7—LO(M
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a
conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal
Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative,
at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal
representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal
representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If
you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will
prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days
of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled,you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to
be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that
a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation
conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out
reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfull1.y , . dd:~
7/30/14 /
Date Leon P. Haller / Jill M. Wineka
Attorney for Plaintiff
Purcell, Krug and Haller
1719 North Front Street
Harrisburg PA 17101
PA ID 157ga / 58802
U.S. BANK NATIONAL ASSOCIATION AS
TRUSTEE FOR THE PENNSYLVANIA HOUSIftTHE COURT OF COMMON PLEAS OF
FINANCE AGENCY CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
VS.
WILLIAM M. WILHELM
Defendant(s) Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28. 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances to determine
possible options while working with your
Please provide the following information to the best of your knowledge:
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 0 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:
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/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and Expenses:
Have you been working with a Housing Counseling Agency?
Yes❑ No❑
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone(Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I/We, authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/we
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Borrower Signature Date
Please forward this document along with the following information to lender and
lender counsel:
V Proof on income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
V (hardship letter)
Listing agreement (if property is currently on the market)
V Copy of 2 years of federal income tax returns
V Copy of deed
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
RonnyRAnderson i- : LD-OFl' CE
Sheriff :IF THE THE ' PR
� E t T H O N O 'i'A V
qt rgi��ranF
Jody S Smith
Chief Deputy �� 2.01[1 AUG 19 AM i. : 19
�'"-�
Richard WStewart
CUMBERLAND COUNTY
- ~� ,a � CUMBERLAND PENNSYLVANIA
OFF1"vE. OF THE £aERIFF
Us Bank National Association
vs.
William M Wilhelm
Case Number
2014-4508
SHERIFF'S RETURN OF SERVICE
08/12/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion
Program and Complaint in Mortgage Foreclosure as "Not Served" at 4316 Allen Road, Lower Allen,
Camp Hill, PA 17011. There were no occupants other than the defendant William Wilhelm.
08/12/2014 09:06 PM - Deputy Dennis Fry, 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:
William M Wilhelm at 4316 Allen Road, Lower Allen, Camp Hill, PA 17011.
DEN S FRY, DEPU
SHERIFF COST: $54.95 SO ANSWERS,
August 14, 2014 RONNY R ANDERSON, SHERIFF
�c) CountySuite Sheriff, Teleosuft, Inc_
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
WILLIAM M. WILHELM,
DEFENDANT(S) MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s)
WILLIAM M. WILHELM for failure to plead to the above action within twenty (20) days from date
of service of the Complaint, and assess Plaintiff's damages as follows:
Unpaid Principal Balance
Interest
Per diem of $8.73
From 01/01/2014
To 08/01/2014
Accumulated Late Charges
Late Charges
($20.56 per month to
08/01/2014)
Escrow Credit
5% Attorney's Commission
TOTAL
$83,777.88
$1,850.76
$41.00
$123.36
-$120.81
$4,188.89
$89,861.08
**Together with additional interest at the per diem rate indicated above from the date herein, based on
the contract rate, and other charges and costs to the date of Sheriff's Sale.
PURCELL, KRUG & HA
Ley . Haller PA I.D. # 15700
19 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ao- s)ip.opc1
iciqd-`1‘0
3j3/a�ed
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
Vs.
WILLIAM M. WILHELM,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on September 16, 2014 I served the Ten Day Notice required by Pa. R.C.P.
on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the
attached Notice.
By
Leon mss' ler PA I.D. # 15700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
C11
t
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA
HOUSING FINANCE AGENCY,
Plaintiff
VS.
WILLIAM M. WILHELM
Defendant
DATE OF THIS NOTICE: September 16, 2014
TO:
WILLIAM M. WILHELM
4316 ALLEN ROAD
CAMP HILL, PA 17011
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 14-04508 CIVIL
CIVIL ACTION LAW
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
. 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PURCELL,
& HALLER
By
LEON P. HAL ' , Attorney for Plaintiff
I.D. # 15700
1719 N. Front St., Harrisburg,PA. 17102
(717) 234-4178
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
WILLIAM M. WILHELM,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
IN MORTGAGE FORECLOSURE
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN -
I, LEON P. HALLER, Attorney for the Plaintiff in the above matter, being duly
s- Torn according to.law,-.hereby certify that the Plaintiff has complied with the -procedures
required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and Defendants have either failed to meet the time
limitations as set forth therein or have been determined by the Housing Finance Agency
not to qualify for assistance.
