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Home My WebLink About10-2980UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 IiCHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC Bank :COURT OF COMMON PLEAS NA ::CIVIL DIVISION 3232 Newmark Drive Miamisburg, OH 45342 ::Cumberland County Plaintiff v. - ? : 7+ Trisha Sholly Casner _ Marc Wayne Casner NO. ?p _aggo C?V, I Ie1w 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 O 717-249 -3166 800-990 -9108 4ga .00 NOA7f 1 &-* 15Dwea P'V4 a g15P8 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. The mortgage and Note were modified in accordance with the Modification Agreement recorded on 10/24/03 at Book: 703 Page 1306. The mortgage and Note were again modified in accordance with the Modification Agreement recorded on 1/18/07 at Book: 733 Page: 3221. Said Mortgage and Modification Agreement are incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 616 Coolidge Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland COUNTY: Cumberland DATE EXECUTED: 4/30/98 DATE RECORDED: 5/7/98 BOOK: 1451 PAGE: 926 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 4/24/10: Principal of debt due $138,899.47 Unpaid Interest at 6.7516 from 4/1/09 to 4/24/10 (the per diem interest accruing on this debt is $25.69 and that sum should be added each day after 4/24/10) 9,966.52 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $284.17 and that sum should be added on the first of each month after 4/24/10) 2,445.39 Late Charges (monthly late charge of $42.43 should be added in accordance with the terms of the note each month after 4/24/10) 297.01 Attorneys Fees (anticipated and actual to 5% of principal) 6,944.97 TOTAL $159,158.36 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $159,158.36 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY :l A L,J uJ V&UIy LAI-4 I o L(/ u Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Apr-29=2010 01:33pn From- At 1. that osain tMCt n N oP New CIS Cumhaim?d at pacet of lnd Show 10 'bo ? follow, Cc'?tY. PettnaYh+anul' mote ppttifcolasly botrndad and EIRGINNING at a Po1M on tits ado iy line of CWAWP Sirol wtuclt paint is one htmdtod AMY 5vuia tttast el?g the (16(» teat Ow of & ?tesetab CO- of Coolidge ttnd EaSl ., tctly um of Ca IMP Suamr Nou 044wa (52) does. 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Box 1820 Dayton, Ohio 45401-1820 March 19, 2010 49120-0000951-001-001-000-000-000 CASNER,TRISHA SHOLLY 616 COOLIDGE ST NEW CUMBERLND PA 17070-1423 1111111 7107 8381 6540 2104 2649 PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937) 910-1200 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 DATE: March 19, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home, This Notice explains how the program work c. 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 s ruing your o nty are listed at the end of this Notice. If you have my iuestions_ , may call the P n ylvani Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): CASNER,MARC WAYNE CASNER,TRISHA SHOLLY PROPERTY ADDRESS: 616 COOLIDGE ST LOAN ACCT. NO.: 0008975366 ORIGINAL LENDER: n/a CURRENT LENDER/SERVICER: INC Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'Ineeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (331 DAYS OF THF, DATE, OF TAic NOTIC`E_ TF VOTT T-)O DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"- EXPLAINS HOW TO BRING YO 1R MORT TAC?R 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 telenhonenumbers of designated consumer credit counseling agencies for the cou= in which the 12ronea is located are set forth at the end ofthis Notice. It is only necessaryto schedule one face-to-face meeting. Advise your lenderimmediatelvof 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 EmergencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency 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 forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED "TEMPORARY STAY OF FORECLOSURE"YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 616 COOLIDGE ST NEW CUMBERALND PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) May 01, 2009 to March 01, 2010 and the following amount(s) are now past due: Monthly Payments 1,132.76 Corporate Fees 0.00 Late Charges 254.58 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 36.00 Less Suspense Balance .00 Total Amount Past Due $12,750.94 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 $12,750.94, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pnymanta meat ha mama aithar hX naahiar's chock- nartifiar3 chock cash nr mnnag nrdpr mar3a payahla and Rant tn: PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR673 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 mortea?ed prove IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybefore the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default performing = other requirements ender the mortgage. Curing your default in the manner set forth in will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER : Name of Lender: PNC Mortgage Address: 3232 Newmark Dr. 1 -- 1 I µ---- - ---- Fax Number: 937-9104009 Contact Person: o ec ons Center E-Mail Address: oss. ga ion pncmo gage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgage property an your n t to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY QPNC MOK1'GAGL' P.O. Box 1820 Dayton, Ohio 45401-1820 March 19, 2010 49120-0000950-001-001-000-000-000 7107 8381 6540 2104 2625 PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937) 910-1200 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 CASNER,MARC WAYNE 616 COOLIDGE ST NEW CUMBERLND PA 17070-1423 DATE: March 19, 20 10 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have my Question- you y call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired heariniz can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): CASNER,MARC WAYNE CASNER,TRISHA SHOLLY PROPERTY ADDRESS: 616 COOLIDGE ST LOAN ACCT. NO.: 0008975366 ORIGINAL LENDER: n/a CURRENT LENDER/SERVICER: PNC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS, IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'ineeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THF, DA TV OF THIC NnTICV TF V01T T-10 DA1'E. THE PART OF THIS NOTICE CALLED "HOW TO THE YOUR MORTGAGE DEFAULT" FXPT ATLAS HOW O BRIN T YOUR MORTGAGE i JP TO QATF.. 