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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/ W Q O O O Ln c—I Y Y Ir a C) C3 � r- ca a0H o ° M H d d a Z w a N ii d m 0+ W a 0 o a)a a s � �- 'cc o a Cf N LL ¢ - 0 y 0 A o c(3d x H c° o �°—' c a *� c a. "am ID ® a Er a a', Z o a U F° •4) L)o Co .D H M a W � Ce) rw uj 0 � W � a-i d' ulI Z o �w> �i S j O W W LL rv� I- N N a Li zo To pay fee;affx stamps or 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. — ` L` 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 0 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