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HomeMy WebLinkAbout10-3008GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagors and Record Owners 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendants CAVIL ACTION; MORT FORFCLOSl1RE GA NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO O $9a.oo PA AT l C?? 5a897q Q,? cZ?Illo?a 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 defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. C4A..__ IN THE C6' PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. (0 -3ocag Civil (em Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.Dhfa.orWconsurners/homeowners/real. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.Dhiladelphiafed.orp-/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiong goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 97440FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY, 3232 New Mark Drive, Miamisburg, OH 45342. 2. The names and addresses of the Defendants are SUSAN B. MCGLONE, 1413 Silver Creek Drive, Mechanicsburg, PA 17050 and DONALD L. MCGLONE, 1413 Silver Creek Drive, Mechanicsburg, PA 17050, who are the mortgagors and record owners of the mortgaged premises hereinafter described. On May 23, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1813 Page 4618. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil. Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$188,359.24 Interest from 02/01/2009 through 04/21/2010 at 7.0000% ..................... $16,105.11 Per Diem interest rate at $36.12 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$9,417.96 Late Charges from 03/01/2009 to 04/21/2010 .............................................$134.48 Costs of suit and Title Search (Estimated) ................................................... $900.00 Pro Rata MIP/PMI ....................................................................................... $145.06 Escrow Advance .......................................................................................$3,739.70 Total Fees .......................................................................................................$79.50 Monthly Escrow amount $460.62 $218,881.05 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit 'B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $218,881.05, together with interest at the rate of $36.12, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure the Wrtgage and Sheriff's Sale of the Property. By: G GOLDS Michael AFFERTY & MCKEEVER Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 ,--Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATION The undersigned attorney for Plaintiff is authorized to make this verification and states that the facts set forth in the foregoing Complaint are true and correct to the best of his or her knowledge, information and belief The undersigned understands that statements made in this verification are subject to the penalties of 18 Pa.C.S.A. §4904. Date:' v5- 0 By: GOLDBECK MCCAF Y & MCKEEVER Michael McKeever D 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 ----?ristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff #97440FC SUSAN B. MCGLONE and DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 ExthibitA ' -EYMBIT "A" am ;War OMR1AU tract or parcel of land 'situate in ilawpdtn Township, cumhsrland qty, Pennsylvania, more particularly bounded and damewibed as follows, to wits 202M MM at a point an the southern right-of-way line or Senseman Road, a 50 foot Wide street, said point also being the northeastern property oo=?z of Lot, 6033 as shown an the final Phase 3 *V"ivieion plan of ry; ?home along the soutbe*n right-at-way line of sansaman Road, 1r41n' 82 degrees 45 minutes 18 meconda Mast, a divtonoe of 100.40 loot to a point oh the southern right-of-dray line of Sansoman Road, said point alsa, being the northwast wn eornnar of Lot 0990 T40enoe along the western property line at Lot tk38, i8auth 07 degrees 14 minutes 45 seconds Bast, a dittknoe of 90.00 feat to a point an t:ho northwestern property corner of Lot M37, said point also being the southwesters property corner of Lot 1381' Thanoa along the western property line of Lot 0137, south 57 40WOens 44natas 14 seconds Nest, a distance of 82.76 foot to a point on the na sastorin property ca;ger of Lot 036, said point also being the sou tRt71 property corner of Twat 1371 Thence Along the northarn property line of Lot 036, South 82 degrees 45 VdMItes 15 aaoends Nest, a 414 no* of 25.00 foot to a point on the northern property line of Lot 136,i said point also being the sontheastern corner of Lot 1331 Thanes along the eastern property line of Lot 133, Korth 07 degrees 14 minutes 45 seconds Nast, a distanoa of 125.o0 feet to a point on the southern rfgh?