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HomeMy WebLinkAbout04-0704IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. GALEN TROLINGER a/k/a GALEN G. TROLINGER LISA TROLINGER a/k/a LISA K. TROLINGER Defendants NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 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 wdtten 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 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. 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 PERSON ATA REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 EN LA CORTE DE ALEGATOS COMON DEL CONDADO DE CUMBERLAND, PENNSYLVANIA DIVISION CIVIL WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff contra : Num. Del Caso. GALEN TROLINGER a/k/a GALEN G. TROLINGER LISA TROLINGER a/k/a LISA K. TROLINGER Defendants AVISO PARA DEFENDER Conforme a PA RCP N~m. 1018.1 USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defenderse contra de la demanda puestas en las paginas siguientes, usted tienen que tomar acci6n dentro de veinte (20) dias despu6s que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando pot escdto con la Corte sus defensas o objeciones pot puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado contra usted por la Code sin m~s aviso pot cualquier dinero reclamado en la Demanda o por cualquier otro reclama o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR I~STE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELI~FONO LA OFIClNA FIJA.DO AQUi ABA JO. ESTA OFICINA PUEDE PROVEER¢: CON INFORMACION DE COMO CONSEQUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, I~STA OFIClNA PUEDE PROVEERI~ INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE A UN HONORARIO REDUCIDO O GRATIS. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION -- MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. GALEN TROLINGER a/ida GALEN G. TROLINGER LISA TROLINGER a/ida LISA K. TROLINGER Defendants COMPLAINT AND NOW, comes Plaintiff, Waypoint Bank, f/Ida York Federal Savings and Loan Association and Hards Savings Bank, by and through its attorney, Benjamin F. Riggs, Jr., and complains of Defendants, Galen Trolinger and Lisa Trolinger, as follows: Parties 1. The Plaintiff is Waypoint Bank, a corporation organized and existing under the laws of the United States of America, and it is registered to do business in Pennsylvania, with offices for the purpose of doing business at 235 North 2nd Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711. 2. The Defendants are Galen Trolinger a/Ida Galen G. Trolinger, an adult individual residing at 615 West Pine Street, Mt. Holly Springs, PA 17065 and Lisa Trolinger a/Ida Lisa K. Trolinger, an adult individual residing at 114 4th Street, 2nd Floor, Boiling Springs, PA 17007, and are the mortgagors and real owners of the Mortgaged Premises located at 615 West Pine Street, Mt. Holly Spdngs, PA 17065, Cumberland County, having acquired title by Deed dated March 28, 1988, and recorded on March 28, 1988, in the Cumberland County, Pennsylvania, Recorder's Office in Record Book G-33, Page 138. Mortgage 3. On or about April 22, 2002, Defendants made, executed, and delivered to Plaintiff a mortgage upon premises therein described, which Mortgage contains a description of the premises subject to said Mortgage and was recorded on April 26, 2002 in the Cumberland County, Pennsylvania, Recorder's Ofr~ce in Mortgage Book 1756, Page 3074. A true and correct copy of said Mortgage is attached hereto, made a part hereof, incorporated herein by reference, and marked "Exhibit A". Assi~lnments There have been no assignments of said Mortgage. Default 5. Said Mortgage is in default because Defendants have failed to make the monthly payments of principal and interest due and owing on their loan from August 1, 2003 through the date of filing this Complaint as required by the terms of the Mortgage. Any payments that may have been made during this period were applied to the delinquency balance due and owing pdor to August 1, 2003. 6. Plaintiff hereby exercises its option to declare the entire amount owing upon said Mortgage immediately due and payable in accordance with its terms and provisions. 7. By reason of the default, the following amounts are due in accordance with the terms of said Mortgage: Unpaid Principal Balance Interest from 7/1/03 to 1/27/04 (inclusive) at $9.8990 per diem Late Charges from 8/'1/03 to 1/27/04 (inclusive) at $45.76 per month Escrow Deficit Attomey's Fees 15% TOTAL AMOUNT DUE $48,239.46 $2,118.38 $228.80 $0.00 $7,235.92 $57.82~56 Compliance with Homeowners' Emerqency Assistance Act 8. