HomeMy WebLinkAbout10-2078. GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
WWW.GOLDBECKLAW.COM
F I
'OF 114E P ; T! vaTAN
2010 MAR Zf AM 11: 2 7aS
rJC L 441
GREEN TREE SERVICING
1400 Turbine Drive
Rapid City, SD 57703
Plaintiff
VS.
ADRIANNE DELTORO
KENNETH P. URSIN
Mortgagors and Record Owners
5020 Mendenhall Drive, Unit 150
Mechanicsburg, PA 17050
Defendants
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term 10 -, -b 7 ?rJv'
t ANN; MOR TGA(3E
FORE(%f ost) 4
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue T?' ?? P7
Carlisle, PA 17013 ck330„7
P 4r- X3 ?'Yiff
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGF,NCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website http://www. hp fa.org/consumers/homeowners/real aspx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentionggoldbecklaw.com.. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 94297FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GREEN TREE SERVICING, 1400 Turbine Drive, Rapid City, SD 57703.
2. The names and addresses of the Defendants are ADRIANNE DELTORO, 5020 Mendenhall Drive Unit
150, Mechanicsburg, PA 17050 and KENNETH P. URSIN, 190 W Falls Road, West Falls, NY 14170,
who are the mortgagors and record owners of the mortgaged premises hereinafter described.
3. On November 30, 2006 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to NATIONAL CITY MORTGAGE A DIVISION OF NATIONAL CITY BANK,
which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1974
Page 4920. The mortgage has been assigned to: GREEN TREE SERVICING by assignment of
Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage
obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will
be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage
and assignment(s) are matters of public record and are incorporated by this reference in accordance with
Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to
attach documents to pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for February 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ..................................................................................$194,612.32
Interest from 01/01/2009 through 02/28/2010 at 7.0600% .....................$15,963.59
Per Diem interest rate at $37.65
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$9,730.62
Late Charges from 02/01/2009 to 02/28/2010 .............................................$465.85
Monthly late charge amount at
Costs of suit and Title Search (Estimated) ...................................................$900.00
Insurance Balance .....................................................................................$5.228.42
$226,900.80
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
:Plaintiff is not seeking a judgment of personal liability (or an "in personam 'judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $226,900.80,
together with interest at the rate of $37.65, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the o gage and Sheriff's Sale of the Property.
By:
GOLDBECK ERTY & MCKEEVER
Michael McKee Pa. ID 56129
Gary McCafferty Pa. ID 42386
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
ATTORNEYS FOR PLAINTIFF
VERIFICATION
1,_ 40141 malkiICU , as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements therein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
17 V1
Date: 3
#94297FC - ADRIANNE DELTORO and KENNETH P. URSIN
5020 Mendenhall Drive Unit 150 Mechanicsburg, PA 17050
Prepared by and Return To:
Manuel Gomcz
Green Tree Servicing LLC
7360 S. Kyrene Road
Tempe, AZ 85283
Acct No. 89672053
ASSIGNMENT OF MORTGAGE
For value received, the undersigned holder of a Mortgage (herein "Assignor whose address is do 7360 S Kyrene
Rd Tempe, AZ 85283, does hereby grant, sell, assign, transfer and convey, unto Green Tree Servicing LLC
(herein "Assignee"), whose address is 7360 S Kyrene Rd Tempe, AZ 85283, all beneficial interest under a certain
Mortgage dated 11-30-2006, made and executed by Kenneth P Ursin and Adrianne Deltoro, mortgagor(s), upon
the following described property situated in Macbanicsburg, State of PA:
See Attached Exhibit "A" for Legal Description.
such Mortgage having been given to secure a payment of $198,964.00, which Mortgage is of record in Book,
Volume, or Liber No. 1974, at page 4920, or as No. NIA in Cumberland County, State of PA, together with the
note(s) and obligations therein descnbed, the money due and to become due thereon with interest, and all rights
accrued or to accrue under such Mortgage.
TO HAVE AND TO HOLD the same unto Assignee, its successor and assigns, forever, subject only to
the terms and conditions of the above-described Mortgage.
IN WITNESS WHEREOF, the undersigned Assignor has executed this Assignment of Mortgage on
January 27, 2010.
IJIX?, 6/ ?11 t
Witness: Man la Grijalva
Witness: than Navarro
State of Arizona
County of Maricopa
PNC Bank, N.A. successor by merger to National City
Mortgage a division of National City Bank by its
attorney in fact Green Tree Servicing LLC
BY?