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 cog= in which ich he property is located are set forth at the end ofthi. Notice. It is only necessaryto schedule one face-to-face meeting. Advise your lenderimmediatelvof 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 EmergencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency 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 forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED "TEMPORARY STAY OF FORECLOSURE"YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 616 COOLIDGE ST NEW CUMBERALND PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) May 01, 2009 to March 01, 2010 and the following amount(s) are now past due: Monthly Payments 1,132.76 Corporate Fees 0.00 Late Charges 254.58 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 36.00 Less Suspense Balance .00 Total Amount Past Due $12,750.94 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 $12,750.94, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pay mPnts miiat hp mado- Pi thpr by raahi Pr' G rhark rani fi orl rhonk raa nr mnna?4 nrrlar mardP pAgahl P and gent to PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR672 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 immediatelyand 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 prove IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey'sfees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at My time Ip to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due. plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing acv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER : Name of Lender: PNC Mortgage Address: 3232 Newmark Dr. Miamisburg, OH 45432 Phone Number: 1-800-523-8654 Fax Number: -9104 Contact Person: Collections Center ail Aaaress: Loss.munganonLpncmortgage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgage property an your n t to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a buyer or transferee who vtn assume the mortgage debt, provideU 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY k f L,4 I ( / LfA k /V bV-." I V/u Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE r ~ UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 yleadiags@udren.com FOR PLAINTIFF PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff =Cumberland County v. Trisha Sholly Casner €NO. 10-2980 Marc Wayne Casner Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: t7 0 ~. -v r~-_~ ° ~ --+ ~ -,~ ~TZ CC1 r l , ,a» .. I ~ _ ~ '~~' ~. , - r c? ` ._.r Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: June 8, 2010 UDREN LAW OFFICES, P.C. BY : J' ~~~ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE y A N V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from retards maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Trisha Sholly Cosner Marc Wayne Canner Loan #0008975366 MJU #10040606-1 (Cumberland County, Pennsylvania} Name : Laura Cauper Tit 1 e : Authorized Officer Company : ~(1 ~ ~3~ Ic-~ rll4 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ' MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division PNC Bank € COURT OF COMMON PLEAS NA ;CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff 'MORTGAGE FORECLOSURE v. Trisha Sholly Casner E NO. 10-2980 Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: r-~- -~ *1 C~ © ..-~ ~ _., ` ,. <-r ~~ ~ : ~ ~ ~~ :. - - ~_: ._-- :~ _ -r- , , a' t._.. z.,y~ `, ~: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Trisha Sholly Casner and Marc Wayne Casner for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $159,158.36 Interest Per Complaint 1,156.05 From 04/25/2010 to 06/08/2010 Late charges per Complaint 42.43 From 04/25/2010 to 06/08/2010 Escrow payment per Complaint 568.34 From 04/25/2010 to 06/08/2010 TOTAL $160,925.18 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice. has been given in accordance with Rule 237.1, a copy of which is attached hereto. ~`ek. ao ~~ ~~ d~ c~~. ~s3 y ~2~ rr a~a~~Y.,_ - r ~lTN GE /'Y1.7.L mil, UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDIC TED DATE : ~~ ~/(~ ~ PR O UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08Q03-3620 856-669-5400 pleadings~udren.com PNC Mortgage, a division PNC Bank =COURT OF COMMON PLEAS NA :CYNIC DIVISION 3232 Newmark Drive Miamisburg, OH 45342 :Cumberland County Plaintiff v. ~ ~~ "~ :: r~ ._, -:5. ~i ~, ~' - ~ ~ ` `= ` ~ -,;_, - : F= f= r~ _ - ~~. .. Trisha Sholly Canner Marc Wayne Canner 5 N0. 10 'dL1'SO ~~Vt~ (Grp'`" 616 Coolidge Street New Cumberland, PA 17070 Defendantts) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or ather rights important to you. YOU SHOULD TAKE T$IS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEP$ONE 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 AGENGTES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ~`~~ y~~~G ~~' ,~n ~z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sher>ff ~¢~~~ at 4~rutrrk~rr,~fA~ Jody S Smith Chief Deputy ~ ~-~ rrt . ~ * '~ Edward [. Schorpp Solicitor ors:^~er ~ srs~u~ PNC Mortgage Case Number vs. Trisha Sholly Casner (et al.) 2010-2980 SHERIFF'S RETURN OF SERVICE 05/06/2610 05:45 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that an May 6, 2010 at 1745 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Trisha Sholly Casner, by making known unto Marc Wayne Casner, Husband of defendant at 616 Coolidge Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. TtM ,DEPUTY 05/06/2010 05:45 PM -Timothy Black, Dep^#y Sheriff, who being duly sworn according to law, states that on May 6, 20'10 at 1745 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Marc Wayne Casner, by making known unto himself personally, at 816 Coolidge Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. ~G~~ i~~ TIM C ,DEPUTY SHERIFF COST: $59.30 SO ANSWERS, ~~~ May 07, 2010 RON R ANDERSON, SHERIFF ?c; (:o~a~iYS:~te Sheriff, Te!racsoft, frr, ~ vt„/ `~ `~" `-~ ..r UDREN LAW OFFICES, P.C. MARK J. i3DREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #66408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-6'69-5400 #iflb4~606-7 PNC Mortgage, a division PNC Bank NA Plaintiff v. Trisha Sholly Casner Marc Wayne Casner Defendant(s) TO: Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Date of Notice: May 27, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10°2980 YOU ARE IN DEFAULT' BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR O$JECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUTRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMTNO DE DIEZ {ZO) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCTA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, TMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DTRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association. 