Sworn to and subscribed
be ore me this
day :
CC 4 errtm ' _L. u_A,.
, NNSYLVAN
NOTARIAL SEAL"_.._. _
roARYLAND 6f. P EREr .'1't, Notary Public
Lawor Paxton TO., D .uphdn County
My CommfssIon ExpIreo August 08, 2018
LEON P. i• LER, ESQUIRE
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
WILLIAM M. WILHELM,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
c- r
Personally appeared before me, a Notary Public in and for said Commonwealth and County,
LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the
Defendants above named are not on active duty in the Military Service nor engaged in any way which
would bring them within the Servicemembers' Civil Relief Act. A copy of the search through the
Defense Manpower Data Center website is attached.
Sworn to and subscribed
before me this
f
day
20J/ .
Nota
y
P. is
ir . NOTAFtA SEAL
MARYLAND K FERREITI, Notary AAA°
Loci; r Pa::twi T'xp., Dauphin ,E't. :int1r
My Corn .!c ,ion Expires Augur
m... `�_. (, a3, 2018
LEO P. HALLER, ESQUIRE
Department of Defense Manpower Data Center
Status Report
Pursuant to Servicer es abers Civil Relief Act
Last Name: WILHELM
First Name: WILLIAM
Middle Name: M
Active Duty Status As Of: Nov -20-2014
Results as of : Nov -20-2014 09:13:24 AM
SCRA 3.0
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA -
No
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
( Status
Service Component
NA
NA - -
- No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
. NA
- - , : No'. -
NA
This response reflects whether the individual or his/her unit has received early,notificatlon to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DOD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DOD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html, If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: WFOB159C1049N70
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO. 2014-04508
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
'VVILLIAM. M. WILHELM,
DEFENDANT(S)
Total Judgment Amount $89,861.08
Interest $1,849,01
Per diem of $8.73 to sale
date 3/4/2015
Late Charges $143.92
$20.56 per month to sale
date 3/4/2015
Escrow Deficit $1,891.82
TOTAL WRIT $93,745.83
*Plus additional interest, late charges and other costs
to date of sheriffs sale.
SALE DATE: Wednesday, March 04, 2015
(PROTHONOTARY'S USE)
Pltf. Paid
Deft. Paid
Due Proth/Clerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSUR
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue Writ of Execution in the above captioned case.
Date: November 20, 2014
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
WRIT OF E
Leon P. Haller
PA I.D. #15700
CUTION - MORTGAGE FORECLOS
COMMONWEALTH OF PENNSYLVAN
COUNTY OF CUMBERLAND
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the a
sell the property described in the attached description kno
Date:
SS
oned case, you are directed to levy upon and
6 ALLEN ROAD CAMP HILL, PA 17011
PROT ' TARY/CLERK CIVIL DIVISION
BY
EPUTY
tDaS
*--31.0Y7
&-S
sd
ALL THAT CERTAIN piece or parcel of land situate in Cumberland Park, Lower Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows, to wit;
BEGINNING at a stake being on the north side of a forty (400 foot wide avenue at the division line
between Lots Nos. 17 and 18; thence by said division line, North 31 degrees 39 minutes West, one
hundred twenty (120) feet to a stake at Lot No. 3; thence along Lots Nos. 3 and 4, North 58 degrees 21
minutes East, sixty (60) feet to a stake on the division line of Lots Nos. 16 and 17; thence along said
division line, South 31 degrees 39 minutes East, one hundred twenty (120) feet to a stake on the north
side of a forty (40) foot wide avenue; thence along said avenue, South 58 degrees 21 minutes West, sixty
(60) feet to a stake, the place of BEGINNING.
BEING Lot No. 17, Block "B", on a Plan of Lots identified as "Plan of Park of Block "B", Cumberland
Park", surveyed for Allen Park Development Corporation, and file in the Cumberland County Recorder
of Deeds Office on July 21, 1950, and of record in Plan Book 4, Page 112.
HAVING THEREON ERECTED A DWELLING KNOWN AS 4316 ALLEN ROAD, CAMP HILL,
PA 17011
PARCEL NO. 13-24-0797-092.
THIS conveyance'is under and subject to building restrictions, restrictions upon use and easements, as
set forth at length of the Deed of Allen Park Development Corporation to Mark T. Garber, dated
October 10, 1950, and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
"N", Volume 14, Page 263.
