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HomeMy WebLinkAbout14-5704 Supreme Coiut:of Pennsylvania Court ofC—omm-nTleas For Prothonotary Use Only:-- Clv><l Cover,Sheet - Docket No: OUI,MERL,M The information collected on this formm is used solely for court administration purposes. This form does not supplement or replace the f ling and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S l Complaint El Writ of Summons 0 Petition E Transfer from Another Jurisdiction E] Declaration of Taking Lead Plaintiff's Name: U.S. BANK NATIONAL Lead Defendant's Name: C ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA Christopher J. Crowley T Dollar Amount Requested: El within arbitration limits I Are money damages requested? O Yes No (check one) El outside arbitration limits O N Is this a Class Action Suit? E]Yes El No Is this an MDJAppeal? El Yes El No A Name of Plaintiff/Appellant's Attorney: Leon P. Haller, Esquire/Jill Wineka, Esquire 0 Check ljere>z'you.liiz.e no at'vorney(are a Serf-lel rese xt d [Pro Sel Lit yant) 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 El Intentional El Buyer Plaintiff Administrative Agencies El Malicious Prosecution El Debt Collection: Credit Card Q Board of Assessment 0 Motor Vehicle Debt Collection: Other El Board of Elections M Nuisance 0 Dept. of Transportation 0 Premises Liability El Statutory Appeal: Other S 0 Product Liability(does not include E mass tort) El Employment Dispute: El Slander/Libel/Defamation Discrimination 0 Employment Dis ute: Other C El Other: p Zoning Board T El Other: I [] Other: o. MASS TORT Asbestos N 0 Tobacco 0 Toxic Tort-DES _ Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Other: El Ejectment El Common Law/Statutory Arbitration B Q Eminent Domain/Condemnation E] Declaratory Judgment El Ground Rent [:] Mandamus El Landlord/Tenant Dispute E]Non-Domestic Relations El Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial Quo Wairanto 0 Dental 0 Partition 0 Replevin M Legal 0 Quiet Title El Other: F1 Medical 0 Other: E] Other Professional: Updated 1/1/2011 Ti Leon P. Haller Esquire 2LIA$Cyt Purcell,Krug&Haller 1719 North Front Street cu'fEE F;[ F t !D Cit Harrisburg,PA 17102 YL�>�.;�,A 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 OF MORTGAGE FORECLOSURE CHRISTOPHER J. CROWLEY, '1 S 7o y to! Defendant 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. . CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Gl fx J �.7 S CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET lei CARLISLE,PA 17013 C {# IPSO I 717-249-3166 `3 t I -5 y 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 CHRISTOPHER J. CROWLEY, 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 CHRISTOPHER J. CROWLEY, 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 0431. The Limited Power of Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 2. Defendant, CHRISTOPHER J. CROWLEY, is an adult individual whose last known address is 918 NIXON DRIVE, MECHANICSBURG, PA 17055. 3: On or about, December 28, 2010, the said Defendant executed and delivered a Mortgage Note in the sum of$153,225.00 payable to FULTON BANK, N.A., 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 December 30, 2010 in Instrument No. 201038787 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 December 30, 2010 in Instrument No. 201038788. 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: 918 NIXON DRIVE, MECHANICSBURG, PA 17055 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 January 01, 2014 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $146,302.33 Interest at $20.32 per day $6,177.28 From 12/01/2013 To 10/01/2014 (based on contract rate of 5.0000%) Accumulated Late Charges $24.80 Late Charges $32.90 $296.10 From 01/0 1/2014k to 10/01/2014 Escrow Deficit $239.47 Attorney's Fee at 5% of Principal Balance $7,315.12 TOTAL $160,115.63 "Together with interest at the per diem rate noted above after October 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. sea.) and Pennsylvania Act 57 of 2008 which contained amendments to Act 6 of 1974 (41 P.S. 101'et. sec.) 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 March 13, 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 5.0000% ($20.32 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. By: 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) ��-C/30 = � a� App# 5701122910. Min# NOTICE: THIS LOAN IS NOTO ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. December 28, 2010 HARRISBURG PENNSYLVANIA [Date] [City] [State] 918 NIXON DRIVE MECHANICSBURG, PA 17055 [Property Address] 1, BORROWER'S PROMISE TO PAY In return for a loan that I have received,1 promise to pay U.S. S 153,225.00 (this amount is called"Principal"), plus interest,to the order of the Lender.The Lender is FULTON BANK, N.A. 