HomeMy WebLinkAbout07-6754- UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Franklin Credit Management :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
101 Hudson Street =Cumberland County
Jersey City, NJ 07302
Plaintiff
V.
Robert W. Kohut
Janice M. Kohut f/k/a Janice € NO. brf54 Civi ` &oi
M. Kunkle
1363 Kiner Blvd
Carlisle, PA 17013
Defendant(s)
CIVIL ACTION/COMPLAINT ON A PROMISSORY NOTE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections 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 claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted
tiene veinte (20) dias de plazo al partir de la fecha de la
demanda y la notification. Hace falta ascentar una comparencia
escrita o en persona o con un abogado y entregar a la corte en
forma escrita sus defensas o sus objeciones a las demanders en
contra de su persona. Sea avisado que si usted no se dafiende,
la corte tomara medidas y puede continuar la demanda en contra
suya sin previo aviso o notificacion. Ademas, la corte puede
decidir a favor del demandante y requiere que usted cumpla con
todas las provisiones de esta demanda. Usted puede perder dinero
o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE.SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the
creditor to whom the debt is owed is as named in the attached document. Unless you notify
us within 30 days after receipt of this Notice and the attached document that the validity of
the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If
you do notify us in writing of a dispute within the 30 day period, we will obtain verification
of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute
the debt, it is not an admission of liability on your part. Also, upon your written request
within the 30 day period, we will provide you with the name and address of the original
creditor if different from the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease
collection of your debt, or any disputed portion of it, until we obtain the information that
is required and mail it to you. Once we have mailed to you the required information, we
will then continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document
is an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 669-5400
r ,r
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page and is the Holder, Endorsee, and/or
is an assignee of a Note, secured by a Mortgage then it is such
by virtue of the following recorded and/or unrecorded
assignments:
Assignor: Community Bank of Northern Virginia
Assignments of Record to: Empire Funding Corporation an Oklahoma
Corporation doing business in California as Empire Funding Corp.
Recorded: LODGED FOR RECORDING
Assignor: Empire Funding Corporation an Oklahoma Corporation
doing business in California as Empire Funding Corp.
Assignee: Franklin Credit Management Corporation
Recording Date: LODGED FOR RECORDING
2. Defendant(s) is the individual designated as such on
the caption on a preceding page, whose last known address is as
set forth in the caption.
3. On or about the date appearing on the Note hereinafter
described, at the instance and request of Defendant(s), Plaintiff
(or its predecessor, hereinafter called Plaintiff) loaned to the
Defendant(s) the sum appearing on said Note, which Note was
executed and delivered to Plaintiff as evidence of the
indebtedness. Attached hereto and made part hereof as Exhibit
"A" is a true and correct copy of the Note.
4. Defendant(s) has/have defaulted with regard to the Note
and Plaintiff has heretofore elected to declare the whole of the
principal sum remaining unpaid together with interest thereon to
become immediately due and payable and by the filing of this
Complaint, Plaintiff has confirmed said election.
5. After demand, the Defendant (s) continues to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts
indicated below:
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Note as of
10/19/07
Principal of debt due and unpaid $38,644.15
Interest at 13.99%
from 9/15/06 to 10/19/07
(the per diem interest accruing on
this debt is $14.81 and that sum
should be added each day after
10/19/07 5,916.14
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Fees
220.00
Attorneys Fees (anticipated and actual
to 5% of principal) 1,932.21
TOTAL $46,992.50
7. The attorney's fee set forth above are in conformity
with the loan documents and Pennsylvania law.
8. If applicable, a Demand Notice and/or Notice of
Intention to Foreclose under Act 6 of 1974 and/or the combined
notice specified by the Pennsylvania Homeowner's Emergency
Mortgage Assistance Program, Act 91 of 1983 of the Commonwealth
of Pennsylvania and Notice of Intention to Foreclose under Act 6
of 1974 has been sent to each Defendant, via certified and
regular mail, in accordance with law, on the date appearing on
the copy attached hereto as Exhibit"B", and made part hereof, and
Defendant(s) have failed to proceed within the time limits
allowed, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
10 WHEREFORE, the Plaintiff demands judgment against the
Defendant(s) herein in the sum of $46,992.50, plus interest,
costs and attorneys fees as more fully set forth in the
Complaint.