BEING the same premises which Samuel R. Theal, Administrator of the Estate of Stephen R. Theal, by
Deed dated January 28, 2011 and recorded in the Recorder of Deeds Office in and for Cumberland
County, Pennsylvania, at Instrument No. 201104274, granted and conveyed unto William M. Wilhelm.
TO BE SOLD AS THE PROPERTY OF WILLIAM M. WILHELM ON JUDGMENT NO. 2014-04508
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
WILLIAM M. WILHELM,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets fort1 as (11.the..d%e
the praecipe for the writ of execution was filed, the following information concerning the -;real property -
located at 4316 ALLEN ROAD CAMP HILL, PA 17011: } ; i ` = , , A,
1.
Name and address of the Owner(s) or Reputed Owner(s):
WILLIAM M. WILHELM
4316 ALLEN ROAD
CAMP HILL, PA 17011
2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1)
above: SAME
3. Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
4. Name and address of last recorded holder of every mortgage of record:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale: UNKNOWN
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
4316 ALLEN ROAD
CAMP HILL, PA 17011
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated.)
I verify that the statements made in this Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to autho •
DATE:November 20, 2014
. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY,
PLAINTIFF
VS.
WILLIAM M. WILHELM,
DEFENDANT(S)
TAKE NOTICE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 2014-04508
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, March 04, 2015
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property, together with a brief mention of the buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
4316 ALLEN ROAD
CAMP HILL, PA 17011
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 2014-04508 JUDGMENT AMOUNT $89,861.08
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
WILLIAM M. WILHELM
1
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of
the proceeds of sale in accordance with this schedulewill, in fact, be made unless someone objects by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of
Common Pleas of the within County at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY
THE JUDGMENT
You may have legal rights to prevent your property from being taken away. A lawyer can advise
you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN piece or parcel of land situate in Cumberland Park, Lower Allen Township,
Cumberland County, Pennsylvania, bounded and described as follows, to wit;
BEGINNING at a stake being on the north side of a forty (400 foot wide avenue at the division line
between Lots Nos. 17 and 18; thence by said division line, North 31 degrees 39 minutes West, one
hundred twenty (120) feet to a stake at Lot No. 3; thence along Lots Nos. 3 and 4, North 58 degrees 21
minutes East, sixty (60) feet to a stake on the division line of Lots Nos. 16 and 17; thence along said
division line, South 31 degrees 39 minutes East, one hundred twenty (120) feet to a stake on the north
side of a forty (40) foot wide avenue; thence along said avenue, South 58 degrees 21 minutes West, sixty
(60) feet to a stake, the place of BEGINNING.
BEING Lot No. 17, Block "B", on a Plan of Lots identified as "Plan of Park of Block "B", Cumberland
Park", surveyed for Allen Park Development Corporation, and file in the Cumberland County Recorder
of Deeds Office on July 21, 1950, and of record in Plan Book 4, Page 112.
HAVING THEREON ERECTED A DWELLING KNOWN AS 4316 ALLEN ROAD, CAMP HILL,
PA 17011
PARCEL NO. 13-24-0797-092.
THIS conveyance is under and subject to building restrictions, restrictions upon use and easements, as
set forth at length of the Deed of Allen Park Development Corporation to Mark T. Garber, dated
October 10, 1950, and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
"N", Volume 14, Page 263.
BEING the same premises which Samuel R. Theal, Administrator of the Estate of Stephen R. Theal, by
Deed dated January 28, 2011 and recorded in the Recorder of Deeds Office in and for Cumberland
County, Pennsylvania, at Instrument No. 201104274, granted and conveyed unto William M. Wilhelm.
TO BE SOLD AS THE PROPERTY OF WILLIAM M. WILHELM ON JUDGMENT NO. 2014-04508
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE PENNSYLVANIA HOUSING
FINANCE AGENCY
Vs. NO 14-4508 Civil Term
CIVIL ACTION — LAW
WILLIAM M. WILHELM
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: $89,861.08 L.L.: $.50
Interest PER DIEM OF $8.73 TO SALE DATE 3/4/2015 - $1,849.01.
Atty's Comm:
Atty Paid: $213.70
MONTH TO SALE DATE 3/4/2015 - $143.92
ESCROW DEFICIT - $1,891.82
Plaintiff Paid:
Date: 11/25/14
Due Prothy: $2.25
Other Costs: LATE CHARGES - $20.56 PER
David D.
ell, Prothonot
(Seal) By:
Deputy
REQUESTING PARTY:
Name: LEON P. HALLER, ESQUIRE
Address: PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102
Attorney for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ID No. 15700