-of-tray line or B*nsalsan Road, said point being tha point and plane of hojinniaq. I Certify this to be recorders In Cumber??nd ('n._,? Recorder oC Dk' k_•C?a ?x?ai3?c4s? E.,X.ehibit (B ;? gar Mortgage P.O. Box 1820 Dayton, Ohio 45401-1 B20 Address Service Requested 02571.0000010-001-001-000-000-000 MCGLONE,SUSAN B 1413 SILVER CREEK DR MECHANICSBURG PA 17050-2086 Nabonat City Mortgage 3s?a NC-Afnafk rifeiC Mallang Address; Loan No: 0002202472 Current Servicer: National City Mortgage HOW TO CURS 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: 1413 SILVER CREEK DR MECHANICSBURG PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) 5 and the following amount(s) are now past due: Monthly Payments $1,805.46 Corporate Fees $0.00 Late Charges $159.96 Non-Sufficient Funds $0.00 Fax Fees $0-00 Property Inspection Fees $9.00 Less Suspense Balance $0.00 Total Due $9,196.26 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): 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 PAYING THE LENDER, WHICH IS $9,196.26, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD- Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: National City Mortgage Customer Counseling Department 3232 Newmark Dr Miamisburg, OH 45432 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter:( Do not use if not applicable). This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR673 t?4 Al Appendix A DATE: 06:29;2009 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 A ency. The name, address and ikon number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions' o?y call the Pennsylvania Housing Finance Ag ncv toll free at 1-800-342-2397. (Persons with impaired hearing an call 717) 780-13-U). 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 SOMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR «'IENDO EN SU CASA. Si NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLA-r+ ANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO AIENCIONADO ARRIBA. PUEDES 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. PAGEI OF4 HOMEOWNER'S NAML(S): -MCGLONE,DONALD L VICGLONE,SUSAN B PROPERTY ADDRESS: 1413 SILVER CREEK DR LOAN ACCT. NO.: 0002202472 ORIGINAL LENDER: n.a CURRENT LENDERISERVICER: National City 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 ti10RTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU 1ZAY 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-faee'inccting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE, IF YOU D NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE In' TO DATE. THE PART OF TINS NOTICE _ CALLED "HOW TO CURE YOUR MORTGAGF DFFAiITT" FXPi AMR, I IOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephonenumbers of designated consumer credit counseling agencies for the c ou ly . which the Froncrty is located are set forth at the end of his Notice. It is only necessary to schedule one face-to-face meeting. Advise your lenderimmediatelyofyour intentions- APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out., sign and file a completed Homcowncr'sEmcrgcncy 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 HEHAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A :NEETIIN"G WITH A CODII,SELING AGENCY PITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION, WITH PHFA WITHIN, 30 DAYS OF THAT ?MEETING, THEN THE LENDER WILL BE 7EA1PORARILY PREVENTED FROM'STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, Iii, THE SECTIONCALLED "TE_,IPORARYSTAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEAIAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FRO.41 STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TL1•fE BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. PAGE 2OF4 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 dccisionaftcr 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 FOLLOtYING PART OF THIS NOTICE IS FOR INFORNIATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have tiled bankruptcy you can still apply for Emergency Mortgage Assistance.) 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 toforeclose upon your mortgaged property IF THE MORTGAGE I FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay a rn y'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 T111RTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff=s Sale. You may do so by navine the total amount then nast thin nhic costs connectedwith the Sheriff'sSalc as specified in writing by the lender and by verforming any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of the Shcriff sSalc will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: National Citv Morteage Miamisburg, OH 45432 Phone Number: 1-800-523-8654 Fax Number: 937-9104009 Contact Person: Customer Counseling Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff sSale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at anv time- ASSUMPTION OF MORTGAGE --You may or may notX (CIIECK ONE) sell or transfer your hometo a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at. the sale and that the other requirements of the mortgage are satisfied. PAGE 3 of 4 YOU MAY ALSO HAVE TIIE 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 IIAVE THE MORTGAGE RESTORED TO TIIE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT IIAVE TIIIS RIGIIT 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 OTIIER DEFENSE YOU BELIEVE YOU MAY IIAVE TO SUCII ACTION BY TIIE LENDER- • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counselinie Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, usin.