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i) Defendants have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendant, a true and correct copy of which is attached hereto as "Exhibit B"; or (ii) Defendants' application for assistance has been rejected by the Pennsylvania Housing Finance Agency. Compliance With Loan Interest and Protection Law 9. Notice of Intention to Foreclose and Rights Under Pennsylvania's Loan Interest and Protection Law, Act of January 30, 1974, P.L. 13, No. 6 (41 P.S. § 101 et seq.), as amended, was sent in accordance with said Act to Defendants on November 12, 2003. A true and correct copy of said Notice is attached hereto, made a part hereof, incorporated herein by reference, and marked "Exhibit B". WHEREFORE, Plaintiff Waypoint Bank, f/k/a York Federal Savings and Loan Association and Harris Savings Bank prays for judgment in its favor and against Defendants, Galen Trolinger and Lisa Trolinger, in the amount of Fifty-Seven Thousand Eight Hundred Twenty-Two and 56/100 Dollars ($57,822.56), with interest thereon until paid at such rate or rates as established by Plaintiff pursuant to the terms of the Installment Note, currently $9.899 per diem, from January 28, 2004, late charges at 5% of the monthly payment amount, currently $45.76 per month from January 28, 2004, attorney's fees, costs of suit, and other charges collectible under the Mortgage; for the foreclosure and sale of the mortgaged premises; and for any and all other relief as the Court deems appropriate. Dated: ;~/J./O~ BY:Benjamin F. Ri~gg ~ Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 VERIFICATION verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I further verify that I am a Default Specialist II of Waypoint Bank, and that as such, I am authorized to make this Verification on its behalf. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. WAYPOINT BANK Dated: Barbara L. Householder Default Specialist II 22 MOl:Il'GAGE tile face amount o[ ~_ __4_9.~_8_5Z~~ . with interest thereon aL the rate specified dlerein requiring Execution or other appropriate writ, Mo gagor waives all rights and benefits under any and all laws or rules of Itl WI INESS WHEREOF, and intending Io be legally bound hereby, Mortgag~r has hereunto) set hand arid seal the Witl~ ~ e delivered h tl~ presence of: ............ _ GOVERNING tAW:Terms foll~winga L] apply when checked' ~ il tile Mortgaged PreperW is located whhm the Commonwealth of Pennsylvania, then this a!peemen[ shall be governed by tile laws of the Commollweald~ et Pennsylvania, except to the extent []If the Mnrtga§ed Property is located withh~ the State of Maryland, then this agreement sharl be 9evern*~d by tbe laws nj the State of Maryland, except to die extent that such laws have been i}reempled nr superseded by Federal Law. if this Agreement is governed by the laws of the State of M~ryland, [her the tender elecEs [o have [his Agreement 9overned by Title 12 et the Commercial Law Aiticle of the Annotated Code of Maryland, r'] Subtitle 9, Credit Grantors Open End Provisions ~_j St~htitle 10, Credit Grantors Closed End Prnvisions STATE OF P~SYLVANIA ) ) COUN I y OF CU~fBBRLAND ) SS: Oil dlbi, the 22nd (lay of Ap~ll 2002 , before me the ul3dersigl~ed officer, personally appeared Lisa 'Prolinqer and Galen Trolinqer known ~o me (or satisfactorily proven) to be the person(s) whose name(si is (are) subscribed to the IN WITNESS WHEREOF, I have hereto set my hand and notarial seab I HEREBY CERTIFY that the precise residence of the Mor[gagee(s)and person entdled to interest on lllisMorlgage s Wsypoint Bank, 2ndand Pine Streets, Harrisburg, Pennsylvania 17101. 8K I 756f ,307 a the ~enter ~ ~ai~ ~oa~, $ou~h 4B ~e~zemm 8 BIll 756P~3076 ecorder of Deeds November ]2, 2003 ACT 91 & ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice tbal the mort-_a~e on your hume is in default, and tile lender intends to foreclose. Specific intbrmation about the nature of the default is prnvided in tile attacbed l)a~oes. The HO]VI~OWNER'S MORTGAGE ASSISTANCE PROGRAM (I-IEMAPt Ina~, be able to help to save yom' home. This notice explains how the l)ro~ram works. To see ii' HEMAP can help. yon must MEET %~ITH A CONS~LB~R CREDIT CO[~'NSELENG AGENCY WITI:IIN 30 DAYS OF TH~ DATE OF THIS NOTICE. Take this Notice witb you when you meet with the Counselin~ A~encv. The name, address and phone number of Consumer Credit Counselin~o A~encies ser~'ing your CounB, are listed at the end of this Notice. If vou ha~'e any questions, you may call the Pennsylvania Housin~ Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contaius 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 coutact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AI)JLWTO ES DE SL2V[A ][MPORT.~rCIA, PUES MFECTA SU DERECItO A CONTINUAR VlXqENDO EN SU CASA. SI NO COMPRENDE EL CONTENII)O DE ESTA NOTIFICAC1ON OBTENGA ETNA T1L~DI7CCION IN~ED1T)d~{ENTE LLAM.&NDO ESTA AGENCIA (PENNSYLVA1N~L4~ HOUSING FINANCE AGENCY) S[~4 CAi~GOS AL ]~U~LERO MENCIONADO :~d~IBA. P[~DES SER ELEGIBLE P.43L4 UN PREST_43MO POR EL PROGR.&MA LLANE4DO "HOMEOWNER'S EMERGENCY MORTGAGE ASSIST.