Tashona Cox, Authorized Agent
On January 27, 2010, before me, the undersigned, personally appeared Tashona Cox, authorized agent for PNC
Bank, N.A. successor by merger to National City Mortgage a division of National City Bank by its attorney in fact
Green Tree Servicing LLC, personally known to me or proved to me on the basis of satisfactory evidence to be the
individual(s) whose name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they
executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the
individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument and that such
individual made such appearance before the undersigned in the state of Arizona, and the county of Maricopa.
OFFtGtAL 5l AL iyl?, O ry Public
.., MA1?lUEL C30tVli+.Z
Public - Shntw of lkts+ona
N°' nom, ,wcoP,a courmr
Gomm. Fjtpcros Jan. 1 S, 20i 4
Exhibit "A"
The land refened to in Ibis Cornmitrnent is described as fdkms:
ALL TMT CERTM Unit. belt Unit No. 150 (the "Unit" ), of to OXXIs 61 grandyvwna, a Tovvritborne
Condominium (tire TmWornMiuW1 koded in Mar Won T4 P. CW&Wfand County, Pennsylvania, Much
Unit is designated in the Dedaratlon of Condontinium of *a Coatis at 8randywkxN a Towvt wM6 Condominium
(the •Deciaratlon of Candanbbium") and DWWOSarn pWft and Plants recorded in the Office of Me Cwrbp&Wd
County Reoorder of Deeds in M#cWarneous Book 721. Page 47,98 and Ighs of Way Platt Book 13, Page 119
respFadively, logether with any and A anwWkntet thwrelo.
TOGETHER v?ilt. Ole irbdiv4* peraw4W k*wast M the Corrunon EhwwrAs appurtenant to the the Unit as
shores pwftutasiy setforth into sloe $ald Dealaradon of Condominium. as last arnended.
TOGETHER with the right to use the Limited Common Elernerb a*lcabk too do Unit being vonve* therein,
prrmwnt to the Qedwffion of Condominium and Dedwation Plift and Plans, s3 last .
UNDER AND SUBJECT to any and all covenants, ponditnns, rv*k i ms, rights of way, easements and
agreements of record in the atoressid Offim the afior+esaid Declaration of Condorinium, and madam Which a
phyAA fnspecoon or survey of #w Unit and Common Elements would disclose.
8MG part of the earn* prerrAses which Mom T. Lehman and Pearl E. Lefhnner by bleed dated Feimrary 19,
20M and recorded February 24, 20M in the Of(iat of IN Cutthberland Gou* Recorder of Deeds in Record
Book 255, Page 4246, granted and convoyed unto Rshin0 Creek Vailay Associates, L.P.
ALSO BEING part of the same preys which Gladys M. Watts by dead dated September 30.2003 and
rewrded October B, 20Q3 in the OfGve of the Recorder of Deeds in Record Book 259. Page 3673, wed and
conveyed unto fihdbing Greek VaWW A?tas. L.P.
When Recorded Return To:
Green Tree Servicing LLC
Attn: Document Custody, T326
7360 South Kyrene Rd
Tempe, AZ 85283
lull
OFFICIAL RECORDS OF
HARICOPA COUNTY RECORDER
HELEN PURCELL
2010-0020811 01/11/10 02:35 PM
1 OF 1
pmoma n
LIMITED POWER OF ATTORNEY
TO: GREEN TREE SERVICING LLC
FROM: PNC Bank National Association (formerly National
City Mortgage)
DATED: 1/4/10
FOR: FNMA - National City Conversion (Nov 2009
FORM OF
LUKE" POWER OF ATI RNEY
LIMITED POWER OF ATTORNEY, dated as of November 7, 2009 (this
"Limited Power of Attorney"), granted to Green Tree Servicing LLC, a Delaware limited
liability company (the "Porch '), by each of PNC Bank, National Association, successor by
merger to National City Bank, a national bank organized under the laws of the United States
("PNC Bank"), and PNC Mortgage Services, Inc. (formerly known as National City Mortgage
Services, Tnc.), a Delaware corporation ("PNC Mortgage Services" and, collectively with PNC
Bank, the "Sellers" and each, a " elle j.