- additional paces ifnecessart, PAGE 4OF4 Nakiwal City t odgage - WE Mortgage 3T tE'uix6Y4 a e'7 S1820 P.O. Bo Ohio 45441-1820 71078381654020617022 wallang Address: 02573-0000009-001-001-000-000-000 MCGLONE,DONALD L 1413 SILVER CREEK DR MECHANICSBURG PA 17050-2086 Certified Mail/Return Receipt Requested Loan No: 0002202472 Current Servicer: National City Mortgage HOPI 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: 1413 SILVER CREEK DR MECHANICSBURG PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) 5 and the following amount(s) are now past due: Monthly Payments $1,805.46 Corporate Fees $0.00 Late Charges $159.96 Non-Sufficient Funds $0.00 Fax Fees $0.00 Property Inspection Fees $9.00 Less Suspense Balance $0.00 Total Due $9,196.26 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): 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 PAYING THE LENDER, WHICH IS $9,196.26, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: National City Mortgage Customer Counseling Department 3232 Newmark Dr Miamisburg, OH 45432 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter:( Do not use if not applicable). This is an attempt to collect a debt, any information obtained will be used for that purpose- Enclosure DR672 Appendix A DATE: 06,:29:2(X)9 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* This is an official notice that the mortizage 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 pales 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 A ency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions_ ouv call the Pe n vlvania 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 VIVVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENTDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAAIENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PAGE 1 OF 4 HOMEOWNER'S NAME (S): VICGLONE,DONALD L MCGLONE,SUSAN B PROPERTY ADDRESS: 1413 SILVER CREEK DR LOAN ACCT. NO.: 0002202472 ORIGINAL LENDER: n,:a CURRENT LENDER/SERVICER: National City 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 CONIEPLY WITH THE PROVISIONS OF THE HONIEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY tiiORTGAGE 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'lnecting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGEE ASSISTANCE. YOU MUST BRING YOUI_? MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS IIOW TO BRING YOLJR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you mcetwith one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located arc set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lenderimmediatelyofyour intentions- APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'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 HEHAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A AfEETING "ITH A COEWSELI1NrG AGENCY if'ITH11'V 33 DAYS OF THE POSTMARK DATE OF THIS A'OTICE AND) FILE ANAPPLICATION 077H PHFA WITHIA' 30 DAYS OF THAT MEETIA'G, THEY THE LEADER WILL BE TE11PORARILY PREVENTED FROG I STARTLYG A FORECLOSURE AGAI NST YOUR PROPERTY, AS EXPLAINED ABOVE, LV THE SECTIOAI CALLED "TE_ 1PORARY STAY OF FORECLOSURE"YOU HAVE THE RIGHT TO FILE A HEIMAP APPLICATIOjV EVEN BEYO D THESE 7111E PERIODS A LATE APPLICATION 97LL NOT PREVENT THE LENDER FROM STARTL'VG A FORECLOSURE ACTIO'V, BUT IF YOUR APPLICATION I.S EVENTUALLYAPPROVED AT ANY TYNE BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. PAGE 2 OF 4 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 bankniptcy you can still apply for Emergency Mortgage Assistance.) 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 toforeelose upon your mortgaged propenc. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorneys 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 T1 IIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs comectedwith the Shcriff'sSalc as specified in writing by the lender and. by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a 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 sSalc 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: National City Mortgage Address: 3232 Newmark Dr. Miamisburg, OH 45432 Phone Number: 1-800-523-8654 Fax Number: 937-9104009 Contact Person: Customer Counseling Department E-Mail Address: Loss.Mitigation(rncmc.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time- ASSUMPTION OF MORTGAGE --You may or may notX (CIIECK ONE) sell or transfer your hometo a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. PAGE 3 of 4 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 []AVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIG[IT 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- o TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). PAGE 4 OF 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~. Sheriff ~s~r at ~~„~,~~~. ~~ Jody S Smith Chief Deputy ~- ~ ` ~I~ ~~~ 12 ~~ 8; Edward L Schorpp Solicitor ~r~ , 4 ;~ ~.:t .