~NCE PROGR~4.M" EL CUAL PUEDE SALVAR SU CASA DE LA PERDI])A DEL DERECHO A P~EDIMIR SU I~POTECA. FRO. Box 171 [, HAR~I~EIURG. I~NN~yL.YANtA 1710B-1711 ri ~:;_~:l;:~q_7R~4~12;/ . IN YORK AR~A 717 '81B-4[;00 - ~wvw,waypointbank.com HOMEOWNER'S NAME (S). G, Ich Trolinger PROPERTY ADDRESS: _615 ~¥' Pine Street, hit Holly Springs, Pa 17065 MAILING Al)DRESS: _615 W Pine Street 5'1t Itolly Springs, Pa 17065 LOAN ACCT.NO.: 5551000089 ORIGINAL LENDER: _Waypoint Bani; N CIq?,RE. T LENDER/SERVICER: XVavooint Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGIL~_M YOU MAY BE ELIGIBLE FOR FINANCE~L ASSIST~kNCE WHICH CAN SAVE YOUR HOME FROM FORI~CLOSIrRE .AND HI~LP 5 Oh M_M,~E FUTtrRE MORTGAGE PAhqV[ENTS 117 k Ol COMi~LY WITH TI-YE PRO\qSIONS OF TI-IF HOMEOWNER'S EMERGENCY MORTGAGE ASSIST_a=NCE ACT OF 1983 (THE "ACT"), YOU Yka. y BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSIST.AN-CE · IF YOUR DEFALq. T EL4.S BEEN CAUSED BY CHlCUMSTA~NCES BEYOND YOLqR CONTROL, · IF YOU HAWE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOLrR MORTGAGE PAXc~I~NT S~ · IF YOU .MEET OTEIIS~R ELIGIBILITY REQ UqILENEENTS ESTABLISHED BY T H TEMPOIL4RY STAY OF FORECLOSL'TtE---Under the Act, you are entitled to a temporary stay of £oreclosnre on your mortgage for thirty (30) days fi'om the date or,his Notice. During that time you mast arrmage and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of riffs Notice. THIS _MEETING MrUST OCCIFR 5X'ITIIIN THE NrEXT THIIRTY DAYS. IF YOU DO NOT .&PPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU PFUST BRING YOUR MORTGAGE L?P TO DATE. TIlE PART OF TI-IlS NOTICE CALLED "HOW TO CURE YOL~ MORTGAGE DEFALILT', EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSqk~IER CREDIT COILNSELING AGENCIES---If you meet with one of the consumer credit counseling agencies listed ar 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 tele¢hone numbers of' desiamated consmner credit counselina aze~qcies for ~he count' in which the crovert¥ is located are set forth at the end of this Notice. It is on13 necessaD~ to schedule one i;ace-to-face meeting. Advise yom: lender immediately of' your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the reasons set £o~h later in this Notice (see following pages for specific infbnnation about the nature of },our deib, ult.) if you have tried and arc unable to resolve this problem wit]~ the lender, you have the right to apply for financial assistaace fi'om the Homeowner's Emergency Mortgage Assistance Program. To do so. you mtlst fill out. sign and file a completed blolneowner's Emergency Assistance Progratn Application with one of the designated consumer ctcdil coLilqse]illg agencies ]isled al thc end of this Notice. ©nly consumer crcdi~ counseling agencies have applications Jbr thc pro,q-am and they wiI] ass~sl yoLt m subn~ittm5 a comp[cie apl>14cation to thc Pennsylvania Housing Finance Agency. Tour application MUST be Ihled o~ ])ostmarked within thirb' (30) days of your [ktce-to-ikrce meeting. YOU MUST FILE YOUR APPLICATION PR()MPTLY. 1F YOU FAiL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YO'[~ HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION---Available funds for emergency mortgage assistance m'e ve~T limited. Tlnev will be disbursed by fl~e Agency under tbe eligibilitV criteria established by the Act. The Pennsylvania Housing Finance Agenc) has sixtT {60) days to n~ake a decision aiher it receives your application. Dnrin_e tbat time. no k~reclosure proceedings will be pnrsued against you if you bare met the time requirements set fo~1h above. You will be notilied directly by the Pennsylx ama Housing Finance Agency ol-its decision on your application. NOTE: IF YOU ARI~ CUPQP~ENTLY PROTECTED BY Tlttl FILING OF A PETITION IN BANICRUPTCY, THE FOLLOWING P_~uqT OF THIS NOTICE IS FOR LNFOILMAT1ON~ PLXLPOSES ONLY .~NT) SHOULD NOT BE CONSIDERED AS _aN ATTEMPT TO COLL~pJT TFt~ DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) I x ~t~R .~OR* ~_-~G~ DE ....... ,rBrin-_ it to date). HOW TO CbT~ "~'~ ...... ~ r ~-r T 'al! NATIT{E OF TI-IE DEFAE'LT---The MORTGAGE debt held by the above lender on yonr prope~, located at:_ 615 W Pine Street, Mt Holly Spm~gs, Pa 17065 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT IVLKDE MONTHLY MORTGAGE PAhqVEENrFS fbr tbe following months and the following amounts are now past due: _Pa~nents of $457.62 due each for the months o£Au~st, September and October 2003. B. Other charges: _Late Charge 5137.28 TOTAL _~MOUNT PASTDE:'JE: _$1,510.14 YOU I-LAVE FAJiLED TO TAKE THE FOLLOWING ACTION: HOW TO ClOt; THE DEFAULT---You may cure the default within THIRTY (30) DAYS of' the date of this notice BY PAYING THTE TOT_a~L _~EVlOUNT PAST DUE TO TI:I~ LENDER, WI-IICH IS $1,510.14 PLUS ANT MORTGAGE PAk~/iENTS AiND LATE CHARGES WHICH BECOME D'GE DL~,iNG TIIE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or money order made Davable and sent to: Waxq~oint Bank 449 Eisenhoxver Boulevard Harrisburg. PA 17111 IF YOU DO NOT CURE THE DEFA[FLT---If you do not cure the default within THIRTY (30) DAYS of the date o£this Notice. the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt wiI] be considered due inzmediate]y and you may ]ose the chance to pay the mmxgage in monthly insta]Iments. If fid] payment of' the tota] amount past due is not IF TIlE MORTGAGE IS FORECIX)SED I~PON---The mortgaged property will be sold b3 the Sheri:ff to pay off thc mortgage debt, if the lender rel~rs your case to its a~lomeys, but you cure lhe dclinquency be;ore the lander begins