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PTJRSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAYS FIRM IS DEEMED TO SE A DEBT COLLECTOR AND THE-~~PT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE~.I~OR TEAT PURPO C~ STUART~WINh'EG; ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARI{EMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. TI30MA5, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, Suite 2D0 C?2errv Hill. New Jersev D8003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75850 CEANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L, KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ Q8003 656-669-5400 #10A40606-'I _ PNC Mortgage, a division PNC Bank NA Plaintiff v. Trisha Sholly Casner Marc Wayne Casner Defendant(s) TO: Trisha Sholly Casner 616 Coolid e Street New Cumberland, PA 17070 Date of Notice: May 27, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2980 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 80D-99D-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10} DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PRETJBA ALGUNA DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE ST USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ~NCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR I~ID--~i3-5~S- UATTEMPT TO COLLECT A DEBT . ANY INFORMATION OBTAINED WILI~.,$~E"'GIBED FOR THAT P OBE. S'1'LTART V9TINNEG ES IRE LORRAINE DOYLEr, E QUIRE ALAN M. MINATO ES UIRE CHANDRA M. ARKEI~A, E~QUIRE LOUIS A. SIMONI, ESQQUIRE ADAM L. KAYES, ESQi~IRE MARGUERITE L_ THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, Suite 200 Cherry Hill, New Jersey 08003-3620 `UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - STUART WINNEG, ESQUIRE - LORRAINE DOYLE, ESQUIRE ALAN M. MTNATO, ESQUIRE CHANDRA M. ARKEMA, ESQUI: LOUIS A. SIMONI, ESQUIRE WOODCREST CORPORATE CENTER 7.11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 PNC Mortgage, a division PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. Trisha Sholly Casner Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Ohio COUNTY OF Montgomery ID #04302 ID #45362 - ID #34576 - ID #75860 [tE - TD #203437 - ID #200869 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO . i o --02`'~ ~v SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant{s} are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Trisha Sholly Casner Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Marc Wayne Casner Age: Over 18 Residence: As captioned above Employment: Unknown ame : C.aupe ~,~?~ T i t 1e : ~onze2l ~fficer Sworn to and su~sy"wed Company : ~C~~k ~ t'~A efore me this yy f 200. O y u 1 - r `~~~~ 9~' GAYENELL BEERS, Notary Public ' = In and for the State of Ohio a ~ ° ~ Mf' Camrrdssion Expires Feb. 2, 2015 ~ ••.. .'~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF -MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC '-COURT OF COMMON PLEAS Bank NA 'CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Trisha Sholly Casner Marc Wayne Casner €NO. 10-2980 Defendant(s) TO: Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Pr thonotary X Judgment by Default Money Judgment Judgment in Replevin ~~Q~~~ Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren Esquire Judgment for Possession Judgment on Award of Arbitration At this telephone number: 856-669-5400 ~~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division PNC Bank € COURT OF COMMON PLEAS NA `CIVIL DIVISION 3232 Newmark Drive Cumberland County Miamisburg, OH 45342 Plaintiff :MORTGAGE FORECLOSURE v. Trisha Sholly Casper € NO. 10-2980 Marc Wayne Casper 616 Coolidge Street New Cumberland, PA 17070 Defendant (s ) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Trisha Sholly Casper and Marc Wayne Casper for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $159,158.36 Interest Per Complaint 1,156.05 From 04/25/2010 to 06/08/2010 Late charges per Complaint 42.43 From 04/25/2010 to 06/08/2010 Escrow payment per Complaint 568.34 From 04/25/2010 to 06/08/2010 TOTAL $160,925.18 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice. has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS DATE: INDIC / D PRO ROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF . .MARK J. UDREN, ESQUIRE - ID #04302 ' STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. ;MORTGAGE FORECLOSURE Trisha Sholly Casner €NO. 10-2980 Marc Wayne Casner Defendant (s ) TO: Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment Money Jw _ Judgment _ Judgment _ Judgment Pro onotary by Default \ c ~ 3gment in Replevin L / Q/r~ for Possession `/ on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J Udren Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ••MARR J. UDREN, ESQUIRE - ID #04302 • STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC Bank € COURT OF COMMON PLEAS NA ;CIVIL DIVISION 3232 Newmark Drive Cumberland County Miamisburg, OH 45342 Plaintiff :MORTGAGE FORECLOSURE v. Trisha Sholly Casner ? NO. 10-2980 Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Trisha Sholly Casner and Marc Wayne Casper for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $159,158.36 Interest Per Complaint 1,156.05 From 04/25/2010 to 06/08/2010 Late charges per Complaint 42.43 From 04/25/2010 to 06/08/2010 Escrow payment per Complaint 568.34 From 04/25/2010 to 06/08/2010 TOTAL $160,925.18 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice. has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS DATE: INDI D PRO ROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID # 04302 STUART WINNEG, ESQUIRE - ID # 45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff =Cumberland County v. :MORTGAGE FORECLOSURE Trisha Sholly Casner €NO. 10-2980 rn-_ _o _~~ Marc Wayne Casner D f d -,,,' ° n ~~ e en ant (s ) - ~- - - ~ ~' 1; ,, W- ~ ~~~ ; ~~ PRAECIPE FOR WRIT OF EXECUTION +,r: ~: ; ~ r~- -n TO THE PROTHONOTARY: n{-' `~ Please issue Writ of Executio n in the above matter: ~ ` =„ ,. Amount due $160,925.18 Interest From 06/09/2010 2,363.48 to Date of Sale September 8, 2010 Ongoing Per Diem of 25.69 to actual date of sale including if sale is held at a Later date (Costs to be added) ~a~l.v~ ~~ ~~ SQ.3 v - Cc,~s F g2.ov _ ~1 l'Y . G U - [r ~ f !r e t a.s~ - UDREN LAW OFFICES, P.C.