~~~~~ 1'fR'%~3~`~ PNC Mortgage Case Number vs. 2010-3008 Donald L. McGlone (et al.) SHERIFF'S RETURN OF SERVICE 05/10/2010 04:35 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 1633 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donald L. McGlone, by making known unto himself personally, at 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~ MICHELLE GU SHALL, DEPUTY 05/10/2010 04:35 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2010 at 1633 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan B. McGlone, by making known unto Donald L. McGlone, Husband of defendant at 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. MICHELLE GUTSFIALL, DEPUTY SHERIFF COST: $53.00 May 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ci Ceu:^;tySuite Shenft, Teiensaft, Inc. ~ In the Court of Common Pleas of Cumberland County PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff No. 10-3008 vs. SUSAN B. MCGLONE - r„~ ~ ~i DONALD L. MCGLONE C ~ (Mortgagor{s) and Record Owner(s)) r~ ~ 1413 Silver Creek Drive ~~` N tv Mechanicsburg, PA 17050 ~ ~ Defendant(s) „G ~ ~ `~ -~ ~ ~--~j PRAECIPE FOR JUDGMENT . ~ 2, ~ ~., , ~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SUSAN B. MCGLONE and DONALD L. MCGLONE by default for want of an Answer. Assess damages as follows: Debt Interest from 6/22/2010 to Date of Sale per diem at $36.12 Total (Assessment of Damages attached) $222,005.61 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES LS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed o r to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occ and eas ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: GOLABECK CC RTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Li Lee Pa. ID 78020 'sting Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW -Z-°~' o°~--~ ~ ~ ,Judgment is entered in favor of PNC MORTGAGE, A DIVISI N OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY and against SUSAN B. MCGLONE and DONALD L. MCGLONE by default for want of an Answer and damages assessed in the sum of $222,005.61 as per the above certificati ~' u~~ ~syca4 ~~~ ~3 ~a J~JO~?ce M,~ l~ Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW PNC MORTGAGE, A DNISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mazk Drive Miamisburg, OH 45342 Plaintiff vs. No. 10-3008 SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagors and Record Owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Protho By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 97440FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June $, 2010 TO: SUSAN B. MCGLONE MCGLONE, SUSAN B. 1413 Silver Creek Drive Mechanicsburg, PA 17050 PNC MORTGAGE, A DNISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagor(s) and Record Owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) TO: SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 In the Court of Common Pleas of Cumberland County CNIL ACTION -LAW Action of Mortgage Foreclosure Term No. 10-3008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FII.E IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 97440FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 8, 2010 TO: DONALD L. MCGLONE MCGLONE, DONALD L. 1413 Silver Creek Drive Mechanicsburg, PA 17050 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mazk Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagor(s) and Record Owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) TO: DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 In the Court of Common Pleas of Cumberland County CIVII. ACTION -LAW Action of Mortgage Foreclosure Term No. 10-3008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIItING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SUSAN B. MCGLONE, is about unknown years of age, that Defendant's last known residence is 1413 Silver Creek Drive Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: Barb Hand ~ a~i~n VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DONALD L. MCGLONE, is about unknown years of age, that Defendant's last known residence is 1413 Silver Creek Drive Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: Barb Hand ~(Z~r~~ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attornev for Plaintiff NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagor(s) and Record owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-3008 Please enter Judgment in favor of PNC MORTGAGE, A DIVISION OF P C BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, d SUSAN B. MCGLONE and DONALD L. MCGLONE for failure to file an Answer in the above action within 0 a s o sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the s $ , 5.61. By: GOLD~3F~CK MCCRFFERTY & MCKEEVER Micha McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ~vid Fein Pa. ID 82628 omas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 and that the na d last known address(es) of the Defendant(s) is/are SUSAN B. MCGLONE, 1413 Silver Creek Drive a is urg, PA 17050 and DONALD L. MCGLONE, 1413 Silver Creek Drive Mechanicsburg, PA 17050; By: GOLD CK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 stina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $188,359.24 Interest from 02/01/2009 through $18,308.43 06/21/2010 Reasonable Attorney's Fee $9,417.96 Late Chazges $134.48 Costs of Suit and Title Search $900.00 Escrow Payments Due 2 X $460.62 $921.24 Pro Rata MIP/PMI $145.06 Escrow Advance $3,739.70 Total Fees $79.50 $222,005.61 By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Di~id Fein Pa. ID 82628 omas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this °~'~ ~- day of ~ , 2010 damages are assessed as above. , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 10-3008 '~ rrz Tr ,~., < Gy PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: f~-y.oo p~ a~~ et ~ S,3y~o9 ~~ a~yr3~ ~ 53.b 0 c~s+s B ~ s~y,Ob ~` ~~ ii ~t ~y'S-~ pD s '~ a-• Sb N ~,L 6 D ,~.L Co Amount Due Interest from 6/22/2010 to Date of Sale per diem at $36.12 (Costs to be added) $222,005.61 d By: GOLDBEC MCC RTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 ' tina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff r.a 0 a c.._ C x .. .