legal proceedings against you, you will gtiI] be reclud-ed to pay thc reasonable attorney's l~es that were actaall) incurred, dp to $50.00. However. illegal proceedings are smiled against you, you will have to pa) alt rcasooable atlorneys' ]~es actually incurred by the lender even if they exceed $50.00. Aoy a~omed's fees will be added to d~e amount you owe the lender, which may also include other- reasonable costs. If yon cure the defnnlt within ll~e THIRTY (30t DAY period, you will not be re~oired ~o lmv ntlornev's l~es. OTItqiR LENDER REMEDIES---The lender may also sue you personally fo~ the unpaid principal balance and all other sums due uudm' the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured tine default within fl~e THIP~TT (30) DAT period and foreclosure proceedings have begun, you still have the ri~tnt to cure the tier;cult mqcl prevent the sale at any time UD to olde hour before the Sheriffs sale. You max do so bx pavin~ the total a~nOtllll thee past due. lolus any late or other chm'~es thell due. reasonable aNorlleV:s ~e5 ai~cI costs connecrecl with the ibreciosure sale and anx other costs connected with the Sheriffs Sale as speci~e( in wnnn~ by the lender and by ¢ertbmtinz any other recmn'ements under fl~e 121o17t~age. Cra'ins your del~ult in the mauner set fin'th in this uotice will restore yom' mortgage to the same position as if you had never dethulted. E)~P. LIEST POSSI~BLE S~!~_IFF'g SALE DATE---It is estimated that the earliest date tlxat sttch a Sheriffs Sale of the mortgaged prope~%' could be held would be approximately Ibm- months fi'om the date of this Notice. A not/ce of the actual date of the SherifFs Sale will be sent to you before the sale. Of coarse, 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 act/on will be by cont]-actmg the lender. HOW TO CONTACT T1TE LENnDER: Nmne of Lender: Address: Phone number: Fax Number: Contact Person: \Vaxq3oint Bank 449 Eisenhower Blvd.. Han-isbur=. PA 17111 (71% 90%2710 or 1-866-929-7646 ext. 2710 (717) t)09-2780 Tara Porter-Trowbridee EFFECT OF SI-~.RLFF'S SALE---You should realize that a SherifFs Sale will encl your ownership of the moltgaged propel%' and your right to occupy it. If yoo continue to lixe in the prope~% after the SherifFs Sale. a lawsuit to remove you and your furnishings and other belongdngs cotdd be stm-ted by the lender at an}, time. ASSUMPTI ON OF MORTGAGE---You may or _~_Xm y not (CHECK ONE) sell 02' transfer your lmme 1o a buyer or n'ansferee who will assume the mortgage debt, provided that all the outstanding p%ments, 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. YOU MAY ALSO H_~kVE THE RIGHT: ]O SELL TItE PIt()P];RTY TO Ol~'I AIN MONEY "lC) l'A~ (~I:1~ THE M( )ItT(3AgE I)EB1 OR ]O BOItltOW MONEY FROM :ZNOTHER LEND~NO INSTI'IIITION ]'() PAY O]:.T THIS D E~T TO HAVE THIS DEFAULT CURleD BY ANdY THIRD PARTY ACTING ON YOUR BEHALF. TO ItAVE TltE MORTGAGE I'~S'FOItED TO TttE S-5ME POSIT]ON AS lY' NO DEFAULT HAF) OCCUP~ED, 1]z YOU CLrRE THE DEF.,'\ULT. (HOWEVER, YOU DO NOT HAVE THIS PdGHT TO CI IRE YOI JR DEFAULT MOI, LE THAN TI-fREE TIMES IN _%Nil' CALEND.~ ~qEAR.} TO ASSERT THE NONEXISTENCE OF A DEFAULT LN ANT FOI~CLOSLPfLE PROCEEDING OR ANI~ OTHER LAWSUIT INSTITUTED UNT)ER THE MORTGAGE DOCUMENTS, TO ASSERT AN%~ OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UN'DER THE FEDEf%~I_ B.&NICRUTTCT LA\Y TPT&ek Ve%, tn.dy No LtrS, Tara Porter-TrowNSdge Collection Counselor If f~lnds &~re received and ne~soti&~{ed in lees {hah {he total &~n~omnt due inclndin~ ri6h{ {o re,urn the fu~nds {o Nou and continue ei{h le6al proceedings pendin~ receipt of {he io{al amoun~ due. CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 FAX (717) 541-4670 Financial Counseling Services of Frank[in 31 West 3~d Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (71 7) 334-8326 Community Action Corem of the Capital Region 1514 Derry Street Harrisburg, Pa 17104 (717) 232-9757 FAX (717)234-2227 P.O. Box ]711 HARRISBURG PENNSYLVANIA 17105-[7]1 ......... ~, ......... ir c2~.~_~:~m~_TK~l . IN YF)RIf AREA 717/815-4500 ' www.waL~pointbank.com November ]2, .~ 00~ The s~bscriber belo~,~' of the ~Z S. P~st Office lock, ted at &120 Den3, S~reet, H~zmsbu~, PA J 7]]], does here[i~' c'ert~' t/tat c~z em,do2e ~,'c~s mcded ~'i~]z postoze preloaid t~y £irst Clax$ z~/~dl from ~he [4~v(rlvoint Bank a&b*essed to Gde~ Troli~ger, 615 ~F Pine Street, ~?h Holly Springs, Pa 17065, ~ ..... ~" ~-- o4' :~ r~ . __ ~ - ~,t o]~, . .~oo.e. ~. S 31czi/ fo,: delive? this l '~ da), of ?Vove,~ber, _ O&.. IA $. Post Office 5]20 Deny Street Hamsburg, PJ RO. Box 1711, HARRISBURG, PENNSYLVANIA 1710~-1711 , · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1, Article Addressed to: Article Number (Transit ftorn service PS Form 3811, Augu., *uu, 7003 A. Si ature ~ X.~ ~ ~Addressee ~1Re~ived b¢4nt~dt~ame) ~ C. Date of D~ivew D. ~s deliveW address different ~ item 1. ~ Yes/ If YES, enter delivew addre~beIow: ~ 3. Service Type ? ~- .,~ ~.