~j BY . ~ /~ _ ~ ~--- Attorneys for ~Xaintiff -~ MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE $~. S'C1 ~.`1. ~ ~s~~rs UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA =CIVIL DIVISION Plaintiff :Cumberland County v. MORTGAGE FORECLOSURE Trisha Sholly Canner €NO. 10-2980 Marc Wayne Canner Defendant (s) C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2980 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION PNC BANK NA, Plaintiff (s) From TRISHA SHOLLY CASNER AND MARL WAYNE CASNER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $160,925.18 L.L. $.50 Interest FROM 06/09/2010 TO DATE OF SALE 9/8/2010 -ONGOING PER DIEM OF $25.69 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,363.48 Atty's Comm Atty Paid $191.80 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JUNE 9, 2010 uell, Protho tary (Seal) R-);(ZUES`('ING PARTY: Name LQRRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, P.C. By: Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division PNC `COURT OF COMMON PLEAS Bank NA ;CIVIL DIVISION Plaintiff :Cumberland County v. ;MORTGAGE FORECLOSURE Trisha Sholly Casner €NO. 10-2980 Marc Wayne Casner Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Mortgage, a division PNC Bank NA, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 616 Coolidge Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Name Address Trisha Sholly Casner Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 616 Coolidge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mortgage, a division 3232 Newmark Drive PNC Bank NA Miamisburg, OH 45342 The Chase Manhattan Bank As Indenture Trustee c/o Residential Funding Corp 1301 Office Center Drive, #200 Fort Washington, PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 616 Coolidge Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 8, 2010 UDREN LAW OFFICES, P.C. BY : _ ~j Attorneys fo aintiff c MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(~udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff €Cumberland County v. Trisha Sholly Casner €NO. 10-2980 ., , Marc Wayne Casner ~ ~ C ~ Defendant (s) -~-,~; -~ TO: ALL PARTIES IN INTEREST AND CLAIMANTS =r;~ ,, ! `ri'm ~ ~ - -;- --, NOTICE OF SHERIFF'S SALE : `~ OF REAL PROPERTY ~_. -- `~ ~ ~, OWNER (S) : Trisha Sholly Casner --- -~ Marc Wayne Casner PROPERTY: 616 Coolidge Street New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 8, 2010, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. . • UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com FOR PLAINTIFF PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Trisha Sholly Canner €NO. 10-2980 Marc Wayne Canner Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Trisha Sholly Canner 616 Coolidge Street New Cumberland, PA 17070 n r- r 'ter>, m ,- ~` ~ ~,y .. ~. , - .~' ~__ 0 a c... ~}. N c, =, -~, ._..~ _s_ .,~ ~" fi"~ T tT i.7 i Your house (real estate) at 616 Coolidge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00am in the Commissioners Hearing Romm, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $160,925.18, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAYS A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GST LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff _'Cumberland County c p ,R v. ~ MORTGAGE FORECLOSURE ~~ `~''~ c_ ~ + ~} ~' r- Trisha Sholly Casner NO. 10-2980 ~~ ~o Marc Wayne Casner _ ~`~ ' _ ~- ~ Defendant (s ) ~' = »~ NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~ ~ TO: Marc Wayne Casper 616 Coolidge Street New Cumberland, PA 17070 Your house (real estate) at 616 Coolidge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00am in the Commissioners Hearing Romm, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $160,925.18, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OT~INER' S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actioa: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 ? STUART WINNEG, ESQUIRE - ID #45362 't •p LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 G 24 ?33 k CHANDRA M. ARKEMA, ESQUIRE - ID #203437 k 1 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 CWWX* CW C OT YLYAA 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division PNC Bank NA 'COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 :Cumberland Countv Plaintiff V. Trisha Sholly Casner Marc Wayne Casner =NO. 10-2980 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: August 10, 2010 UDREN LAW OFFICES, P.C. BY: ?- Attorneys f?r`Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division PNC Bank NA Plaintiff V. Trisha Sholly Casner Marc Wayne Casner Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION € Cumberland County NO. 10-2980 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Trisha Sholly Casner Marc Wayne Casner PROPERTY: 616 Coolidge Street New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on September 8, 2010, at 10:00am, at the Commissioners Hearing Room, 2"d Fl., Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. r ? ? m? 01 C n S9 p ? rr 3 N N CD (4 0 -? D ? ? y I © \? y Q ? I N ? d II ° C:) o r , y J tS ^ ? 3 v p r m " y N I o a I m cD 1 'o t9 ? I •G K G 1 ro O W O "C3 W O " , I ? I Cq ? ? a am C7 v _ -p Z ' r- o w , Iv Om0 ?.? ?IVZI,ro ?Z _ m A-1-?!Inwo n? (D Nn m? I? wo -z3 ro -' I =UfPs W=f N=N (0 ? m ? ? (J)C?y? y rn cn w ? m ? I w Grn ° '? c CD =-5 r« CI.O ri? ? ? ro -1 rtnQ7 y l ? fly ?D?N ? Cn?l?d?]r (? N ? co 0 .w I? 0 a I? Ta b ?N?? WAN ?O 1 v Wro ZI, v O N N. -tNJ-h - a I omRy ? ? ? 