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 x Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.000%. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PATENTS (A)Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the is t day of each month beginning on February 01, 2011 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may,owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal.if,on January O1, 2041 1 still owe amounts under this Note,I will pay those amounts in full on that date,which is called the"Maturity Date." I will make my monthly payments at ONE PENN SQUARE, LANCASTER, PA 17602 or at a different place if required by the Note Holder. (B)Amount of Monthly Payments My monthly payment will be in the amount of U.S.S 822.54 4. BORROWER'S RIGHT TO PREPAY The Borrower shall have the right to prepay at any time, without,premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or$100.00, whichever is less. Any Prepayment in full of the indebtedness shall be credited on the date received,and no interest may be charged thereafter.Any partial Prepayment made on other than an installment due date need not be credited until the next following installment due date or 30 days after such Prepayment, whichever is earlier. 5701122910 5701122910 MULTISTATE FIXED RATE NOTE-Single Family-Fannie MaelFreddle Mac UNIFORM INSTRUMENT-Veterans Affairs Form 3200 1101 Amended 6100 Wolters Kluwer Financial Services VMPr'-50 toeorl Page 1 of 3 Initials: t �rolPY ><- i bi A 5. LOAN CHARGES °If a law,which applies to this loan and which sets maximum loan charges,is finally interpreted so that the interest-or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then:(a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and(b)any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me.If a refund reduces Principal,the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A)Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of Fifteen calendar days after the date it is due,I will pay a late charge to the Note Holder.The amount of the charge will be 4.000%of my overdue payment.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,I 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 by 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[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 be 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 Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note 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 mail to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note,including the promise to pay the full amount owed.Any person who is a guarantor,surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor,surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. 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. 5701122910 5701122910 MULTISTATE FIXED RATE NOTE-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT-Veterans Affairs VM0°4G IDaorl Form 32 , //e1 Page 2 0l 3 l� Initialc: 10. ALLONGE TO THIS NOTE If an allonge providing for payment adjustments or for any other•supplemehial information is executed by the Borrower together with this Note,the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑Graduated Payment Allonge ❑Other[Specify] ❑Other[Specify] 11. 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 1 owe under this Note. Some of chose conditions are described as follows: Regulations(38 C.F.R. Part 36)issued under the Department of Veterans Affairs("VA")Guaranteed Loan Authority(38 U.S.C. Chapter 37)and in effect on the date of loan closing shall govern the rights, duties and liabilities of the parties to this loan and any provisions of this Note which are inconsistent with such regulations are hereby amended and supplemented to conform thereto. WTI?vESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED. L-VU (Seal) (Seal) CHRIS OPHER J. CROWLEY -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower Paytothoorderof Qi WNS� I-ijUSiNG FINANCEAGENGY WithoLq coul`F Fulton Ban PJ. ' � [Sign Original Only] By: ——... } Nim R4419ON Tede: FFICER 5701122910 5701122910 MULTISTATE FIXED RATE NOTE-Single Family-Fannie Mae/Freddie Mae UNIFORM INSTRUMENT•Veterans Affairs Form 3200 1/01 V M P$-S G(0807) Page 3 of 3 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: 22240783004 2391266 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): CHRISTOPHER J.CROWLEY Secured by the real property located at: 918 NIXON DRIVE,MECHANICSBURG,PA 17055 Municipality of: TOWNSHIP OF MONROE Original Mortgagee: FULTON BANK Original Principal Amount: $153,225.00 County Recorded