~ ~ ~ ~- ~ ~r~Cer~ified Mail E]~xpres~r~ .., r L ~' Registered ~ Re~rn~4c~t ,~ ~e~ndise ~ Insured Mail ~ C,0~,~ ~ ~ L~J 4, Restricted Delivew? (E~ra Fee) ~ Yes 2260 0000 9701 2146 L)omesno Return Receipt 102595 02-M November /2, 2003 ACT 91 & ACT 6 NOTICE TAKE, ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an ollicial notice that the mort~oa.oe on your home is in default, and tile lender intends to foreclose. Svecific information about tile nature of tile default is provided in tile attached pa~es. Tile HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IH~EMAP~ may he able to held to save your home. This notice explains how the Droaram works. To see it' HEh~4P can helD. vou nmst MEET ;hqTH A CONSUM~;,R CREDIT COE_'NSELING AGENCY %rlTI:IEN~ 30 DAYS OF TH]~ DATE OF THIS NOTICE. Take this Notice with von when you meet with the Counselin~o A~encv. The name, address and phone number of Consumer Credit Counselin~o A~encies servin~o yom' County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housin~ Finance A~encv toll free at 1-800-342-2397. (Persons with iml~aired hearin~ can call (717~ 780-1869). This Notice contaius important legal information. If yon 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 _aD.JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DEl(ECHO A CONTLNUAR XqXqJENDO EN SU CASA. SI NO COMPRENDE EL CONTENYDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLANk4NDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN C)d/GOS AL NUM~ERO MENCIONADO AJLRIBA. PL~EDES SER ELEGIBLE P.&IL4 UN PRESTAMO POR EL PROG1L&MA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTA,NCE PROGIL4,M" EL CUAL PUEDE SALVAR SU CASA DE LA PERDEDA DEL DERECHO A REDIMIR StY I~IPOTECA. F~O, Box 171 I, HARRISBURG, PENNSYLVANIA 1710E;-1711 HOMEOWNER'S NASIE (S): _Lisa Trolinger PROPERTY ADDRESS: _615 55' Pine Street, 511 Holl5 Si)rings, Pa 1 7(165 MAILING ADDRESS: 615 55,' Pine Street, hit Holly Springs, Pa 17065 LOANACCT,N O.: 5551000089 ORIGINAL LENI)ER: _55:aypoinl Bank CUI{RENT LENI)ER/SERXqCER: Wavpoinl Bank HOMEOVYNER S EMERGENC5~ MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINA~NCIAL ASSISTA~NCE WHICH CAN SAV"E YOlff{ HOME FROM FORECLOSURE ANq) HELP YOU MAKE FUTtrq'dE MORTGAGE PAYMENTS IF 5zOU COMJ'LY WITH THE PROVISIONS OF THE HOMEOWNER'S E!VYERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGHgLE FOR EMEI~GENCY MORTGAGE ASSISTA~NCE IF YOL_IR DEFAULT H_A~S BEEN CAUSED BY CLRCLTMSTA_NCES BEYOSFD YOUR CONTROL, · IF YOU p~a.x,% A REASONABLE PROSPECT OF BEING _ABLE TO PAY YOUR MORTGAGE PAYYYENTS, AND · IF YOU _MEET OTHER ELIGIBILITY REQL~R.EM]ENTS ESTABLISlq~D BY TIlE TEMPORa, RY STAY OF FORECLOStrRE---Under the Act. you are emitled to a temporaD, stay of foreclosure on your nmrtgage for th/try- (30) days from the date of this Notice. During that time you must an'ange and attend a "face-to-face" meeting with one of the consumer credit counsetiug agencies listed at the end of this Notice. THIS MEETING MUST OCCUR ~VITHEN TI-YE NEXT THIRTY (30) DAYS. II~ YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF Tills NOTICE CALLED "HOW TO CUqRE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE LIP TO DATE. CONSITMER CREDIT COUNSELING AGENCYES---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 tlmv (30) days after the date of this meeting. The names, addresses and tele;~hone numbers of desmmated consumer credit counselina a~encies for the county in which the l>roDerrv is located are set forth at the end of this Notice. It is on]y necessary to schedule one fhce-to-face meeting. Advise your lender mm~ediate]¥ of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in deSault for the reasons set forth later in this Notice (see following pages for specific intbmnation about the nature of yom' default.) I£you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance fi'om the Homeowner's Emergency Mol~.gage Assistance Progq'am. 'Fo do so, you must fill out. sign and file a completed Homeowner's Emergency Assistance Pro,'am Application with one o[' ~he designated consumc~ credit counselin$ agencies lisied a[ rise end oJ'ihis Notice. On]y consumer credi~ counseling agencies have applications }~)i- due pl'O~mnn and they will assist you iD SLIblnitfing a comp}ere application to tlae Pennsvb,ania Housing Finance Agency. Tour application MIJST be filed or posmmrked within thirly (30) days of?ur flute-to-[hoc meeting. 'lOU MUST FILE YOIIR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TIlE OTItER T1ME PERIODS SET FORTH IN THIS LETTER, FORECLOS[~ MAY PROCEED AGAINST YOI]~. HOME IMMEDIATELY AND YOE'R APPLICATION FOR MORTGAGE ASSISTA~NCE WILL BE DENIED. AGENCY ACTION---Available £unds £or emergency mortgage assistance are ye:T limited. The}, w/Il be disbursed by the Agency under fine eligibility criteria establishecl by the Act. The Penn?lvania Housing Finance Agency has sixB, (60) days to make a decision afker it receives your application. During that time, no fbreclosure proceedings will be pm'sued against you if you have met the tnne reqmrements set fo~-~h above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: PF YOU ARE CURRENTLY PROTECTED BY THE FILLN'G OF A PETITION IN B,~NKRI~TC'i, THE FOLLOY~TNG PAINT OF THIS NOTICE IS FOR LN~ORMATIONI PURPOSES ON%Y _~ND SHOULD NOT BE CONSH)ERED AS .4~N ATTEMPT TO COLLECT THTE DEBT. (IIyou have flied bankrnptcy .