~ ~ ~ o ~ ttiL L L ~H x U z a zo `~ ~' z ~ o pz¢ ~~ ° o~~ x 00 v,~0 >z H°o o A~~ QF'¢ F, za Q~ o ~oo ~ x ~a ~ ~z UO z ~, aQ z z o ^ ~~ ~ ,~~ W woo~~° w zabQ~ O U o~ a ~ ~ ~ ~. ~ F+ H ~a~~~ 3 Q ~ ai z~ ~~~ o .~-~ z ~ U rn0 ~ a~ ~I ~ ~ A ao '-' ~ W ~ ~ ~ ~ W .. a a U f-" U /-~ ~, ~~ ~U ~~ o o~ y ~ ~ N ~~~Q~ ~c~:~~ o ~, U ~c+ ~ ~n rri O c~C N .S ~ moo a bo o ,~ C7 ALL THAT CERTAIN tractor parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern right-of-way line of Senseman Road, a 50 foot wide street, said point also being the northeastern property comer of Lot #33 as shown on the final Phase 3 subdivision plan of Turnberry; thence along the southern right-of-way line of Senseman Road, North 82 degrees 45 minutes 15 seconds East, a distance of 100.00 feet to a point on the southern right-of-way line of Senseman Road, said point also being the northwestern comer of Lot #38; thence along the western property line of lot #38, South 07 degrees 14 minutes 45 seconds East, a distance of 90.00 feet to a point on the northwestern property corner of Lot #37, said point also being the southwestern property corner of Lot #38; thence along the western property line of Lot #37, South 57 degrees 44 minutes 14 seconds West, a distance of 82.76 feet to a point on the northeastern property comer of Lot #36, said point also being the southwestern property comer of Lot #37; thence along the northern property line of Lot #36,South 82 degrees 45 minutes 15 seconds West, a distance of 25.00 feet to a point on the northern property line of Lot #36, said point also being the southeastern comer of Lot #33; thence along the eastern property line of Lot #33, North 07 degrees 14 minutes 45 seconds West, a distance of 125.00 feet to a point on the southern right-of-way line of Senseman Road, said point being the point and place of BEGINNING. TAX PARCEL #: 10-16-1060-188 BEING KNOWN AS: 1413 Silver Creek Drive, Mechanicsburg, PA 17050 BEING the same premises which Randall C. Vathis and Andrea M. Vathis, husband and wife by Deed dated 5/20/2003 and recorded 5/29/2003 in Book 257 Page 1323 granted and conveyed unto Donald L. McGlone and Susan B. McGlone, husband and wife. GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY LD. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF Fl~~-~~E 131= ~ 1~ ~ rf ~`"~TA~'t' 201D JUG! 22 Pty (Z= ~-b r~-.. ~i..o k~ 1 CU11~~~=r=' ~"~ ~ f'~t,iNTY PENtiS1'~VA~'~IA PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) Term No. 10-3008 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. ~ ~ By: - vy~-v v GOLDBE K McCAFFERTY & McKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Attorneys for Plaintiff Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS PNC MORTGAGE, A DNISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagor(s) and Record Owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 10-3008 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1413 Silver Creek Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 t)F ~ VARY 2010 JUG! 22 PM f2: 46 of Cumberland County CIVII, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1413 Silver Creek Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) 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. Section 4904 relating to unsworn falsification to authorities. DATED: June 18.2010 GOLDBECK McCAFFERTY & McKEEVER BY: Barb Hand 10-3008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendants; Term No. 10-3008 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MCGI,oNE, SUSAN B. SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 Your house at 1413 Silver Creek Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $222,005.61 obtained by PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Fl~~l~x= u~ hF THE !}~''-~#4~~"~RY zo c o ~ur~ 22 ~~s ~z= ~ ~ F'~fV~J`1l.VAN(A of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 10-3008 1. The sale will be cancelled if you pay to PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 4. 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 below 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 NOT TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 shaze 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 thirty (30) days from the date of the Sheriffs 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) aze filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: httn://www.philadelphiafed.org/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 r 10-3008 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httn://www.phfa.or~/consumers homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 97440FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 10-3008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff Ft,~f•i '~ THE F'~~~1~'CY' 2Q10 JUN 22 PM 12~ kf~ CUt~~E:~~~~~~ ~U ~~.h1MY ~~ti~~~A~ PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant( of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-3008 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MCGLONE, DONALD L. DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 Your house at 1413 Silver Creek Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $222,005.61 obtained by PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 10-3008 1. The sale will be cancelled if you pay to PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure! 