in: CUMBERLAND Mortgage Recorded: December 30,2010 Instrument#: 201038787 Last Assignment to: PA Housing Finance Agency Instrument#: 201038788 IN WITNESS WHEREOF,the said Pennsylvania Housing Finance Agency,has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 930) GUTSHALE DATED: July 11,2014 By: PENNSYLVANIA HOUSING FINANCE AGENCY Thomas F.Brzana,Jr. Director of Loan Servicing Division COMMONWEALTH OF PENNSYLVANIA COUNTY O,F DAUPHIN On this,the I�- day of 2014,before me,the undersigned officer,personally appeared Thomas F.Brzana,Jr.,Director of Loan ervicin Division,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. V L2 Q /A6tU Notary Public COfNMOIrl�N 1) 6�PENN LVANIA Notarial seat Kimberley A.Ayala,Notary Public City of Harrisburg,DauPhin County CERTIFICATE OF RESIDENCE OF ASSIGNEE My commission Expires San.15,2015 E I certify that the principal business and mailing address for this assignment and assignee isoMBER,PENNS'ILVANIA A550rS4'i7gN OF NOTARIES U.S.Bank National Association,c/o PHFA-Loan Servicing Division 211 North Front Street,P.O.Box 15057,Harrisburg,Pennsylvania 17105-5057 ok" Authorized Officer EX-NUt a ALL THAT CERTAIN lot of ground situate in the Township of Monroe,County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at a pipe on the line dividing lands of the Grantors herein and lands now or formerly of Harry C.Musser,which said pipe is South eight(8)degrees thirty(30)minutes East three hundred fifty-seven(357)feet from a point in the center line of the Trindle Road,which said last mentioned point is five hundred ninety-five(595)feet measured westwardly along the center line of the Trindle Road from the property now or formerly of R.C.Myers;thence along lands now or formerly of Charles Hoffman South eight(8)degrees thirty(30)minutes East one hundred fifty-four(154)feet to a pipe on the northern line of said fifty(50)foot wide right-of-way;thence along the northern line of said fifty(50) foot wide right-of-way South seventy(70)degrees thirty(30)minutes West eighty-five(85) feet to a pipe at corner of lands now or formerly of M.K. Cover; thence along said last mentioned lands North eight(8) degrees thirty(30)minutes West one hundred fifty-four(154)feet to a pipe;thence along other lands of the Grantor herein,of which the tract herein conveyed was a part,North seventy(70)degrees thirty(30) minutes East eighty-five(85)feet to a pipe at the point and place of BEGINNING. BEING known as Parcel#22-24-0783-004 BEING the same premises which Marlene S. Schlusser,a married Woman, and Connie L.Bishop,a married woman by Indenture dated 08/16/2007, and recorded in the Office for the Recording of Deeds, in and for the County of Cumberland,aforesaid, in Deed Book and Page 200734025, granted and conveyed unto Richard Harrison and Margaret Harrison, husband and wife,in fee. C- Date: 3/13/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. E ' ' ID ACT691 LR/dtmdocs/ALSW X�'1 HOMEOWNER'S NAME(S): CHRISTOPHER J. CROWLEY PROPERTY ADDRESS: 918 NIXON DRIVE MECHANICSBURG, PA 17055-4046 LOAN ACCOUNT NO.: 2391266 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..M.UST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. , _41 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: 918 NIXON DRIVE, MECHANICSBURG, PA 17055-4046, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months January, 2014 thru the first of March, 2014 in the amount of $3,030.00 plus late charges that have accrued in the amount of $90.60 and other charges (inspection fees and / or attorney fees and costs in the amount of $24.00) . THE TOTAL AMOUNT DUE IS $3,120.60. 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 $3,120.60 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 acceleratethe 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 writinq 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/ALSW `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 PAYOFF 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/ALSW Pennsylvania - Housing 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 3/13/2014 CHRISTOPHER J. CROWLEY 918 NIXON DR MECHANICSBURG, PA 17055 RE: Account #2391266 TO: CHRISTOPHER J. CROWLEY 918 NIXON DRIVE MECHANICSBURG, PA 17055-4046 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 Plione:888-297-5568 HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT 34 S.Duke St. ONE PENN CENTER;1617 JFK BLVD;SUITE 1-550 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 t i t I r i ACT691 LR/dtmdocs/ALSW .....................................:. 