~ou can still apply for Emergenc.~ Mortgage Assistance } HOW TO CITRE YOUR MORTGAGE DEFAULT (Brin,o it up to date]. NATURE OF TIlE DEFAULT---The MORTGA.JI~ oebt helu by the above lender on yom- property located at: _ 615 W Pine Street, Mt Holly Springs, Pa 17065 IS SERIOUSLY LN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAh.2ViENTS for the £ollowi. ng months and the following amounts are now past due: _Payments of $457.62 due each for flue months of Augusl.. September and October ,00=. B. Other charges: _Late Charge $137.28 TOTAL AMOUNT PASTDUE: _$1.510.14 YOU HAVE FAILED TO T~adLE THE FOLLOWLNG ACTION: HOW TO CURE THE DEFAULT---You ma_v cure the de±hult within THIRTY (30) DAYS of the date of this notice BY PAYENG THE TOTAL AxMOtLNT PAST DUE TO THE LENT}ER, WHICH IS $1,510.14 PLUS .~'4Y MORTGAGE PAh~Vi. ENTS AND LATE CFLARGES W'blICH BECOME DUE DULLING THE THIRTY (30) DAY PERJOD. Payments must be made either by cash. cashier's check. ce:tilled check or ntonev order made l~avahle and sent to: Wa'vT~oint Bank 449 Eisenhower Boulevard Hamsbunz. PA 17111 iF YOU DO NOT CURE THE DEFAULT---[£' you do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intends to exercise its rights to accelerate the morto, a~.e 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 morLgage m monthly insta]lments. If full payment of the total amount past due is not n3adu ~,~ithin THIIiTT /3Il} DAYS. the lender alsn intends to inst]-uc3 tis atiorncys to start {c~ai act~oo tn IF THE M()RTGAGE IS FORECLOSED UPON---The morlgaged propert3 will bc sold bb, the Sheri~X' to pay off the mortgage debt. Il" the lender refkrs your case tn its attorneys, bul you cure the delinclnency belbre the lender begins legal proceedings against you. you will still be required to pay the reasonable atlorney's rises tbal were actaall_', incurred, up to $502)0. However. if legal proceedings are started against you, you will bare to pa3 all reasonable atlorneys' fees actually iocurred by the lender even il' they exceed $50.00. Any at~on~cy's fees will be added to the amount you owe the lender, which may also incfttcle other reasonable costs. If you cm'e the default within the THIRTY (30) DAY Deriotk you will not be required to lmV attorney's fees, OTHER LENI)ER REMEDIES---The lender naa5' also sue you personall3 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 TH~TY t301 DAT period and foreclosure proceedings bare begun, you sfitl have fine rmht to cure the clefhult and i~reven/tbe sale at any time tm to one hour befbre the SheriWs sate. You may cio so by Daxinz the total amount then lmst due. ~Ius anx late or other chm-~es then dne. reasonable a~ornev's fees anc~ costs connectecl with the Foreclosure sale ancl anv other costs connected with the Sheriffffs Sale as sDeci~ed in writint by the lender and by Del-fOn~12n2 any other reouirements under the mortffa~e. 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. EARLEEST POSSIBLE SltERIFF'S SALE DATE--It is estimated that the earliest date that such a Sherif£s Sale of the mortgaged prope~Xy could be held would be approximately tbur months h'om the date of this Notice. A notice of the acrual date of the Sheriffs Sale wil! be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You nray find out at any time exactly what the required payment or action will be by corm-acting the lender. HOW TO CONTACT TItX~ LEN~DER: Name of Lender: Address: Phone number: Fax Number: Contact Person: ~raxq~oint Bank 449 Eisenhower Blvd.. Harrisbnrt. PA 171 t (7175 909~2710 or 1-866-929-76'46 ext. 2710 (7173 909-2780 Tara Poner~Trowbrid,oe EFFECT OF SHERIFF'S SALE---You should realize that a SherifTs Sale will end your ownership of the mo~lgaged property' and your rigbt 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. ASSI~PTION OF MORTGAGE---Yon may or X Ina3' not (CHECK ONE) sell or transikr your home to a buyer or n'ansferee who will assume the mortgage debt, provided that all the outstanding paymeats, 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. YOU MAY ALSO HA'~E ThrE RIGHT: TO SELL THE PROPERTY TCI OB~f AiN MONEY 'I O PAY (iFF THE MOPJI GAGE DEBT O1( T(i BOIt[(O\,\ MONEY FROM ANOTItER LENDLNG LNST]TUT1ON TO PAT OFF TItlS DEB']'. TO ItA\E THIS DEFAULT CUPuED BY ANT THJP,-D P.~d[TY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE ]~ST(-iP,~ED TO THE S.~k~[E POSITION AS IJ: NO DEFAULT H,4D OCCUPd?dED, LF YOL CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THiS PdGHT TO CUP~E YOUR DEF ~LTLT MOLLIE TH.MN THKEE T~'IES IN .A~.ry CALENDAR YE,~R.) TO ASSERT Tile NONTXiSTENCE OF A DEFAULT IN AbUt' FOPdSCLOSUP,~E PROCEEDING OR A~N5~ OTHER LA~ SUIT LNSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ~NT OTHER DEFENSE YOU BELEEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDEP,~4~ B,~_%rI,LRUPTCY LAW. TPT/n~k \;e:T truly yours, Tara Poner-Trowbridg~ Collection Counselor 7III h} funds are received and neSotiated in ]e%s fees and c:o~ta: Wavpc)int Bank ~e~R, cs the con{inue wkh legal proceedings pendin~ receip~ of {Ne {o{al amount due. Wayp i nt CUMBERLAND COUNTY CREDIT COUNSELING AGENCIES CCCS of Western Pennsylvania, Inc. 2000 Lingiestown Road Harrisburg, PA 17102 1-888-511-2227 FAX (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6t~ Street Harrisburg, PA 17101 (7! 