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 f 10-3008 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httv://www.nhfa.or~/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 97440FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-3008 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY Plaintiff (s) From SUSAN B. MCGLONE AND DONALD L. MCGLONE (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$222,005.61 L.L.$.50 Interest FROM 6/22/2010 TO DATE OF SALE PER DIEM AT $36.12 Atty's Comm Atty Paid $185.50 Plaintiff Paid Due Prothy $2.00 Other CostsTO BE ADDED Date: NNE 22, 2010 (Seal) REQUESTING PARTY: Name THOMAS PULEO, ESQUIRE Deputy Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET, PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 27615 ell, Pro onotary By: GOLDBECK McCAFFERTY & MCKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 OF THEPROTHON 20roNOV 30 AM it: 2€3 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff VS. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 10-3008 Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (50 Personal Service by the Sheriffs Office /ccupete"Owh It (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectful y subitte , BY: Keith C. Halli'li Legal Secretary 97440FC CF: 05/06/2010 SD: 12/08/2010 $222,005.61 T OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Q Cy T N N ?? b C+G1+ "S {t m 7 C ? Y m a m d 7 0. 7 R4 t{r{ -?` Vv ? ? m o o . A m s n ls l Ul m - _ Z- Uj o c_p w O- F Q G C o G Q U Q 0 m? - C N W ul d o a 'amlL® as CD 3 ? F g ¢ ' U o U M ? n CD LL- 0 CL Z p a o O m E Q cr) zU m r r W LSm 0 4 CI- v ? ? ? m m CC ?' U -d U ?a 4 a ass t? 9 .. c t 5 O .3 a tom' - 7 d N o '),, ?5 13 coo LUZ a N D di6 ??? 0 2 O? a c m N to 4 a.Y?oY?N UJLL) m w Q `?G © r C4 Z 0 p 0-- - m a c d .V Q V d d N tT" ? ,.. O x c i .. T r T Q ?, 61 W C. O 5 U r N m co o p m N <- Z 11.1 a ? Z CD Ta o ? a J N C) o .T o Z oa m U O $ m d g Q C Od Z 7-3 U U m w LL ? r- ti] a Z U u. mO ° cn Q LL ? I I o 73 ti cfl .ri cr5 I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy R-ichird-W -Stewart Solicitor , to" ai ? Or-" aF TK SR'EWF! PNC Mortgage vs Case Number . Donald L. McGlone (et al.) 2010-3008 SHERIFF'S RETURN OF SERVICE 10/2112010 02:06 PM - William Cline, Deputy Sheriff, who being duty sworn according to law, states that on 10121/1 D at 1349 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Donald L. McGlone, by making known unto, Donald L. McGlone, personally, at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/21/2010 02:07 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10/21110 at 1349 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Susan B. McGlone, by making known unto, Donald L. McGlone, spouse, at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same 10125/2010 Valarie Weary, Deputy Sheriff, who being duly sworn according to law, states that on 10/18110 at 1130 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donald L. and Susan 8 McGlone, located at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. SHERIFF COST: $908.92 October 27, 2010 SO ANSWERS,. RON R ANDERSON, SHERIFF to! cok"Ysufte steehft. Talaosa t. Ix. GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 VS. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-3008 AFFIDAVIT PURSUANT TO RULE 3129 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SBIM NATIONAL CITY MORTGAGE COMPANY, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1413 Silver Creek Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 1.7050 2. Name and address of Defendant(s) in the judgment: SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1413 Silver Creek Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) 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. Section 4904 relating to unsworn falsification to authorities. DATED: November 24, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r? PNC Mortgage vs. Donald L. McGlone (et al.) Case Number 2010-3008 SHERIFF'S RETURN OF SERVICE 10/21/2010 02:06 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at 1349 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Donald L. McGlone, by making known unto, Donald L. McGlone, personally, at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/21/2010 02:07 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at 1349 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Susan B. McGlone, by making known unto, Donald L. McGlone, spouse, at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same 10/25/2010 Valarie Weary, Deputy Sheriff, who being duly sworn according to law, states that on 10/18/10 at 1130 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donald L. and Susan B McGlone, located at, 1413 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 12/02/2010 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 2/2/2011 01/31/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney on 3/1/11. SHERIFF COST: $883.12 SO ANSWERS, tr.' March 01, 2011 RON R ANDERSON, SHERIFF Q Z26) 1, - cc, SZ) tl/- /V*1 , -6 3?? Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff VS. SUSAN B. MCGLONE DONALD L. MCGLONE (Mortgagor(s) and Record Owner(s)) 1413 Silver Creek Drive Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 10-3008 AFFIDAVIT PURSUANT TO RULE 3129 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1413 Silver Creek Drive Mechanicsburg, PA 17050 l.Name and address of Owner(s) or Reputed Owner(s): SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 Name and last known address of every judgment crgditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1413 Silver Creek Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) 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. Section 4904 relating to unsworn falsification to authorities. DATED: June 18, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Barb Hand 10-3008 GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff VS. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Defendant(s Term No. 10-3008 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MCGLONE, SUSAN B. SUSAN B. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 Your house at 1413 Silver Creek Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriff s Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $222,005.61 obtained by PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 10-3008 .1. The sale will be cancelled if you pay to PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www. hip iladelphiafed.or.e/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 10-3008 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hLtp://www.phfa.orp-/cons=ers/homeowners/real.asRx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 97440FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern right-of-way line of Senseman Road, a 50 foot wide street, said point also being the northeastern property comer of Lot #33 as shown on the final Phase 3 subdivision plan of Turnberry; thence along the southern right-of-way line of Senseman Road, North 82 degrees 45 minutes 15 seconds East, a distance of 100.00 feet to a point on the southern right-of-way line of Senseman Road, said point also being the northwestern comer of Lot #38; thence along the western property line of Lot #38, South 07 degrees 14 minutes 45 seconds East, a distance of 90.00 feet to a point on the northwestern property corner of Lot #37, said point also being the southwestern property corner of Lot #38; thence along the western property line of Lot #37, South 57 degrees 44 minutes 14 seconds West, a distance of 82.76 feet to a point on the northeastern property comer of Lot #36, said point also being the southwestern property comer of Lot #37; thence along the northern property line of Lot #36,South 82 degrees 45 minutes 15 seconds West, a distance of 25.00 feet to a point on the northern property line of Lot #36, said point also being the southeastern comer of Lot #33; thence along the eastern property line of Lot #33, North 07 degrees 14 minutes 45 seconds West, a distance of 125.00 feet to a point on the southern right-of-way line of Senseman Road, said point being the point and place of BEGINNING. TAX PARCEL M 10-16-1060-188 BEING KNOWN AS: 1413 Silver Creek Drive, Mechanicsburg, PA 17050 BEING the same premises which Randall C. Vathis and Andrea M. Vathis, husband and wife by Deed dated 5/20/2003 and recorded 5/29/2003 in Book 257 Page 1323 granted and conveyed unto Donald L. McGlone and Susan B. McGlone, husband and wife. 10-3008 r w GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE COMPANY 3232 New Mark Drive Miamisburg, OH 45342 Plaintiff vs. SUSAN B. MCGLONE DONALD L. MCGLONE Mortgagor(s) and Record Owner(s) 1413 Silver Creek Drive Mechanicsburg, PA 17050 Term No. 10-3008 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MCGLONE, DONALD L. DONALD L. MCGLONE 1413 Silver Creek Drive Mechanicsburg, PA 17050 Your house at 1413 Silver Creek Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriff s Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $222,005.61 obtained by PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 10-3008 1. The sale will be cancelled if you pay to PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hn://www.pbiladelpbiafed.orgiforeclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 10-3008 .t Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.go_v for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http //www phfa ors/consumers/homeowners/real.asyx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@ Roldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 97440FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern right-of-way line of Senseman Road, a 50 foot wide street, said point also being the northeastern property comer of Lot #33 as shown on the final Phase 3 subdivision plan of Turnberry; thence along the southern right-of-way line of Senseman Road, North 82 degrees 45 minutes 15 seconds East, a distance of 100.00 feet to a point on the southern right-of-way line of Senseman Road, said point also being the northwestern comer of Lot #38; thence along the western property line of Lot #38, South 07 degrees 14 minutes 45 seconds East, a distance of 90.00 feet to a point on the northwestern property corner of Lot #37, said point also being the southwestern