2. Article Number oil, • • A Received by(Please Print Clearly) 8. Date of Delivery z i 4i- C. _C. Signature X 1�+J ED Agent 7196 9008 9111 1452 6266 �% �'` ED Addressee D. Is delivery addr s different from item 1? ❑les If YES,enter delivery address below: 0 No 3. Service Type CERTIFIED MAILTM 4. Restricted Delivery?(Extra Fee) QYes i 1. Article Addressed to: i CHRISTOPHER J CROWLEY""-.. 918 NIXON DRIVE MECHANI CSBURG, PA 176 2391266 CONDE PS Form 3811,January 2005 Domestic Return Receipt 7196 9008 9111 1452 6266 M: CHRISTOPHER J CROWLEY li 918 NIXON DRIVE MECHANICSBUR G P A 1 70 5 5 - SENDER: % • E �,., :o C= t :2 t,� CONDE o �f REFERENCE: 239116; 0. o n� � .O � k.�v 4 'E+:�.. �✓°j �l: ��' S1a tF.s•c� 4.e:( m � PS Fo#A 3800 Janua 2005 RETURN Postage CL 9 to ( RECEIPT E2.1— E co Certified Fee S, In o 1 SERVICE w p rn Return Receipt Fee L E o Restricted Delivery j 6' o ® W o Total Postae&Fees g i �` � waPz o C") j USP,M POSTMARK OR DATE82 LO f ® `.- It) H " " Receipt for m U x z o Certified Mail I , Q.L O >4 H kD N i No Insurance Coverage Provided 8� �� E-i H to Do Not Use for International Mal x go W y - X 00 2 � @� � 03 c ; �� Byg y N E Gt�tl ® O i I V Print Key Output Page 1 5770SS1 V7R1M0 100423 PHFASYSI 03/10/14 12:10:45 ,S Display Device . . . . . QPADEV01CP ;:3i User . . . . . . . . . . CONDE SRV860-02 =a======a= ====a=====__=====a=====_________________= 3/10/14 CONDE PERSONAL K PROPERTY DATA 12:10:44 Loan# 0002391266= =Inv*=930 a= Asum: Y Total Due ==x3120.60 Due 1/01/14 CP: CONDE Msg#l: 36 2: 3: UnPaidBal 146302.33 LPR 1/31/14 Borr 1: CHRISTOPHER J CROWLEY 717-798-2793 Empl: VERIZON Sal: 0 717-766-4181 Email: cjcrowley@verizon.net On-Line Reg: Y/N Borr 2: 000-00-0000 Empl: Sal: 0 Email: On-Line Reg: Y/N Prop: 918 NIXON DRIVE Number of Children: 00 Addr• Ages: 00 00 00 �.,-MECHANICSBURG PA 170554046 Seller: Maili -918 NIXON DR Addr:' -MECHANICSBURG PA 170554046 Legal Description: F3-Exit F6=Additional Names and Addresses F7=Next Loan Page Dn=Loan Data FB=Prey Loan F12-Return F16-Opt Out Info ACT Letter NAR I r DepaAment"of Defense Manpower Data Center Results as of:Sep-18-2014 11:02:39 AM SCRA 3.0 rf�°qf '4x "t�t�. Report Yrti P1rsu8fltrnaemCivil Relief Act Last Name: CROWLEY First Name: CHRISTOPHER Middle Name: J. Active Duty Status As Of: Sep-18-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale 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 Noted of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army, Navy, Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. JON Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 L,xhi �� 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 CROWLEY 2391266 U.S. BANK NATIONAL ASSOCIATION AS : IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA HOUSING : CUMBERLAND COUNTY,PENNSYLVANIA c c _711 . FINANCE AGENCY, Plaintiff(s) _T)c'3 Mr.3 C'o VS. Gr r' r!J 77 CHRISTOPHER J. CROWLEY, `D- Defendant(s) civil ` � I") 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. Respectfully su ed: Date Leon P. Haller / Jill . ineka Attorney.. for Plaintiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 PA ID 1570b / 58802 U.S. BANK NATIONAL ASSOCIATION AS IN THE COURT OF COMMON PLEAS OF TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff(s) VS. CHRISTOPHER J. CROWLEY, 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: CUSTOMEMPRIMARY 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? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy?Yes❑ No❑ If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ 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/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No❑ ` If yes, please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �P i l O ,GCT -I 9PM 2.37 1 I ✓UDC \L/-\hU vt;JNTY PENNSYLVANIA U.S. Bank National Assocation as Trustee for the Pennsylvania Housing vs. Christopher Crowley Case Number 2014-5704 SHERIFF'S RETURN OF SERVICE 09/29/2014 Deputy Christopher Sharpe, 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: Christopher Crowley at 918 Nixon Drive, Monroe Township, Mechanicsburg, PA 17055. 09/30/2014 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 918 Nixon Drive, Monroe Township, Mechanicsburg, PA 17055. There were no Occupants other than the defendant Christopher Crowley. SHERIFF COST: $55.30 SO ANSWERS, September 30, 2014 (c) CountySuito Sherif,, feieOSoft, inc. RONN R ANDERSON, SHERIFF s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 14-5704 CIVIL U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHRISTOPHER J. CROWLEY, DEFENDANT(S) Total Judgment Amount $160,115.63 Interest $3,046.74 Per diem of $20.32 to sale date 3/4/2015 Late Charges $164.50 $32.90 per month to sale date 3/4/2015 Escrow Deficit $2,635.22 TOTAL WRIT $165,962.09 *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 FORECLOSURE 