WITNESSETH:
WHEREAS, the Sellers and the Purchaser have entered into that certain Mortgage
Servicing Rights Purchase and Sale Agreement, dated as of October 9, 2009 (as amended,
supplemented or modified from time to time in accordance with its terms, the "Pu hase
Ag[eement"), providing for, among other things, the Purchaser's acquisition of the Servicing
Rights (as defined in the Purchase Agreement), the Servicing Files (as defined in the Purchase
Agreement) and all rights under the documents contained therein with respect to the servicing of
each related Mortgage Loan (as defined in the Purchase Agreement) (collectively, the "Servicing
Assets'); and
WHEREAS, the sale, transfer and conveyance of the Servicing Assets from the
Sellers to the Purchaser under the Purchase Agreement was consummated effective October 31,
2009;
NOW, THEREFORE, pursuant to the Purchase Agreement and for good and
valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Sellers
hereby agree as follows:
1. Definitions. Each capitalized term used but not defined herein has the
meaning given to such term in the Purchase Agreement.
2. Limited Power of Attorney. For the purpose of effectuating the efficient
servicing of the Mortgage Loans, each Seller hereby names, constitutes and appoints the
Purchaser as its duly authorized agent and attorney-in-fact, with full power and authority in its
name, place and stead (but on behalf and for the benefit of, and at the expense oC the Purchaser)
to (i) execute such deeds and other documents as are necessary to sell or convey real and
personal property securing the Mortgage Loans, including, but not limited to, signing deeds to
convey real property acquired through foreclosure of a Mortgage Loan; (ii) execute documents
and instruments necessary to release any and all Mortgages, security instruments, liens, security
interests or related documents with respect to the Mortgage Loans; (iii) execute documents and
instruments necessary to release all obligations under any promissory note or related documents
with respect to the Mortgage Loans; (iv) execute documents and instruments necessary to sign
subordination agreements and consent to easements related to the Mortgage Loans; (v) execute
such documents as are necessary to assign the Mortgage Loans; (vi) endorse checks and other
payment instruments that are payable to the order of such Seller and that have been received by
the Purchaser from Mortgagors or any insurer in respect of insurance proceeds related to any
Mortgage Loans; and (vii) execute such other documents as may be necessary or appropriate to
enable the Purchaser to carry out its servicing and administrative duties with respect to the
Mortgage Loans.
3. Purchase gSreement. The execution and delivery of this Limited Power
of Attorney by the Sellers shall not be (or be deemed) a waiver or discharge of any
representation, warranty, covenant or agreement of the Sellers or the Purchaser in or under the
Purchase Agreement (other than a discharge of the obligations of the Sellers under the Purchase
Agreement, if any, to execute and deliver this Limited Power of Attorney), and such execution
and delivery shall not be (or be deemed) a modification or amendment of any provision of the
Purchase Agreement in any respect. This Limited Power of Attorney is not intended to enlarge
or otherwise modify any rights transferred under the Purchase Agreement or to allow Purchaser
to take any action with respect to a Mortgage Loan not contemplated by the transactions under
the Purchase Agreement.
4, fridemniV- The Purchaser agrees to indemnify, defend and hold harmless
Sellers from any and all claims, liabilities, damages, losses or expenses (including, without
limitation, reasonable attorneys' fees) resulting from or arising out of any misuse of this Limited
Power of Attorney or Purchaser's willful misconduct, gross negligence and bad faith in its use of
this Limited Power of Attorney.
5. Tenn. This Limited Power of Attorney shall remain in effect until
Purchaser ceases to service any Mortgage Loan.
6. Waivers and Amendments. This Limited Power of Attorney may be
amended, modified, supplemented or restated only by a written instrument executed by the
Sellers and the Purchaser. The terns of this Limited Power of Attorney may be waived only by
a written instrument executed by the party waiving compliance.
7. Counterparts. This Limited Power of Attorney may be executed by the
Sellers in separate counterparts, each of which when so executed and delivered shall be an
original, but all such counterparts shall together constitute one and the same agreement, and all
signatures need not appear on any one counterpart.
8. Headings . The headings in this Limited Power of Attorney are for
convenience of reference only and shall not define, limit or otherwise affect any of the terms or
provisions hereof.
9. Successors and Assim. This Limited Power of Attorney shall inure to
the benefit of, and be binding upon, the Sellers and the Purchaser and their respective successors
and assigns; vi however, that the Purchaser shall not assign any of the rights under this
Limited Power of Attorney (except by merger or other operation of law) without the prior written
consent of the Sellers and any such purported assignment without such consent shall be void and
of no effect. Notwithstanding the foregoing, the Purchaser may assign its rights hereunder to one
or more of its Affiliates or any servicer that is a successor to the Purchaser.