By:
Mark J`?Udren, ESQUIRE
UDREN LAW OFFICES, P.C.
Attorney for Plaintiff
Attorney I.D. No. 04302
(Page 12 of 60)
' •I
{
t: NOTE
34ptamber 28, 1898 '
RBSTON, VIRGINIA
PROPERTY ADDRESS: 1363 KINER BLVD . No.-98"00ibS66
CARLISLE, PA .17018 ?-
4 t promise to pay • U.S. 862,900.00 Ithis amount Is
S 1.. BORROWER'S PROMISE TO PAY: In return for a loan that I have reaehred,
called the "principal"), plus, Interest, to the order of the Lender. The Lender is
ay COMMUNITY BANK OF NORTHERN VIRGINIA the I I Lm*nts tnddar this Note Is _called transfer this Note. The Lander or anyone who takes this Note by transfer and who is entitled to receive
Now HoWer." the
2. i INTEREST: i will pay interest at; a, yearly rate of 13.990 %. Interest will be charged on unpaid principal until the full amount of
principal has been paid. '
payments each month of U.S. 8704.14 1 will make my payments on the let
3. PAYMENTS: ' 1 egwill i h pay principal and Interest by making . I will make ties paymemwevery month until t have- paid all-of th&principal
described mber below, 01w,, that 1898 i'may owe under this Note. If, on October 01, 2093 , 1 stM owe amounts
day Interest and month b other r c ohear rges, November
and In
M
under this Note, 1 will pay two amounts, in full, on-that date:
I. win make my monthly payments at 111400 Conunmr m Park Drive, Ste. 110
i , RES-TON, VA 20190
or at a different place If required by the Note. Holder.
4. BORROWER'SMAILURE TO PAY AS REQUIRED: and of 10
(a), Lou Charge for Overdue Psymerds: 'If the Note Holder has. not received the fun amount of any of my monthly payments, the calendar days after'the date it is due will pay a late charge to the Note Holder. The amount of the, charge will be 5•0 of, my overdue
but not loss then U.S. A = and not more than U.S. *SAO I win pay this late charge only once on each late payment.
M)4 Oefaulft N I d=P%; he fun amount of each manthdir payment by the rite stated in Section 3 above, l will-be in defaWL Evan If, at a
time when I am in Note Holder does not (squire me to pay In. full as described above, the Nate, Holder will still have the right to do
so if I am in default at a later time.
lo) NottEe From Note Holder. If I am in default, the Note Holder may send no a written notice telling me that if I do not trey the overdue and all
amount by a' certain.date.the Note.Hokder may require me to ,pay Immediately the full-amount of-principal nowhich t mailer! which days alter paid all , 30 interest on•that amount. That date must be at least 30 days after the notice Is mailed to me or,
which It is delivered to me. If I do,not cure the default, the No *Holtlar will have the rights which the law allows, including the right to require
me to pay immediately the full. amount of principal which has not. been MW and all the Interest that t owe an that amount.
[d) Prraut of Nois'Hotdeu:'s Coate and$Expensas:: if the:Note Holder has required me to pay Immediately in full- as described above, the.Note
Holder weyrile have the right to be paid for ks costa and expenses to the extent not prohibited by applicable law. Those expanses Include, for
example, reasonable attorneys' fees. s
S.1HIS NOTE iS 'SECURP.D BY A MORTGAGE- In- addition to the ptatsctlons given to the Note Holder under this Note, a Mort age, dated'the
same day as this Note, protects the Note-Holder from posslble lossea• which might result if t do not. keep the promises which-1 ma7ce it this Note.