0 < (D o tt? w0 CD I .fl OI ??? ? pT? ? Z.° O? n I ? " ? 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PA TINA MARIE RICH OFFICE ADMINISTRATOR August 10, 2010 UDREN LA W OFFICES, A C. WOODCREST CORPORATE CENTER III WOODCREST ROAD SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856-669-5400 FAX. 856-669-5399 FREDDIE MAC PENNSYL VA NIA DESIGNATED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Mortgage, a division PNC Bank NA VS. Trisha Sholly Casner Marc Wayne Casner Cumberland County C.C.P. No. 10-2980 PENNSYLVANIA OFFICE 1I 6 - Dear Prothonotary: In connection with the above file, enclosed please find Praecipe to File Proof of Service for filing. Also enclosed is an extra copy of the Praecipe to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. ?erely yours, Dan Devlin Foreclosure Specialist /dad Enclosure CC: Sheriff of Cumberland County 15 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. Trisha Sholly Casner Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2980 PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with, regard to the captioned matter. Date: August 10, 2010 UDREN LAW OFFICES, P.C. _ BY: Attorneys for naintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE t"`t(' Mor7glate. t diw4A(m of PNCtia", k et. at.. Plaintiff(s) V s. ri'Jt .`;ht'-4tsCasnor,et..A,Dei`end<tnt(s) ,ti I ? t)stticti c Trey lip. i 1 Ni trt drt°eri R ..:ac. ?tti! t:`hsrrv°EItI1,tiJ !f$titl;.3t,ji Service of Process bi S International, Ltd. 1-800-328-71-71 - ? .,:tCS=-'..zrt,? tz.. _.?"+ FntertvtYionat !'kt.z? '800 (Acorn Rd. Minne:ttmhN, WIN :x:+439-3322 -..? ?PSI?iie#; t"S3I9-tkrl37t AFFIDAVIT OF SERVICE -- individual Servic. c?i r'roa-:-.s ctrl: it57tf Casner Court Ca,( No. 10-2980 ?:ttttc ofSer?s=er' -' , f ?' r-- tt,'tl, being clula• -cc :rr±_ and says that-,' th,: tim cl t, ?2 aw' .?. 7 not a mart t :`u t !):o ?int. o "(,n icc. tat on the ti,%v' C.- 1 - --- E7i:1C1 l0.t Serifi;': i C t?a`?t ..QOi7 Y},n,P StrY"er - to Nvvcr i )o. ttrttenrs S rv°ed: t : t:atc r,i ^ t< < t-, -ci tI'.,: a: tuft cl:; _a t ti as: ?Otice of Siteritt", Sate nfReal Prorlertl. e r4'{CL-' crf l'rrrsc? s t)T2:: A. uric and correct pop, `t -Oi:: ...t "`??i.. tt' -was sei i,- d on: larc: Wayne Casa r l'eeCott Served, tttrci - !'-%- nersonall-v deliven'WL ih?:.n'Into Ithe hands ofth_ rrrsun to h; ;Zfnrtd1 . Method of Service: t. Llixeriw, them i . '-21itafll?: ti['}](7 verii.(;-'. oi- ::`i m q11es1] i,*1Mi ?..?..:?_ th-i.1't::. she res id-, with .1 j:r rc aN-nv ?.':1Siler In anti istionshtp to the person is: - - Description offlem nt '11C lstu"can ruYC?Jc im) do,:wne:nts i follow,^ iZeCt lN 7rr' T Ot rirrtenLu: C'_ ? skin L olor ia,r Color Facial ',tJ 'F, the best 4fmv knowledge and k licE said pes-..,,n vcas no* Ott ?_? :? to ,h, `.hiita ry at Signature of Server: t r ,?:r,tnned declares under penalty of ` .;D?,,?sd%--C1 -,r,3 to t,: i, TL rtt::,ih? ? i.t, llt. iitt3oc71t2n i>, lni mid '411TCCI t? 1 `.PS lTrter-natioual. Ltd. vMT B e? PVC' a ttfcixiora of PNC I3 ?ti '` ? . ?a. aL, I'latntYfit'; "t rislz.. Slag!!, C'asum et a:.. Defersd:im Ms. DautelleDeviin t i t Woodcrest Rd., Ste. 200 Citerry H111. NJ (19003-362f) Service of Process itv S International, Ltd. 1-800-32s-7171 <r? , t u ',PS International Pt-uLt ' 7504 Glenro,?F V d r Minneapolis, 1i AEi li)A IT OF SERVICE -` !ndikridual .'... ?ff?y'S"}Ce` tii; t'r'd/Cf tiS 8I1. i __'t risil:i .`;'dolty Caisner ("hurt t :itik No, 10-2980 I _"tialaaf Ot ' 4'r• i,Y-: tindCT-SI ,n:' b:::Inn dul. c ..,.T?. £i r:: c.;?•. and .^i :3y Lht at. th 1111)is of z-r 4;11:1. ?}i. le8zal 3-',:: tllii al fl 13a.t't`t" ?:4 :Iil`-- c3?t.1 Date' l'iatae of Service: that on th' llav' of ?$ ?4't Place of Service: at Itt rr« t amhcrlclnd s"a ''ti 4, CR17i1(t;_'t, .1S7Y ei - Documents Served: tlt': underslp:_-J 5 ?d tl,_ tli+ lraact?t> 3 i ,`x ass Notice of Sheritt's 's ile ofRcat Propertt Sa'r6 f:: r.; 'r' 'es on: `i [rl teti£1 co-! 111 :t14J1"eSflttl (IICU,t1 'lii - s£ S S'i C tS[: J rklia Sholl-, C asner - Person `mot r ved, and . . _.- "... .. __ _._.. - _. - - - _ ,.. ... . i;x ptr onalh delis rind: deem into thu panel:, u the person to la : served- Method of `;erv-ice: 13v dehverinp diem Into the hinds of a pemm o suitable age, who verifi'tA or who upon questioning stated. that hc'shC resides, with "Trisha Sboily Casner at th--pl .. ofservice- .,,i rtlatlonsiilp to th:: Nnson is. Deo-r"iption of Person J(le P£_--,!n f"_?_'i?'I,n2 d£? -Urutn 1, 1S derSCTbetl.'- allt t; r {tCllCttl; t3C131YlC1ttS: II' i'liil' L al Fiair }:In ?C?li7£ ' _ " i' ,t7tJr£3 . AgL -i-lil '. To alt lac t (r;l r:-ttav'lecl e and 1%:: 1.. , , tiea' n i_ t:A i `v`ilitarl a tl LIMC :tt :; -- _ t ' 4 f Signmur,; ol'Serven 11`:cn :wfx?l t li ';,-: rn this t_ndersime do LrT - undcx ;a?,:nalty ofp:;Y,; li ` azsi ?;?a13 r drat thc.dow,oim 1, tnu:;j;i` ."rrtcC l.t? ci" at? !ti_ i lrtternsational, Ltd. OF PENW!YWAM;? y . 1? 7 B r? MARX J. UDREN* STUART WINNEG** LORRAINE DOYLE** ALAN M. MINA TO*** CHANDRA M. ARKEMA*** LOUISA. SIMONI*** ADAM L. KAYES** MARGUERITE L. THOMAS*** * ADMITTED NJ, PA. FL * ADMITTED PA -ADMITTED NJ. PA TINA MARIE RICH OFFICE ADMINISTRATOR August 10, 2010 UDREN LA W OFFICES, A C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRYHILL. NEW JERSEY 08003-3620 856. 669. 5400 FAX. 856. 669. 5399 FREDDIE MAC PENNSYL VA NIA DESIGNATED COUNSEL PLEASE RESPOND TO NEW JERSEY OFFICE Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Mortgage, a division PNC Bank NA vs. Trisha Sholly Casner Marc Wayne Casner Cumberland County C.C.P. No. 10-2980 To whom it may concern: PENNSYLVANIA OFFICE 215-.568-950V- In connection with the above captioned matter, enclosed please find the following: 1. Certificate of Service to be filed; 2. Copy of first page to be time stamped and returned to me in the enclosed self-addressed stamped envelope. Your assistance in. this matter is greatly appreciated. Sincerely yours, Dani 1 e. l in Foreclosure Specialist /dad Enclosures UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division PNC Bank NA Plaintiff v. Trisha Sholly Casner Marc Wayne Casner Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County ENO. 10-2980 CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of Notice of Sale upon the following person(s) named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxx Certified Mail other (certificate of mailing) Date Served: 7/19/2010 TO: Trisha Sholly Casner Marc Wayne Casner c/o Timothy J. O'Connell, Turner and O'Connell 4701 North Front Street Harrisburg, PA 17110 Esquire UDREN LAW OFFICES, P.C. BY Attorneys r' Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. 