7) 234-5925 FAX (717) 234-9459 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Community Action Cornm of the Capital Region 1514 Derry Street Harrisburg, Pa 17104 (717) 232-9757 FAX (717) 234-2227 RO Box 171[. HARRi~E]UR6 PEN~'~YLVAr,IIT, I710~.-171t , Wa oint November ]2, 2003 77~e subscriber below of the ~( S. Post Office located at 5]20 Der73' Street, HarrisbutT, PA ] 7J/J, does hereby cert~' thrz~ ~m em,elope was mailed with postage ?re]mid by First Class fi'onl the Wap])oint Bank addressed to Lisa D'o/inger, 615 W Pine Street. Mt Ho[(~' ] / 06.L proj)erly defiosi:ed ~ S Jk/c,. ~,o/ .t~z. e,3, t~his 1 ?m ? . U~ S. Post Office 5]20 Der~¢J Street Harrisburg, PA RO. Box 1711. HARRI~BURGi P~NNSYLVANIA 17105-1711 Ir_ -~-. .... ~ o~ t~/^vn~,~,~ fl-~l;;-cl2q. TFAZ~Rl · IN YORK AR~A 717/~315-z3~;OO . wwvv. wagpointbank.com ' · Complete items 1, 2, and 3. Aisc complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: PS Form 3811, August 2001 3. S ce Type ~ Registered 7003 2260 0B00 9701 2139 Domestic Return Receipt REGULAR .. SHERIFF'S RETURN - CASE NO: 2004-00704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS TROLINGER GALEN ET AL RONALD HOOVER Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon TROLINGER GALEN AKA GALEN G TROLINGER the Sheriff or Deputy Sheriff of who being duly sworn according to law, on the 25th day of February , 2004 by handing to - MORT FORE together with DEFEND~NT , at 2049:00 HOURS, at 34 S MIDDLESEX ROAD CARLISLE, PA 17013 JASON TROLINGER, ADULT SON a true and attested copy of COMPLAINT and at the same time directing His attention to the Additional Comments 615 WEST PINE STREET MT HOLLY IS VACANT. contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this ~.,~ day of ~roth~©tar~ · So Answers: R. Thomas K[ine o2/26/2004 WAYPOINT BANK Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2004-00704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS TROLINGER GALEN ET AL REGULAR VALERIE WEARY , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon TROLINGER LISA AKA LISA K TROLINGER the DEFENDANT , at 1418:00 HOURS, on the 23rd day of February Sheriff or Deputy Sheriff of who being duly sworn according to law, 803 WALNUT BOTTOM ROAD by handing to together with at CARLISLE PEDIATRICS CARLISLE, PA 17013 LISA TROLINGER a true and attested copy of COMPLAINT - MORT FORE 2004 and at the same time directing Her attention to the contents thereof. Additional Comments LISA'S NEW ADDRESS IS 9 GOBIN DRIVE CARLISLE, PA. Sheriff's Costs: Docketing 6.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 23.59 Sworn and Subscribed to before me this 2,,-W~ day of ~ ~ V A.D. /Prothonotary · - So Answers: R. Thomas Kline 02/26/2004 WAYPOINT BANK By: /~ Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION -- MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS, No. 2004-00704 GALEN TROLINGER NK/A GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants CERTIFICATE OF SERVICF I HEREBY CERTIFY that on Mamh 22, 2004, a 10-Day Default Notice in the above-captioned matter was mailed to Defendant, Lisa Tmlinger a/k/a Lisa K. Trolinger, by regular mail, postage prepaid. A true and correct copy of the 10-DAY Default Notice is attached hereto and incorporated by reference. Dated: March 22, 2004 By:. ~/~~ Benjamih F.~ Rigg~, ~'r. Attorney for Plaintiff P.O. Box 17'11 Harrisburg, PA 17105-1711 Phone: (7171) 815-4518 I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION -- MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. No. 2004-00704 GALEN TROLINGER NWA GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants TO: Lisa Trolinger a/k/a Lisa K. Trolinger 9 Gobin Drive Carlisle, PA 17013 DATE OF NOTICE: March 22, 2004 NOTICE Dated: March 22, 2004 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 NOTICE 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 /¢ Benjamin Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 7203(I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION -- MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION : HARRIS SAVINGS BANK Plaintiff VS. GALEN TROLINGER NK/A GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants No. 2004-00704 Dated: Mamh 22, 2004 CERTIFICATE OF SERVICF I HEREBY CERTIFY that on March 22, 2004, a 10-Day Default Notice in the above-captioned matter was mailed to Defendant, Galen Trolinger a/k/a Galen G. Trolinger, by regular mail, postage prepaid. A true and correct copy of the 10-Day Default Notice is attached hereto and incorporated by reference. Benjamin F. P, iggs, J~'"" Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION - MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. GALEN TROLINGER NK/A GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants No. 2004-00704 TO: Galen Trolinger a/k/a