Tlist Mortgage describes, how and-under what conditions I may be required to make immediate payment in fun of an amounts that I owe under
this.Nots. .
6.: BORROWER'S PAYNIENfS BEFORE THEY ARE IMM I -have the right to make payments of prirxr)pal at any time before they are due. A
payment at pr I onir Is known as a "prern•' When I make a ymant, !win felt the NNote Holder in a loiter that I am doing to. A
erepayment. Of al of than unpaid priuc(pal •is• n as a "full prepayment.-, A Prepayment of only pelt of the unpaid principal is known as a
partial prepayment."
I may make' a full prepayment or a payment without paying any. penalty. The Note Holder will use all of my prepayments to
reduce On amount of principal that I owe par thispNotere. If I make a partial'prepayment, there will be no delays in the due data or changes in
the amounts of my mordWy pay unless the Note. Holder spraw-In wring to those delays or changes. I may make a full -prepayment at any
time. If 1• choose to make a partial tme er ^t, the Note Holder may, regtdre me-to make the prepayment on the same day that one, of my -
man payments ire due. The Now H may also require that the amount of my partial prepayment be equal to the amount of principal that
would have- been, part of my next ape or more monthly payments.
7. BORROWER'S WAIVERS: .I waive my rights ta:requtnt the Note, Molder to do•cartaln things. Those things are: JA) to demand payment of
amounts due (known as Ppresentment"); (BY to give notice that amounts due have not been paid (knowp as "notice of dishonor"); (C) to obtain
an official•certifloation otfi6n-p nt (known as a "protest"). Anyone-else who alp to keep the promisee made in this Note, or who agrees
to make, payments to the Noter If I fan `to keep my' promises astder this Note, or who signs this Note to transfer A to .someone also also
waives these rights. These•pereonp are known as "guarantors, eurades and endorsers."
8. = GIVING OF NOTICEM ' Any'notice that must be given to me under this Note will- be given by delivering it or mailing it by certifled man
addressed' to me at+the Property.Address above., A notice will, be delivered or malted to me at a different addrsas If I give, the. Note Holder a
notice of that. different address. '
Any notice that must bs'given to the. Note Holder under this Note will be given by maning it certified mail to the Note Holder at the
l be. mailed tot the Note. Holder at a different address if I am given a notice of that different
address stated in Section 3 AboYe. A nPtice wil
address.
9.- RuPOINSIBILfI'Y OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each of us is fully and personally obligated to
pay the fun amou nt,owed and to keep all at the promises made In this Note. Any guarantor, surety, or andorser of this Note (as described in
Section 7 above) is alsaobligated to do these things. The Note Holder may enforce-Rs rights under this Nate against each of us individually-or
against all of us together. This means that any one of us may, be required to pay all of the amount owed under this Note. Any parson who
takes over the rights or obligations of a guarantor, suretyr or endorser of this Note (as described In Section 7 above) is also obligated to keep-all
of the.promdses made in this Note.
X -
• Ros>:RT w.ltoHUr .
X
JANME M K
CE11111M D TRUE CpPY
X -
(Sign Original-Only)
PENNSYLVANIA'-Second Mortgage -1/80 - FNMAIFHLMC UNIFORM 06-MUMENT - Form
Management Systems Development, inc. (80019846060 Title-One EAer#&or12' PPA_NOTE Copyright fal 1994
(Page 13 of 60)
ENDORSEMENT OF NOTE
(WITHOUT RECOURSE)
App No. 2R-98.001 5868 •0912811998
FOR VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, the undersigned hereby
endorses- to: EMPIRE FUNDING CORPORATION' AN OKLAHOMA CORPORATION
DOING BUSINESS IN CALIFORNIA AS EMPIRE FUNDING CORP.