-2-
10. Governing Law. This Limited Power of Attorney shalt be governed by
and construed and enforced in accordance with the Laws of the State of New York, without
regard to any conflicts of law rules that might apply the Laws of any other jurisdiction.
11. Irrevocable Power of Attorney. This Limited Power of Attorney is
irrevocable and coupled with an interest.
[Signature Page Follows]
-3-
IN WITNESS WHEREOF, the undersigned have executed and delivered this
Limited Power of Attorney as of the date first above written.
PNC BANK, NATIONAL ASSOCIATION,
successor by merger to National City
Bank
By: rX...?
Name: w--?-.- =tea.
Title: ?;feren Ili. Fsheid
S°.;lF?s i?i,_•. E' "'.°r4rtFt;
PNC MORTGAGE SERVICES, INC. (formerly
known as Na Id City Mortgage Services, Inc.)
By:
Name: _ - a . ??rhf is
Title:
State of 4W10 )
county of /r7oMl"ooA"Y) SS.
On ! 1 1 before me,.e Cnt? i? ?, Personally appeared
and , personally known to me (or proved
to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the
within instrument and acknowledged to me that he or she executed the same in his or her
authorized capacity, and that by his or her signature on the instrument the entity, on behalf of
which the person acted, executed the instrument
WITNESS my hand and official seal.
/Notary Public in and for said
County and State
JE A RF.IGELSPERGER
NOTARY PUBLIC
INANDFOR
TUESTATEOFOHIO
MY COMMISSION
EXPIRES
MAY 3, 2014
-4-
?f355s t?
F..v9«'T ?. 7 "L£R
nc or%DEP OF DE:'-D.:
2W6 GEC 4 Rol 3 03
Prq)orw By:
KAREN EVANS
5115 PEGASUS COURT STE #AS
FREDERICK MD 21704
Return To:
National City Hank
P.O. Sox 8800
Dayton, OR 45401-8800
Parcel Nwnher:
ovp)
Premims:
5020 UMMMALL DR, Unit 150,
MsCBANrCSBURG, Pennsylvania 17050
lb}psct Above 7U Lire For Recordin Dotal
MORTGAGE 0005029186
DUM-T1ONS
Words used in multiple sections of this document are defined below and other wards ace defined in Sections
3, 11, 13, 18, 20 and 21. Certain rates rcprding the usage of words used in this document are also Provided
in Section 16.
(A) "$ecarity br& meW means this document, which is dated November 30, 2006
together with all Riders to this document.
(B) "Borrower" is
K>3UnM p URSIN and ADRIANNE DELTORO
i
Borrower is the mortgagor tnxler this Security I nt.
(G) " " is National city mortgage a division of
National City Bank
PEYMYLVAltlA - SkVW FaMilyr - Fannie MAWTISddis Mae UNIFORM 14SMMENT Form 3039 UOt
04KPA) (ter,
P.a.,of ,e IOOYl: I VW mortgaW sokooft.1 ? (DW*21-7201 1% 1974PG4920
E.xhibitA
First American Title insurance Company
Commitment Plumber: 06589
9CHEDUL,IS C
PROPERTY DETION
The lend referred to in this Commitment Is described as follows:
ALL THAT CERTAIN Unit, being Unit No. i6o (do Vnif'), of the Courts at Brandywine, a Townhome
Condomkrkxn (the "Condomk9umll loMW In Hampden Townft, Cumberland County, Perrmylvenls, which
Unit Is dos*W d in the Declaration of Condominium of to Courts at Brandywine, a Townirome Condominium
(the "Deda?etlon of Cmion"n") and Dedgradon Plata and Plans recorded In the Cylotr of the Cuntbetfand
County Recorder of Deeds In Miscellaneous gook 721, Page 4M and RIW of Wary Plan Book 13, Page 119
resP y, Wgethar with any and all amendmavlts .
TOGETHER with the ird vkkw pwoentage interest in the common Elamu to s i parhmamt to the the unit as
more Particularly ad forth'ln the alloreeaid Declaration of CondomiMum, as last amended.
TOGETHER with the right to use the Limited Common Elements appllcatrle to the Unit being conveyed herein,
Pursuant to the Declaration of Condominium and Declaration Plate and Plans, as last amended.