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Turner and O Connell OB°"NO 4701 North Front Street siaie: zip+ Harrisbur PA 17110 Jr 3 t A "C 9 aw ?i Certified Mail Provides: ¦ A mailing receipt s A unique identifier for your mailpiece r A record of delivery kept by the Postal Service for two years Important Reminders: s Certified Mail may ONLY be combined with First-Class Mailo or Priority Mails. r Certified Mail is not available for any class of international mail. e NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider insured or Registered Mail. ¦ For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece "Return Receipt Requested". To receive a fee waiver for a duplicate return receipt, a USPSO postmark on your Certified Mail receipt is required. ¦ For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement "Restricted Delivery". • If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. PS Form 3800, August '2006(Revese) PSN 7530-02-000-9047 m z ?Q $ ? ? U z CL a _L ?i m ¢ d xim m m a > a Iv m pE moE dj? Crr Z.9 oiPo C7 N ? U 'D ma 2 c ra C m cu. m m C.2 0 .. a w m ? 4) z c°ca C3 E m¢ m Mr .. 7 3« m m 0- t pavc caa c)ra aiQ `o N }Z ? ? C, E 3 g N v ro m v v m m 'a w w N 0 0 m N Q m U 42 f F- r?i ? M a? i? U) t1J c m C- ¢Oo ?U CU)tQO?C? Uo IU Q a) >,O ti i1 •C 'O i c O 21 L) ?C L =3 t0 k 71 } 13 Er r- m rq M L) O r_1 O O O O M r-q co E3 r- cc v Z N 7 Z m U c CV N O CL 9 Cr C 7 m ¢ U m E is 0 0 N 2 a U_ :o LL U) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. Trisha Sholly Casner Marc Wayne Casner :NO. 10-2980 Defendant(s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE 17) ,7 " '07 ?c +v Plaintiff, by its counsel, petitions the Court for a two (2) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 616 Coolidge Street, New Cumberland, PA 17070 was originally scheduled for September 8, 2010, then postponed to November 3, 2010, then postponed to January 5, 2011. 2. The Plaintiff seeks the postponement of the Sheriff's sale two (2) months to allow time to assess the possibility of loss mitigation. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. + 4 x? 4. No Judge has been assigned to this matter. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the March 2, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. .r BY: Nathan C. f, wire Attorney.far Plaintiff Local Couns Alan M. Mlnato, Esquire PA 10 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC ;COURT OF COMMON PLEAS Bank NA -CIVIL DIVISION Plaintiff :Cumberland County V. Trisha Sholly Casner Marc Wayne Casner NO. 10-2980 Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to assess the possibility of loss mitigation. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove particularly set forth in the motion, Plainti requests continuance of the Sheriff's Sale of premises, located at 616 Coolidge Street, New 17070, to the March 2, 2011 Sheriff's sale as Motion. stated, and as more Ef respectfully the mortgaged Cumberland, PA set forth in the Respectfully submitted, Nathan C. Wolf, Esquire Local Counsel UDREN LAW OFFICES, P.C. Attorney for,. P.la. htif f Alan M. Mtnato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com ATTORNEY FOR PLAINTIFF PNC Mortgage, a division PNC Bank NA Plaintiff V. Trisha Sholly Casner Marc Wayne Casner Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2980 CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriffs Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxX Regular First Class Mail Certified Mail Other Date Served: January 4, 2011 TO: Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 Nathan olf, Esquire Local Counsel Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 UDREN LAW OFFICES, P.C. BY _... Attorney for- R1.ajntiff Alan M. Minato, Esquire PA ID 75860 l JAN 0 4 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION (-s AND NOW, this day of January, 2011 , after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 616 Coolidge Street, New Cumberland, PA 17070, it is hereby ORDERED that the said Sale currently scheduled for January 5, 2011, is extended two (2) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for March 2, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the January 5, 2011 Sheriff's Sale. PNC Mortgage, a division PNC _ Bank NA 7z Plaintiff V. NO. 10-2980 t" Trisha Sholly Casner Marc Wayne Casner ZD Defendant (s) R D E R =w*i BY THE COURT: J. TO: Trisha Sholly Casner 616 Coolidge Street -led New Cumberland, PA 17070 (}?? ?Marc Wayne Casner GW 616 Coolidge Street T? New Cumberland, PA 17070 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff -in bin Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 5 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff Cumberland County rn .rx e Trisha Sholly Casner Marc Wayne Casner NO. 10-2980 Defendant(s) , PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Vim) J rv Plaintiff, by its counsel, petitions the Court for a two (2) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 616 Coolidge Street, New Cumberland, PA 17070 was originally scheduled for September 8, 2010, then postponed to November 3, 2010, then postponed to January 5, 2011. 2. The Plaintiff seeks the postponement of the Sheriff's sale two (2) months to allow time to assess the possibility of loss mitigation. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. _-; c; ::.'.7 4. No Judge has been assigned to this matter. 4 WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the March 2, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: , Nathan C. f, wire -Attorney for Plaintiff Local Couns Alan M. M,inato, Esquire PA 10 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC =COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. Trisha Sholly Casner Marc Wayne Casner :NO. 10-2980 Defendant(s) PLAINTIFF'S _MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to assess the possibility of loss mitigation. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 616 Coolidge Street, New Cumberland, PA 17070, to the March 2, 201'1 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY. Attorney for _P_la.iiztiff Alan M. M.inato, Esquire PA ID 75860 Natnan (-:. wolz, r.9(4uist-- Local Counsel UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff =Cumberland County V. Trisha Sholly Casner Marc Wayne Casner ::NO. 10-2980 Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: XXXX Regular First Class Mail Certified Mail Other Date Served: January 4, 2011 TO: Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 Nathan olf, Esquire Local Counsel Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 UDREN LAW OFFICES, P.C. -------- C BY ' Attorney for.P1a. nti.f Alan M. Minato, Esquire PA ID 75860 Is UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingo@udren.com PNC Mortgage, a division PNC :COURT OF COMMON PLEAS r.: Bank NA CIVIL DIVISION Plaintiff Cumberland County'' ti. 71; Trisha Sholly Casper ?_.. _ . Marc Wayne Casner NO. 10-2980 Defendant (s) z PETITION FOR POSTPONEMENT OF SHERIFF'S SALE ry Plaintiff, by its counsel, petitions the Court for a two (2) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 616 Coolidge Street, New Cumberland, PA 17070 was originally scheduled for September 8, 2010, then postponed to November 3, 2010, then postponed to January 5, 2011, then postponed to March 2, 2011. 2. The Plaintiff seeks the postponement of the Sheriff's sale two (2) months to allow time to assess the possibility of loss mitigation. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable Albert H. Masland, was assigned to this matter and granted Plaintiff's order to Postpone Sheriff's sale to March 2, 2011. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the May 4, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY : ? n2 ` t ?A' Attorney for Plaintiff CINI&O M. Arkems, Esquire PA iO 2037 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@u.dren.COm PNC Mortgage, a division PNC ;COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff ;Cumberland County V. Trisha Sholly Casner Marc Wayne Casner NO. 10-2980 Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter; the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to assess the possibility of loss mitigation. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 616 Coolidge Street, New Cumberland, PA 17070, to the May 4, 2011 Sheri-ff's sale as set forth in the Motion. Respectfully submitted, Natha C. off, Esquire Local Counsel UDREN LAW OFFICES, P.C. BY: Ptorney for P aintiff Ch4f** M. A*wn, Esquire PA 10 203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com PNC Mortgage, a division PNC ;COURT OF COMMON PLEAS Bank NA ':CIVIL DIVISION Plaintiff :Cumberland County V. Trisha Sholly Casner Marc Wayne Casner NO. 10-2980 Defendant (s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: March 1, 2011 TO: Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 N4-%f-Kan C W f, Esquire Local Counsel Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff Chsnft M. Arkema, Esquire PAID 203437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION PNC Mortgage, a division PNC Bank NA Plaintiff V. NO. 10-2980 Trisha Sholly Casner Marc Wayne Casner Defendant(s) O R D E R s" f AND NOW, this day of March, 2011 after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 616 Coolidge Street, New Cumberland, PA 17070, it is hereby ORDERED that the said Sale currently scheduled for March 2, 2011, is extended two (2) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for May 4, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 2, 2011 Sheriff's Sale. BY THE COURT Albert H. Masland J'. TO. ?Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Copley ma•led 311111 t ,a S A& SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff L ? t i±:t i [E1- Jody S Smith Chief Deputy Richard W Stewart Solicitor U "I PEN PNC Mortgage vs. Trisha Sholly Casner (et al.) Case Number 2010-2980 SHERIFF'S RETURN OF SERVICE 06/22/2010 03:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2010 at 1546 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Trisha Sholly Casner & Marc Wayne Casner, located at, 616 Coolidge Street, New Cumberland, Cumberland County, Pennsylvania according to law. 09/01/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/3/2010 11/02/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/04/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/02/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriff's Sale Continued to 5/4/2011 05/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $834.09 SO ANSWERS, August 09, 2011 RON R ANDERSON, SHERIFF SC"' L C Pal . "a/W _-) X30/-7 UDREN LAW OFFI7ES, P.C. MARK J.,UDREN,I ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF PNC Mortgage, a division PNC 'COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Plaintiff `-Cumberland County V. ;MORTGAGE FORECLOSURE Trisha Sholly Casner :NO. 10-2980 Marc Wayne Casner Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Mortgage, a division PNC Bank NA, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 616 Coolidge Street, New Cumberland, PA 17070 1. Name and address of owner(s) or reputed Owner(s): Name Address Trisha Sholly Casner Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 616 Coolidge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mortgage, a division 3232 Newmark Drive PNC Bank NA Miamisburg, OH 45342 The Chase Manhattan Bank c/o Residential Funding Corp As Indenture Trustee 1301 Office Center Drive, ##200 Fort Washington, PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address 49 None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 N Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 616 Coolidge Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 8, 2010 UDREN LAW OFFICES, P.C. BY: Attorneys fo aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC =COURT OF COMMON PLEAS Bank NA :CIVIL DIVISION Pla-ntiff :Cumberland County V. Trisha Sholly Casner