Galen G. Trolinger 34 S. Middlesex Road Carlisle, PA 17013 DATE OF NOTICE: March 22, 2004 NOTICE Dated: March 22, 2004 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 NOTICE 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Benjamin F Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA, 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION--MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS, GALEN TROLINGER NK/A GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants No. 2004-00704 PRAECIPE TO ENTER JUDGMENT To the Prothonotary: ENTER JUDGMENT in the above case for failure to file, or enter, a timely Answer to Plaintiff's Complaint in Mortgage Foreclosure against Galen Trolinger a/Ida Galen G. Trolinger and Lisa Trolinger a/Ida Lisa K. Trolinger in favor of VVaypoint Bank, f/Ida York Federal Savings and Loan Association and Harris Savings Bank for the following: Amount Due Per Complaint .......... $57,822.56 Interest from 1/28/04 through 4/14/04 (inclusive) at $9.8990 per diem ...... $ 772.12 Late Charges from 1/28/04 through 4/14/04 (inclusive at $45.76 per month) ........ $ 137.28 TOTAL AMOUNT $ 58,731.96 with interest from April 15, 2004 at such rate or rates established by Plaintiff pursuant to the terms of the Note currently $9.8990 per diem, from April 15, 2004, late charges from April 15, 2004 at 5% of the monthly payment amount, currently $45.76 per month, attorney's fees, costs of suit and other charges collectible under the Mortgage; and for any and all other relief as the Court deems appropriate. DATE: By: ~ ~/'~/~ Benjamin F,~R gs, J ,~ Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 (717) 815-4518 I.D. No. 72030 ~ lq ,2004 Judgment entered by the Prothonotary this day accordirlg to the tenor of the above statement. Pmthono~ar~j ]:N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION--MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. No. 2004-00704 GALEN TROLINGER A/K/A GALEN G. TROLINGER LISA TROLINGER AJK/A LISA K. TROLINGER Defendants TO: Lisa Trolinger a/k/a Lisa K. Trolinger 9 Gobin Drive Carlisle, PA 17013 DATE OF NOTICE: March 22, 2004 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 NOTICE 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~ ...~ Dated: By:;J ~.,~ ._~;:~// March 22, 2004 Benjamin F.'~;g;'~-'J Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105~1711 Phone: (717) 815-4518 I.D. No. 72030 ]:N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION -- MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION HARRIS SAVINGS BANK Plaintiff VS. : No. 2004-00704 GALEN TROLINGER A/K/A GALEN G. TROLINGER LISA TROLINGER A/K/A LISA K. TROLINGER Defendants TO: Galen Trolinger a/Ida Galen G. Trolinger 34 S, Middlesex Road Carlisle, PA 17013 DATE OF NOTICE: March 22, 2004 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 NOTICE 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3i66 // --,~" ~/ ~ Dated: March 22, 2004 By: '/~ ~'~;~2'¢/ Benjamin F': Riggs,~z/ Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 Phone: (717) 815-4518 I.D. No. 72030 Galen Trolinger a/k/a Galen G. Trolinger 34 S. Middlesex Road Carlisle, PA 17013 OFFICE OF THE PROTHONOTARY Cumberland County Court House One Courthouse Square Carlisle, PA 17013 Telephone: (7'17)240-6195 Da~: No: 2004-00704 RE: VS. WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK, Plaintiff GALEN TROLINGER A/WA, GALEN G. TROLINGER and LISA TROLINGER A/K/A LISA K. TROLINGER, Defendants (x) (x) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $58,731.96 on A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary Civil Div. a If you have any questions concerning the above case, please contact the following party: Benjamin F. Riggs, Jr. Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 (717) 815-4518 I.D. No. 72030 (This Notice is given in accordance with Pa.R.C.P. 236.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION- - MORTGAGE FORECLOSURE WAYPOINT BANK, F/K/A YORK FEDERAL SAVINGS AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff VS. No. 2004-00704 GALEN TROLINGER NK/A GALEN G. TROLINGER LISA TROLINGER NK/A LISA K. TROLINGER Defendants Commonwealth of Pennsylvania County of York AFFIDAVIT OF NON-MILITARY SERVICE Before me, a Notary Public for York County, Pennsylvania, personally appeared Benjamin F. Riggs, Jr., Attorney for the Plaintiff in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the Defendants above named are not in the military service of the United States of Amedca, that he has personal knowledge that Defendant, Galen Trolinger a/k/a Galen G. Trolinger's last known address is 34 S. Middlesex Road, Carlisle, PA 17013 and Defendant, Lisa Trolinger a/k/a Lisa K. Trolinger's, last-known address is 9 Gobin Ddve, Carlisle, PA 17013. Sworn and subscribed before methis /~' dayof/~/?/, 2004 ~ My Commission Expires By: Attorney for Plaintiff P.O. Box 1711 Harrisburg, PA 17105-1711 (717) 815-4518 I.D. No. 72030 Notarial Seal Dawn M. Guticrrez, Notary Public Cty of York, York County My Commission Expires Apr. 15, 2006 Member, pennsylvania Association ot Notaries