UNDER AND SUBJECT b ww and all coverma. conditions, restrictions, rights of way, amsernenb and
agreements of record In the aforoesid Office, doe ai[oraanid Dedaradrm of Condominium, and mailers which a
Physical Inspection or survey of the Unit and Common I_iemerda would disdose.
B
2003 and recoximl EING port of the seine Premises which WBtam T. Ldow and Pearl E. Lehrner by deed dated February 19,
Book 255, Page 424524, 220M in the Me of the Cumberland County Recorder of Deeds in Record and eyed unto Fishing Crask Valley Assodaatas, L.P.
ALSO BEN G part of the same premises which Gladys M. Welts by deed dabd September 30, 20003 and
recorded Oclober 6, 2003 In the Opice of the Recorder of Deeds in Record Book 2W Page 3673. granted and
conveyed unto Fishing Creek Valley Aseodates, L.P.
I Certify this tD be wwrded
In Cumbedand County PA
Recorder of Dees'.
Tsai air. "
towed MMMs)
OKI974PG4940
Ex,hibit (B
DELTORO, ADRIANNE
ADRIANNE DELTORO
5020 Mendenhall Drive Unit 150
Mechanicsburg, PA 17050
File #: 94297FC
Sale date:
County: Cumberland
Property: 5020 Mendenhall Drive Unit 150 Mechanicsburg, PA 17050
ACT 91 NOTICE
DATE OF NOTICE: 02/05/2010
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
This is an official notice that the mortgage on your home is in default, and the
lender intends to foreclose Specific information about the nature of the default is provided in
the attached p4ges.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMMM) may be
able to help to save your home. This Notice explains how the pMgram works
To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this
Notice with you when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have M questions you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired
hearing can call (717 780-1869)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact any 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 comp rende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa Ilamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
Date: 02/05/2010
Homeowners Name: ADRIANNE DELTORO and KENNETH P. URSIN
Property Address: 5020 Mendenhall Drive Unit 150, Mechanicsburg, PA 17050
Loan Account No.: 89672053
Original Lender: National City Mortgage a division of National City Bank
Current Lender/Servicer: GREEN TREE SERVICING
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the_prop;M is located are set
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) You have the right to apply for financial assistance from the Homeowner's Emergency
Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency 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. To temporarily stop the lender from filing a foreclosure action, your
application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU
HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA
WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WELL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND
THESE TIME PERIODS. A LATE APPLICATION WELL NOT PREVENT THE LENDER
FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS
EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 5020 Mendenhall Drive Unit 150, Mechanicsburg, PA 17050 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:
(a) Monthly payment from 02/01/2009 thru 02/05/2010
(13 mos. at $1,331.07/month) $17,303.91
(b) Total Late charges $465.85
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $17,768.95
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $17,768.95, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
GREEN TREE SERVICING
1400 Turbine Drive, Suite 200
Rapid City, SD 57703
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to
accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also
intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Property.
IF THE MORTGAGE LS 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 brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
Period, you will not be required to nay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.
You may do so by paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would he approximately four (4) to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs 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 by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: GREEN TREE SERVICING
Address: 1400 Turbine Drive, Suite 200
Rapid City, SD 57703
Phone Number: 800-643-0202
Fax Number: 866-479-6843
Contact Person: Collection Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs 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
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
5
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.
Contact: Collection Department
Phone Number: 800-643-0202
HEMAP Consumer Credit Counseling Agencies
I Report last updated: U2942010 8:59:47 AM I
CCCS of Western PA DAUPHIN County
4402 Peach Street
CCCS of Western PA
, PA 16509
Eris, 166 9 2000 l.inglestown Road
88&6112227 ext Harrisburg, PA 17102
108
888.5112227 ext 888.511.2227
108 886.511.2227
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
814.337.6450
Community Action Commission of Capital Region
1514 Deny Street
Harrisburg, PA 17104
717.232.9757
Greater Erie Community Action Committee
18 West 9TH Street
Erie, PA 16501
814.459.4581
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
724.981.5310
SL Martin Center
1701 Parade Street
Erie, PA 16503
814.452.6113
CUMBERLAND County
CCCS of Western PA
2000 Unglesfoxn Road
Harrisburg, PA 17102
888.5112227
888.511.2227
Community Action Commission of Capital Region
1514 Derry Skeet
Harrisburg, PA 17104
717.232.9757
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.3422397
PHFA
211 North Front Street
Harrisburg, PA 17110
717.760.3940
800.342.2397
DELAWARE County
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
215.389.2810
American Credit Counseling institute
175 Strafford Avenue
Suite 1
Wayne, PA 19087
610.971.2210
888.212.6741
American Credit Counseling Institute
526-528 Dekalb Street
Norristown, PA 19401
610.971.2210
888212.6741
American Financial Counseling Services Inc.