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 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FOREC COMMONWEALTH OF PENN COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUN To satisfy the judgment, interest and costs in the abov sell the property described in the attached description known as 17055 Date: 99-S6 S .36 eg F 'l57SIIIt d C) ry cn r,.) w - 71 VT1- -r, --,t- (773 c ca rrl ioned case, you are directed to levy upoAnd DRPO MILPI ROTHONOTARY/CLE BY EPU77 �2, 95 �k.a <,.SQ C.l jp. 199a7-1 f _/ CIVIL DIVISION ALL THAT CERTAIN lot of ground situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a pipe on the line dividing lands of the Grantors herein and lands now or formerly of Harry C. Musser, which said pipe is South 8 degrees 30 minutes East three hundred fifty seven (357) feet from a point in the center line of the Trindle Road, which said last mentioned point is five hundred ninety five (595) feet measured westwardly along the center line of the Trindle Road from the property now or formerly of R. C. Myers; thence along lands now or formerly of Charles Hoffman South 8 degrees 30 minutes East one hundred fifty four (154) feet to a pipe on the northern line of said fifty (50) foot wide right of way; thence along the northern line of said fifty (50) foot wide right of way, South 70 degrees 30 minutes West eighty five (85) feet to a pipe at corner of lands now or formerly of M. K. Cover; thence along said last mentioned lands North 8 degrees 30 minutes West one hundred fifty four (154) feet to a pipe; thence along other lands of the Grantor herein, of which the tract herein conveyed was a part, North 70 degrees 30 minutes East eighty five (85) feet to a pipe at the point and place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 918 NIXON DRIVE, MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-004 BEING THE SAME PREMISES WHICH Richard Harrison and Margaret Harrison, husband and wife, by deed dated 12/28/2010 and recorded 12/30/2010 in Cumberland County Instrument No. 2010-38786, granted and conveyed unto Christopher J. Crowley. TO BE SOLD AS THE PROPERTY OF CHRISTOPHER J. CROWLEY ON JUDGMENT NO. 14-5704 CIVIL U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHRISTOPHER J. CROWLEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 918 NIXON DRIVE MECHANICSBURG, PA 17055: c-) t"n r - CD a N 1. Name and address of the Owner(s) or Reputed Owner(s): CHRISTOPHER J. CROWLEY 918 NIXON DRIVE MECHANICSBURG, PA 17055 CHRISTOPHER J. CROWLEY 244 SILVER SPRING ROAD MECHANICSBURG, PA 17055 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: Monroe Township Municipal Authority 1220 Boiling Springs Road Mechanicsburg, PA 17055-9794 Michael J. Pykosh, Esquire Dethlefs Pykosh Law Group LLC 2132 Market Street Camp Hill, PA 17011 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 918 NIXON DRIVE MECHANICSBURG, PA 17055 (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 • 'cs. DATE:November 20, 2014 on P. 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. CHRISTOPHER J. CROWLEY, DEFENDANT(S) TAKE NOTICE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA. CIVIL ACTION LAW NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: C—) e„„, — czzt —rr DATE: 0 r-7.7 C:3 C) `© > • • 74 , "-; 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) Wednesday, March 04, 2015 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE LOCATION of your property to be sold is: 918 NIXON DRIVE MECHANICSBURG, PA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 14-5704 CIVIL JUDGMENT AMOUNT $160,115.63 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: CHRISTOPHER J. CROWLEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot of ground situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a pipe on the line dividing lands of the Grantors herein and lands now or formerly of Harry C. Musser, which said pipe is South 8 degrees 30 minutes East three hundred fifty seven (357) feet from a point in the center line of the Trindle Road, which said last mentioned point is five hundred ninety five (595) feet measured westwardly along the center line of the Trindle Road from the property now or formerly of R. C. Myers; thence along lands now or formerly of Charles Hoffman South 8 degrees 30 minutes East one hundred fifty four (154) feet to a pipe on the northern line of said fifty (50) foot wide right of way; thence along the northern line of said fifty (50) foot wide right of way, South 70 degrees 30 minutes West eighty five (85) feet to a pipe at corner of lands now or formerly of M. K. Cover; thence along said last mentioned lands North 8 degrees 30 minutes West one hundred fifty four (154) feet to a pipe; thence