all of Its/his/her rights, title and interest in and to the attached Note dated 0912811998 in the face amount
of $52,900:00 . The Borrowers in said. Note are:
ROBERT W. KOHUT AND JANICE M. KOHUT F/K/A JANICE M.. KUNKLE, HUSBAND
AND WIFE
Said Note is secured by a mortgage, deed of trust or security deed of the same date on real property
located, at: 1'363 KINER BLVD
CARLISLE, PA 17013
COMMUNITY BANK OF NORTHERN VIRGINIA (Endorser/Beneficiary/Mortgages) transfers all
rights accrued or to accrue, under said Note and securing the mortgage, deed of trust or security deed' iir
which. the undersigned-Endorser is the.Beneficlary/Mortgagee, and Borrowers are Trustors/Mortgagors.
Endorser: COMMUNITY BANK OF NORTHERN VIRGINIA
.Endorsement Date: 9-28-98
By:
JOHN E. GRACE
Title: GECONDARY MARRETTNr QrrT _RR
Attestation pf mgzdn4
11 the. Secretary or Assistant Secretary of
hereby certify that
is the duly elected President or Vice President of and has, the
requisite, corporate authority to execute this document and that the signature appearing above is. his/her genuine signature.
Date:
BY.
Title:
Management Systems Development, Inc. (800)9846060 Loan-Energizerl' 4ASSNN0TE0426/98co.nm/date) Copyright (c) 1994
(Page 16 of 60)
N
Assignment of Note Loan# 5056850
For valuable consideration, receiptofwhich ?he Db E ?wledges, the undersigned hereby sells, transfers,
endorses, assigns and delivers WITHOUT
all of its n , title and interest in and to the attached promissory note dated 0 9 / 2 8 / 9 8 in. the face
amount o 52-,900.00 . The borrowers in said promissory note are:
ROBERT W KOWT and JANICE' X ROM"
Said promissory note is secured by a Mortgage, Deed of Trust or Security Deed ("Security Instrument') of
the same date on real property located at:
1363 KINSR BOVLVnM
CARLISLE, PA 17013
r(B78759
ent in
he undersigned is the Beneficiary and the borrowers arc the Trusters.
Dated: 10/06/98
i
f
EFC 4197 Form: D-20
Beneficiary: E=ire Funding Corp..
an Oklahoma corporation
i
By. zrimt?in Frederi , Asst. V.P.
September 26, 2007
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The HnMT OWNEROS MORTGAGE ASSISTANCE. PROGRAM (HF.MAI!) mny he We
to help to cav your home- Thic Notice exnlsins how the gram works-
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
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
Page 1 of 1 GA g
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
Robert W. Kohut
_. Janice M. Kohut fka_Janice M. Kunkle.,..___._
1363 Kiner Blvd
.. Carlisle PA 17013..,...___.?._.?._.._._.._.?....._.._.._._._....._
Communily_Bank of Northern Virginia
Franklin Credit Management Corporation
HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOTT MAY RF Fi iC.IRi.F FOR FiNANCIAI. ASSISTANCE.
MMIC14 CAN SAVE YOUR HOME. FROM FORECLOSURE AND
HELP YOU MAKE FITTiTRE MORTGAGE, PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTO), 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 FORE,Ci.OSITRE -- 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. During that
time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THiS MEETING MUST OCCITR WITHIN
NOTICE CALLED OHOW TO C1TR1E YOUR MORTGAGE DREAi1i.TO, EXPLAINS HOW TO
BRING Y01 TR MORTGAGE ITP TO DATE
CONSUMER CREDIT .OITNSFI, NG 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 el=hone numbers
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.
APMI CATION 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.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
Page 2 of 2
face- to-face meeting.
YOU MIST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
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.)
NATURE. OF THE. DEFAITI.T -- The MORTGAGE debt held by the above lender on your property
located at:
1363 Kiner Blvd
Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monti Pa..?ments of 704.14 for October 15, 2006 throe h Se?tember_15,_2007..._= X8449.68
_Mont" Late_Chames of. 0 for October 15 2007 throuah'Se tember 152007 =$0.00
Other charges (explain/itemize): BPO=$85.00
_Other. Fec4135.00 -- - ..?._.r._.?._.?._.-.. __ __ _...._...._..