1080 N. Delaware Avenue
Suile 200
Philadelphia, PA 19125
267.228.7903
800.490.3039
American Financial Counseling Services Inc.
405 West Germantown Pike
Nonistovm, PA 19403
267.228.7903
800.490.3039
American Financial Counseling Services Inc.
175 Strafford Avenue
Suite One
Wayne, PA 19087
267228.7903
800.490.3039
Page 8 of 21
HEMAP Consumer Credit Counseling Agencies
Report last updated: W912010 8:59:47 AM 1
American Red Cross of Chester FOB CDC
1729 Edgemont Avenue 1201 West Olney Avenue
Chester, PA 19013 Philadelphia, PA 19141
610.874.1484 215.549.8755
APM Germantown Settlement
600 W Diamond Street 5538 Wayne Avenue
Philadelphia, PA 19122 Bldg C
215.235.6070 Philadelphia, PA 19144
(267) 953-4615 215.849.3104
Carroll Park Community Council, Inc. HALE
5218 Master Street 167 W. Allegheny Avenue
Philadelphia, PA 19131 2nd FI
215.877.1157 Philadelphia, PA 19140
215.426.8025
CCCS of Delaware valley
113 East Main Street Housing Partnership of Chester County
2nd floor 41 West Lancaster Ave
Norristown, PA 19401 Downingtown, PA 19335
215.563.5665 610.518.1522
CCCS of Delaware Valley Media Fellowship House
1001 East Lincoln Rghway 302 South Jackson Street
Suite 102 Media, PA 19063
Coatesville, PA 19320 610.565.0434
215.563.5665
Northwest Counseling Service
CCCS of Delaware Valley 5001 North Broad Street
4400 North Reese Street Philadelphia, PA 19141
Philadelphia, PA 19140 215.324.7500
215.563.5665
Phiila Council For Community Advmnt
CCCS of Delaware Valley 1617 John F Kennedy Blvd
790 E. Market St. Suite 1550
Suite 170, Marshall Building Philadelphia, PA 19103
West Chester, PA 19382 215.567.7803
215.563.5665 800.930.4663
CCCS of Delaware Valley Urban League of Philadelphia
1608 Walnut Street 121 S Broad St
10th Floor 9th Floor
Philadelphia, PA 19107 Philadelphia, PA 19107
215.563.5665 215.985.3220
CCCS of Delaware Valley ELK County
280 North Providence Road
Northern Tier Community Action Corp.
Media, PA 19063
215.563.5685 P.O. Box 389
135 West 4th Street
Chester Community Improvement Project Emporium PA 15834
412 Avenue of the States 814.486.1161
PO Box 541
Chester, PA 19016 ERIE County
610.876.8663 Booker T. Washington Center
Diversified Community Services 1720 Holland Street
Dixon House Erie, PA 16503
1920 South 20th Street 814.453.5744
Philadelphia, PA 19145
215.336.3511
Page 9 of 21
HEMAP Consumer Credit Counseling Agencies
Report last updated: 1129/2010 8:59:47 AM
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
8885112227 ext
108
888.5112.227 ext
108
Greater Erie Community Action Committee
18 West 9TH Street
Erie, PA 16501
814.459.4581
St. Martin Center
1701 Parade Street
Erie. PA 16503
814.452.6113
Voices for Independence
1107 Payne Avenue
Erie, PA 16503
814.874.0064
800.838.9890
FAYETfE County
Action Housing, Inc
425 61h Avenue
Suite 950
Pittsburgh, PA 15219
4122812102
800.792.2801
Southwestern Pennsylvania Legal Services Inc.