NO. 10-2980 Marc Wayne Casner Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS I 7z, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY -= OWNER(S): Trisha Sholly Casner - Marc Wayne Casner PROPERTY: 616 Coolidge Street New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 8, 2010, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J.,UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division PNC =COURT OF COMMON PLEAS C- Bank NA = CIVIL DIVISION Plaintiff 'Cumberland County = V. ;MORTGAGE FORECLOSURE Trisha Sholly Casner NO. 10-2980 _ Marc Wayne Casner r.' Defendant(s) NOTICE OF ' -- 1 SHERIFF S SALE OF REAL PROPERTY TO: Trisha Sholly Casner 616 Coolidge Street New Cumberland, PA 17070 Your house (real estate) at 616 Coolidge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00am in the Commissioners Hearing Romm, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $160,925.18, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS''EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the She:-iff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner cf the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. MARK J.: UDREN, ESQUIRE - ID STUART WI-NNEG, ESQUIRE - ID LORRAINE DOYLE, ESQUIRE - ALAN M. MINATO, ESQUIRE - CHANDRA M. ARKEMA, ESQUIRE WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com #04302 #45362 ID #34576 ID #75860 - ID #203437 200 PNC Mortgage, a division PNC Bank NA Plaintiff V. Trisha Sholly Casner Marc Wayne Casner Defendant(s) ATTORNEY FOR PLAINTIFF .COURT OF COMMON PLEAS .CIVIL DIVISION 'Cumberland County :MORTGAGE FORECLOSURE :NO. 10-2980 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 C ?y z rte: c.? r? -c Your house (real estate) at 616 Coolidge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00am in the Commissioners Hearing Romm, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $160,925.18, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN-IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly =_nadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA NO 10-2980 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION PNC BANK NA, Plaintiff (s) From TRISHA SHOLLY CASNER AND MARC WAYNE CASNER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) ?:hat: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $160,925.18 L.L. $.50 Interest FROM 06/09/2010 TO DATE OF SALE 9/8/2010 - ONGOING PER DIEM OF $25.69 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - S2,363.48 Atty's Comm % Due Prothy $2.00 Arty Paid 5191.80 Other Costs Plaintiff Paid Date: JUNE 9, 2010 uell, Prothon taffy (Seal) By: Deputy REQUESTING PARTY: Name LORRAIINE DOYLE, ESQUIRE Address: UDR,EN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a-legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, Jul), 23, and July 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 4isa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 30 day of Jules 2010 Notary NOTARIAL SEA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Writ No. 2010-2480 Civil PNC Mortgage vs. Trisha Sholly Casner Marc Wayne Casner Atty.: Mark J. Udren ALL THAT CERTAIN tract or par- cel of land situate in the Borough of New Cumberland County, Pennsylva- nia, more particularly bounded and described as follow: BEGINNING at a point on the southerly line of Coolidge Street which point is 160 feet east of the southeasterly corner of Coolidge and Beckley Streets; thence along the southerly line of Coolidge Street North 62 degrees 30 minutes East, 50 feet to a point on the westerly line of a 20-foot wide public alley; thence along same South 27 degrees 30 min- utes East, 140 feet to a point on the northerly line of a 20-foot wide public alley; thence along same South 62 degrees 30 minutes West, 50 feet to a point; thence North 27 degrees 30 minutes West, 140 feet to a point the place of BEGINNING. BEING PREMISES KNOWN AND NUMBERED AS 616 COOLIDGE STREET. BEING KNOWN AS: 616 Coolidge Street, New Cumberland, PA 17070. PROPERTY ID NO.: 26-23-0543- 381. TITLE TO SAID PREMISES IS VESTED IN Trisha Sholly Casner and Marc Wayne Casner, her hus- band by deed from Trisha A. Sholly, now known as Trisha Sholly Casner, and Marc Wayne Casner, her hus- band dated 08/ 12/ 1993 recorded 08/31/1993 in Deed Book 111 Page 79.. Tile Patriot-News Co. 2020 `fechnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-•255-8213 CUMBERLAND CO. SHERIFF=S OFFICE CUMBERLAND COUNTY COURT HOUSE Z4t pNow you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/09/10 Sworn to a ' CsUbscn d before m `te/ h*?65 ,? f.? Notary Pub of August, 2010 A.D. COMMONWEALTH OF PENNSYLVANIA Sherrie LNotarial Seal Lower PaxtonKlsner' Notary Public My Comm"onTWP' Dauphln County Member, Penn Ares Nov. 26, 2011 svivanla Association of Notaries 07/16/10 07/23/10 AU. THAT CE1C3'11 Toft DR. PARCEL OF I sm* IN T MMUGH OF NtW CU)r(BISI, AND COUNTY, PENNSYLVANIA, ? Y FWIM BtR A BUt"(3 AT A'P( 3T ON THE SOUlMtLY LINE OF COOLMXF STREET WHICH POINT IS 160 FEET EAST OF THE SOU' HFAS'IF IYCLlMOF000LIDGE AND BECKLEY STREETS, THENCE ALONG THE SOUTHERLY LINE OF C001om STRUT NOM 62 DEGREES 30 mvAM EAST, 50 FEET TO A POINT ON T4 E'WVMy LANE OF A 20-FOOT WIDE Pt1 UC ALI EY, THENCE ALONG SAME SOUTH 27 DEGREES 30 MINUTES EAST, 140 FEET TO A POINT ON THE NORTHERLY LINE OF A 20-FOOT WIDE PUBLIC EkL3 E1?'}F>YE ALONG SAME EST DE " TO A POINT THE PLACE OF BEGiti!! M- BEING PREMASES JKNOWN_ AND NUA 7+S 616 . BEi 'rtgOW 1AS: 616, Coolidge Street New cwnbaiaad, PA 17070 PROPERTY ID NO:: 26.230543-381 TITLE TO SAID B IS VESTED IN TRA$HA.SMIY CAM AND MARC WAYNECAS E A%MfDBYDU FBOM TI;3 A X-Wly,1 WOWN. LK MARC AS UMAW 1,Y qMM UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 PNC Mortgage, <3 division PVC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION' .Cumberland County NO. 10-2980 c's cn v. Trisha Sholly Casner Marc Wayne Casner 616 Coolidge Street New Cumberland, PA 17070 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT A] TO THE PROTHONOTARY: x2cc 3 M DISCONTINUE WITHOUT PREJUDICE S -r rr c? CJ -r ?.1 P Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment. of your costs only. DATED: July 3, 2012 10040606-1 C,hna_ q. 5 o PO A77`l TA 775 gt,a77ss7