_ TOTAI. AMOUNT. PAST DUE: _.... _....?__._._.._ _._. _ ._..__..... _..__...... __._....._._....... -.._.__..... ?._..__._.__.._._$Q.(?$...
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not annli . hl .): WA
HOW TO CITRF. THE. DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS .($, PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must he mane either by cash, cashier's .heck., .ertified check or money order made hayahle
and cent to- .
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter: (Do not use if not apnlirable_l: NA
Page 3 of 3
IF YOU DO NOT CTTRF, 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 he 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
forecloc . anon your mortgaged propeEly.
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 THMTY_(36) DAY period, you will not he
required to pay a ey's fees-
OTHER i,F.NDF.R REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RIGHT TO CITRF, THE DEFAULT PRIOR TO SHERIFF'S SAi.E_, - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
12.q)jng th total mo mt then Vast clue 121 us any late or other charg os then due, reasonable attorney's fees an
coats onnected with the foreclosure Sale and any other costs, connected with the Sheriff's Salem, . ifie
in writing by the lender and by pri forming any other requirements order 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.
EARi,TEST POSSIBLE SHERIFF'S SALF, DATE - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately 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.
Name of Lender/Servicer:
__._.__....-.._-...._ ....?._.__....__._____._._.
Franklin Credit __....__..._-.... ......
Address: 101 Hudson Street
_Jersey_City,_NJ 07302._.._ .....__.._._._....___....___._...--_..... _.__...._._._.._.._.-......
Phone Number:
__..___._?_.__.....__.....___.....__.
_1-800-255-5000 .......___.__....__....__..._._._.._._.....
Fax Number:
Contact Person: -..-Customer Service ...._-_..... ___...........
__.-.--.-.--....
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 MORTGAGF. - You may not 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.
Page 4 of 4
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 of 5
.i .1 r
• 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.
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FAX (717) 5414670
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
FAX n/a
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
Page 6 of 6
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A e . t
V E R I F I C A T I ON
Mark J. Udren, Esquire, hereby states that he is the
attorney for the Plaintiff, a corporation unless designated
otherwise; that he is authorized to take this Verification and
does so because of the exigencies regarding this matter, and
because Plaintiff must verify much of the information through
agents, and because he has personal knowledge of some of the
facts averred in the foregoing pleading; and that the statements
made in the foregoing pleading are true and correct to the best
of his knowledge, information and belief and the source of his
information is public records and reports of Plaintiff's agents.
The undersigned understands that this statement herein is made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Mark J. dren, ESQUIRE
UDREN LAW OFFICES, P.C.
00 -?.
i 'r7
.
ul i
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Franklin Credit Management :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
Plaintiff :Cumberland County
V.
Robert W. Kohut :NO. 07-6754 Civil Term
Janice M. Kohut f/k/a
Janice M. Kunkle
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint on the above-captioned matter.
DATE: December 18, 2007
UDREN LAW OFFICES, P.C.
BY0401YI dif)1 vplw/) ,
Attorneys for -Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
Q
p
F
C,3 -C
SHERIFF'S RETURN - REGULAR
CASEONO: 2007-06754 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FRANKLIN CREDIT MANAGEMENT COR
VS
KOHUT ROBERT W ET AL
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
KOHUT ROBERT W
the
DEFENDANT , at 2020:00 HOURS, on the 3rd day of December-, 2007
at 1363 KINER BLVD
CARLISLE, PA 17013
ROBERT KOHUT
was served upon
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge All,
? \ -
Sworn and Subscibed to
before me this
of
So Answers:
18.00
5.76
.00
10.00 R. Thomas Kline
.00
33.76 12/04/2007
UDREN LAW OFF
By:
day Deputy Sheriff
A.D.