45 East Main Street
Suite 200
Uniontown, PA 15401
724.439.3591
Tableland Services km
535 East Main Street
Somerset, PA 15501
814.445.9628
800.452.0148
FOREST County
Warren-Forest Counties Economic Opportunity Council
1209 Pennsylvania Ave, West
P.O. Boot 547
Warren, PA 16365
814.7262400
FRANKLIN County
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
717.637.3768
CCCS of Western PA
2000 UnglesloWnt Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
CCCS of Western PA
1 North Gate Square
#2 Garden Center Drive
Greensburg, PA 15601
888.511.2227
888.511.2227
Community Action Southwest
58 East Greene Street
Waynesburg, PA 15370
724.8522893
Fayette Co. Community Action Agency, Inc.
108 North Beeson Avenue
Uniontown, PA 15401
724.437.6050
800.427.INF0
NeighborWorks of Western Pennsylvania
710 5th Avenue
suite 1000
Pittsburgh, PA 15219
412281.9773
CCCS of Western PA
55 Cover Hill Road
Dallastown, PA 17313
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Deny Street
Harrisburg, PA 17104
717.232.9757
Maranotha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PA Interfaith Community Programs Inc
40 E High Sheet
Gettysburg, PA 17325
717.334.1518
FULTON County
CCCS of Western PA
55 Clover Hill Road
Dallastown, PA 17313
888.5112227
888.5112227
Page 10 of 21
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson , ..-
Sheriff FILED
p14' Qi cfljrltlr?f r(Ic Tt i. I ,1 ' ('fN0TARY
Jody S Smith
Chief Deputy 70 10 MAR 31 AIM 8: 18
Edward L Schorpp
Solicitor ; '.:UNITY
PEiM,,'SYE' ANA A.
Green Tree Servicing, LLC Case Number
vs.
Kenneth P. Ursin (et al.) 2010-2078
SHERIFF'S RETURN OF SERVICE
03/29/2010 07:58 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March
29, 2010 at 1958 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Kenneth P. Ursin, by making known unto Adrian ne ltoro, adult in charge
at 5020 Mendenhall Drive Unit 150, Mechanicsburg, Cumberland County, Penn nia 170,50 its content;
and at the same time handing to her personally the said true and correct a sa
AEL BARRI K, DEPUTY
03/29/2010 07:58 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March
29, 2010 at 1958 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Adrianne Deltoro, by making known unto herself personally, at 5020
Mendenhall Drive Unit 150, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at
the same time handing to her personally the said true and correct copy of the same. «..._..?
MICHAEL BARRI K, DEPUTY
SHERIFF COST: $53.00
March 30, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c'. Gciiry3uitr Sc?rr?ff_ 1?6^sa`=t. tnc.
KML LAW GROUP, P.C.
Suite 5000 - BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
GREEN TREE SERVICING
1400 Turbine Drive
Rapid City, SD 57703
Plaintiff
vs.
ADRIANNE DELTORO
KENNETH P. URSIN
(Mortgagor(s) and Record owner(s))
5020 Mendenhall Drive, Unit 150
Mechanicsburg, PA 17050
Defendant(s)
FROTHONO Tea , ;
'ZO?92 APR -3 AM 10: 5e-'
-*!UAPPPI L N n rrt'11?dT r+
P, IENNSYLVANI A
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 10-2078 CIVIL
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
KML LAW GROUP, P.C.
FWA GOJ BEVK NW,
By. ! 1 ?i
Mich 1 Mc ever a. ID 56129
Jay . Kivit a. ID 26769
Lisa Lee Pa. D 78020
Kristina Murtha Pa. ID 61858
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
Andrew Gornall Pa. ID 92382
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
TY & McKEEVER
KML LAW GROUP, P.C.
Suite 5000 - BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
GREEN TREE SERVICING
1400 Turbine Drive
Rapid City, SD 57703
Plaintiff
VS.
ADRIANNE DELTORO
KENNETH P. URSIN
(Mortgagor(s) and Record Owner(s))
5020 Mendenhall Drive, Unit 150
Mechanicsburg, PA 17050
Defendant(s)
CERTIFICATE OF SERVICE
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 10-2078 CIVIL
Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe
to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class
mail, postage pre-paid, on L
ADRIANNE DELTORO
5020 Mendenhall Drive Unit 150
Mechanicsburg, PA 17050
KENNETH P. URSIN
5020 Mendenhall Drive Unit 150
Mechanicsburg, PA 17050
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
KML LAW GROUP, P.C.
F/K/A GOLDBECK McCAFFERTY & McKEEVER
By:
An a M. Smith, Legal Assistant
asmith@kmllawgroup.com
215-825-6325 (Direct Phone)