along other lands of the Grantor herein, of which the tract herein conveyed was a part, North 70 degrees 30 minutes East eighty five (85) feet to a pipe at the point and place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 918 NIXON DRIVE, MECHANICSBURG, PA 17055 TAX PARCEL NO. 22-24-0783-004 BEING THE SAME PREMISES WHICH Richard Harrison and Margaret Harrison, husband and wife, by deed dated 12/28/2010 and recorded 12/30/2010 in Cumberland County Instrument No. 2010-38786, granted and conveyed unto Christopher J. Crowley. TO BE SOLD AS THE PROPERTY OF CHRISTOPHER J. CROWLEY ON JUDGMENT NO. 14-5704 CIVIL 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 14-5704 Civil Term CIVIL ACTION — LAW CHRISTOPHER J. CROWLEY 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: (l) 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: $160,115.63 L.L.: $.50 Interest PER DIEM OF $20.32 TO SALE DATE 3/4/2015 - $3,046.74 Atty's Comm: Atty Paid: $216.05 MONTH TO SALE DATE 3/4/2015 - $164.50 ESCROW DEFICIT - $2,635.22 Plaintiff Paid: Date: 11/25/14 (Seal) 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 Due Prothy: $2.25 Other Costs: LATE CHARGES - $32.90 PER David D. Buell, 'rothonotary . By: Deputy U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL ACTION LAW VS. NO. 14-5704 CIVIL CHRISTOPHER J. CROWLEY, DEFENDANT(S) MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: y C-j-� C) C) w=• c s• n •• • Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) CHRISTOPHER J. CROWLEY 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 $146,302.33 Interest $6,177.28 Per diem of $20.32 From 12/01/2013 To 10/01/2014 Accumulated Late Charges $24.80 Late Charges $296.10 ($32.90 per month to 10/01/2014) 5% Attorney's Commission TOTAL $7,315.12 $160,115.63 **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 & HALL By Leo/ aller PA I.D. # 15700 1 19 North Front Street Harrisburg, PA 17102 (717) 234-4178 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF Vs. CHRISTOPHER J. CROWLEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on November 10, 2014 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leo Haller PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff VS. CHRISTOPHER J. CROWLEY Defendant DATE OF THIS NOTICE: November 10, 2014 TO: CHRISTOPHER J. CROWLEY 918 NIXON DRIVE MECHANICSBURG, PA 17055 CHRISTOPHER J. CROWLEY 244 SILVER SPRING ROAD MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 14-5704 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, KRUG & By LEON P. HALLER, Attorney for Plainti f 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. CHRISTOPHER J. CROWLEY, - DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS - --n COUNTY OF DAUPHIN I, LEON P. HALLER, Attorney for the Plaintiff in the above matter, being duly sworn according to law, hereby certify that the Plaintiff has complied with the procedures .required by Pennsylvania Act 91 of.1983 (Homeowners' Emergency Mortgage 7-. 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 before me this day . of �I oV ZOJ otary COMMONWEALTH OF Pc 'NSYLVa l RTOTARIALSEAL MARYLAND it FERRET117. Nosy Public Lower Paxton Twp., Dauphin County My Commission Expires August 00, 2018 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHRISTOPHER J. CROWLEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN c,a 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 b ore me this40 day of 20 jy : �..,i/f, �. Not. yi: ublic / A' COMMONWEAL Tib O i NNSYLVAN1A NOTARIAL SEAL MARYLAND It. RERRE1TI. No ay Public Laver Paxton Tap., Dauphin County My Commission E.pins August 08, 2018 LEG P. HALLER, ESQUIRE Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: CROWLEY First Name: CHRISTOPHER Middle Name: J Active Duty Status As Of: Nov -20-2014 Results as of : Nov -20-2014 10:14:07 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 notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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: OF6B36FCQOCD2F0 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. CHRISTOPHER J. CROWLEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW . NO. 14-5704 CIVIL IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on against you in the above -captioned matter: ( 133)) 2-/ the following judgment has been entered $160,115.63 and for the sale and foreclosure of your property located at: 918 NIXON Dt VE MECHANICSBURG, PA 17055 Dated: November 20, 2014 Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 PROTHONOTARY I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236 CHRISTOPHER J. CROWLEY 918 NIXON DRIVE MECHANICSBURG, PA 17055 CHRISTOPHER J. CROWLEY 244 SILVER SPRING ROAD MECHANICSBURG, PA 17055