SHERIFF'S RETURN - NOT FOUND
CASE-NO: 2007-06754 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FRANKLIN CREDIT MANAGEMENT COR
VS
KOHUT ROBERT W ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
KOHUT JANICE M F/K/A JANICE M KUNKLE but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT
M KUNKLE
1363 KINER BLVD
NOT FOUND , as to
, KOHUT JANICE M F/K/A JANICE
CARLISLE, PA 17013
PER ROBERT, JANICE IS LIVING IN MECHANICSBURG.
HE DID NOT KNOW EXACT ADDRESS.
Sheriff's Costs: So answers
Docketing 6.00'' ~
Service 9.60 r
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
a .00
,???/ ? 3 0 . 6 0
Sworn and Subscribed to before
me this day of
A. D.
UDREN LAW OFFICES
12/04/2007
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-06754 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FRANKLIN CREDIT MANAGEMENT COR
VS
KOHUT ROBERT W ET AL
JESSICA HERMANSEN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
KOHUT JANICE M F/K/A JANICE M KUNKLE the
DEFENDANT , at 1527:00 HOURS, on the 31st day of December , 2007
at 400 INDEPENDENCE COURT
MECHANICSBURG, PA 17050
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.60
Affidavit .00
Surcharge f 10.00
.00
/s? f s 3
7.60
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
01/03/2008
UDREN LAW OFFICES
By:
De u y S eriff
A.D.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
V-dHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Franklin Credit Management :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
101 Hudson Street :Cumberland County
Jersey City, NJ 07302
Plaintiff
V.
Robert W. Kohut NO. 07-6754 Civil Term
1363 Kiner Blvd
Carlisle, PA 17013
Janice M., Kohut f/k/a Janice
M. Kunkle
400 Independence Court
Mechanicsburg, PA 17050
Defendant (s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
the Defendant(s) Robert W. Kohut and Janice M. Kohut f/k/a Janice
M. Kunkle for failure to file an Answer to Plaintiff's Complaint
within 20 days from service thereof and assess Plaintiff's
damages as follows:
As set forth,in Complaint $46,992.50
Interest Per Complaint 4,916.92
From 10/20/07 to 4/23/08
TOTAL $51,909.42
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, a copy of which is attached
hereto.
UDREN LAW OFFICES, P.C.
BY:1 /pto 1 WA ?? ?
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE : Q?a25?DS? S
R PROTHY DGB
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
RjBAAyaas@udrea om
Franklin Credit Management Corporation
Plaintiff
V.
Robert W. Kohut
Janice M. Kohut f/k/a Janice M. Kunkle
Defendant(s) .
TO: Robert W. Kohut
1363 Kiner Blvd
Carlisle, PA 17013
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 07-6754 Civil Term
DATE of.Notice: January 22, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ
(10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER
USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED
TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
s
Par a. uaren, Esquire
Stuart Winneq, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA4 ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, Na 08003
856-669-5400
Fl Adi"aeudren nom
Franklin Credit Management Corporation
PlainEiff
V.
Robert W. Kohut
Janice M. Kohut f/k/a Janice M. Kunkle
Defendant(s)
TO: Janice M. Kohut,f/k/a Janice M. Kunkle
400 Independence Court
Mechanicsburg, PA 17050
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 07-6754 Civil Term
DATE of Notice: January 22, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ
(10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER
USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED
TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
s
Ma J. uaren, Esquire
Stuart Winneg, Esquire
Lorraine Doyle, Esquire
Alan M. Minato, Esquire
Chandra M. Arkema, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Franklin Credit Management :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
Plaintiff ::Cumberland.County
v.
Robert W. Kohut
Janice M. Kohut f/k/a Janice
M. Kunkle NO. 07-6754 Civil Term
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF CAMDEN
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant (s) are not in the
Military or Naval Service of the United States of America or its
Allies as defined in the Servicemembers' Civil Relief Act (108 P.L.
189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and
last known residence and employment of each Defendant are as
follows:
Defendant: Robert W. Kohut
Age: Over 18
Residence: As captioned above
Employment: Unknown
Defendant: Janice M. Kohut f/k/a Janice M. Kunkle
Age: Over 18
Residence: As captioned above
Employment: Unknown
UDREN LAW OFFICES, P.C.
BY:
Att rneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
Sworn to and subscribed
before me this 1 g' day
of ^77ptember, 2041^
Notary Public
Notmy Pu6Gc
State of NewYersey
T
c_
C-n
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LOR.R.AINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCR.EST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Franklin Credit Management ::COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
Plaintiff 'Cumberland County
V.
Robert W. Kohut -NO. 07-6754 Civil Term
Janice M. Kohut f/k/a Janice
M. Kunkle
Defendant(s)
TO: Robert W. Kohut
1363 Kiner Blvd
Carlisle, PA 17013
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a Judgment has been entered against you
in the above proceeding as indicated below.
X Judgment by Default
X Money Judgment
Judgment in Replevin
Judgment for Possession
Prothonotary
/s/ dxici je.
4x4
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Udren Law Offices. P.C.
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Franklin Credit Management :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
Plaintiff :Cumberland County
V.
Robert W. Kohut
Janice M. Kohut f/k/a Janice :NO. 07-6754 Civil Term
M. Kunkle
Defendant(s)
TO: Janice M. Kohut f/k/a Janice M. Kunkle
400 Independence Court
Mechanicsburg, PA 17050
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a Judgment has been entered against you
in the above proceeding as indicated below.
X Judgment by Default
X Money Judgment
Judgment in Replevin
-Judgment for Possession
Prothonotary
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d ?q
-Judgment on Award of Arbitration
-Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY- Udren Law Offices, P.C.
At this telephone number: 856-669-5400
ti
Return To & Prepared By:
M. E. Wileman
Orion Financial Group, Inc.
2860 Exchange Blvd. # 100
Southlake TX 76092
DPROTHONOTARY#C
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2014 AUG 15 PM 12: 5 I
CUMBERLAND COUNTY
PENNSYLVANIA
Di- (D75I
ASSIGNMENT OF JUDGMENT Send Any Notices To Assignee.
For Valuable Consideration, the undersigned, THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE
TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A 7 EASTON.OVAL EAE63, COLUMBUS, OH
43219 (Assignor) by these presents does assign, and set over, without recourse, to BOSCO CREDIT II TRUST
SERIES 2010-1 1761 East St. Andrews Place, Santa Ana; CA 92705 (Assignee) the described judgment with all
rights due or to become due thereon. Said judgment against defendant, ROBERT W. KOHUT AND JANICE M.
KOHUT F/K/A JANICE M. KUNKLE, dated 9/25/2008 is recorded in the Court of Common Pleas as Case #Case #
07-6754 in the State of PA County of Cumberland.
IN WITNESS WHEREOF, the undersigned corporation has caused this instrument to be executed by its proper
officer. Executed on: August 11, 2014
THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET
TRUST 2009-A Franklin Credit Management Corporation Attorney in fact
By:
Kelli J. Airis, Vice President
Witness: T. Davis
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Witness: S. Bryan
State of Texas, County of Tarrant
Personally appeared before me M. Conner and made oath that he/she saw the within named Kelli J. Airis, Vice
President of/for THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN
MORTGAGE ASSET TRUST 2009-A Franklin Credit Management Corporation Attorney in fact by sign, seal and
as their act and deed deliver the within written instrument and that he/she with THE HUNTINGTON NATIONAL
BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A witnessed the due
execution thereof. Sworn before me this August 11, 2014.
M. CONNER
MY COMMISSION EXPIRES
November 30, 2014
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Notary public, M. Conner
My commission expires: November 30, 2014
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Pfr 08
1918460
PA Cumberland FCMC/JUDG/ASMT JUD