property corner of Lot #38; thence along the western property line of Lot #37, South 57 degrees 44 minutes 14 seconds West, a distance of 82.76 feet to a point on the northeastern property comer of Lot #36, said point also being the southwestern property comer of Lot #37; thence along the northern property line of Lot #36,South 82 degrees 45 minutes 15 seconds West, a distance of 25.00 feet to a point on the northern property line of Lot #36, said point also being the southeastern comer of Lot #33; thence along the eastern property line of Lot #33, North 07 degrees 14 minutes 45 seconds West, a distance of 125.00 feet to a point on the southern right-of-way line of Senseman Road, said point being the point and place of BEGINNING. TAX PARCEL #: 10-16-1060-188 BEING KNOWN AS: 1413 Silver Creek Drive, Mechanicsburg, PA 17050 BEING the same premises which Randall C. Vathis and Andrea M. Vathis, husband and wife by Deed dated 5/20/2003 and recorded 5/29/2003 in Book 257 Page 1323 granted and conveyed unto Donald L. McGlone and Susan B. McGlone, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-3008 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION SB/M NATIONAL CITY MORTGAGE COMPANY Plaintiff (s) From SUSAN B. MCGLONE AND DONALD L. MCGLONE (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$222,005.61 L.L. $.50 Interest FROM 6/22/2010 TO DATE OF SALE PER DIEM AT $36.12 Atty's Comm % Atty Paid $185.50 Plaintiff Paid Date: JUNE 22, 2010 (Seal) Deputy REQUESTING PARTY: Name THOMAS PULEO, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET, PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 27615 Due Prothy $2.00 Other CostsTO BE ADDED ,---/ - 11-14 Davi well, Prothon ?ary By: On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 1413 Silver Creek Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: Real Estate Coordinator 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: October 22, October 29, and November 5, 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. isa Marie Coyne, 7itor SWORN TO AND SUBSCRIBED before me this 5 da of November, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-3008 Civil PNC Mortgage, a Division of PNC Bank National Asociation, S/B/M National City Mortgage Company VS. Donald L. McGlone Susan B. McGlone Atty.: Michael McKeever ALL THAT CERTAIN tract or par- cel of land situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern right-of-way line of Sense- man Road, a 50 foot wide street, said point also being the northeastern property comer of Lot #33 as shown on the final Phase 3 subdivision plan of T umberry; thence along the south- ern right-of-way line of Senseman Road, North 82 degrees 45 minutes 15 seconds East, a distance of 100.00 feet to a point on the southern right- of-way line of Senseman Road, said point also being the northwestern comer of Lot #38; thence along the western property line of Lot #38, South 07 degrees 14 minutes 45 sec- onds East, a distance of 90.00 feet to a point on the northwestern property corner of Lot #37, said point also be- ing the southwestern property corner of Lot #38; thence along the western property line of Lot #37, South 57 degrees 44 minutes 14 seconds West, a distance of 82.76 feet to a point on the northeastern property comer of Lot #36, said point also being the southwestern property comer of Lot #37; thence along the northern property line of Lot #36,South 82 degrees 45 minutes 15 seconds West, a distance of 25.00 feet to a point on the northern property line of Lot #36, said point also being the southeast- ern comer of Lot #33; thence along the eastern property line of Lot #33, North 07 degrees 14 minutes 45 seconds West, a distance of 125.00 feet to a point on the southern right- of-way line of Senseman Road, said point being the point and place of BEGINNING. TAX PARCEL #: 10-16-1060-188. BEING KNOWN AS: 1413 Silver Creek Drive, Mechanicsburg, PA 17050. BEING the same premises which Randall C. Vathis and Andrea M. Vathis, husband and wife by Deed dated 5/20/2003 and recorded 5/ 29/2003 in Book 257 Page 1323 granted and conveyed unto Donald L. McGlone and Susan B. McGlone, husband and wife. 84 -ihe Patriot-News Co. 2C M Technology Pkwy Suite 300 Mechanicsburg, PA 17050. Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 i4epatriot News Now you know 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 oi'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: 10/15/10 10/22/10 10/29/10 v .. . Sworn to andd bscribed before me this 10 klay of No bK,,-2010 A. D. j Notary Public COMMONWEALTH OF PENNSYLVANIA Notarlai Seal Sherrie L. Kisner, Notary Public Lower Paxton Twp., Dauphin County My C.ommisslon Expires Nov. 26, 2011 Member, Pennsylvania Associatior of Notaries 2010.3008 ChM Tartu PMG Yee a 00vislon of pt1C sm* Asocleflon, SBfM NaBonst CRY Morwe" conWny Vs Dodd L McGlone Susan B. McGlone A1tiy: Mid" McKesw ALL THAT CERTAIN tract or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and descn'bed as follows, to wit: BEGINNING at apoint on the southern right- of-way line of Senseman Road, a 50 foot wide street, said point also being the northeastern property comer of Lot #33 as shown on the final Phase 3 subdivision plan of lbmberry; thence along the southern right-of-way Be of Senseman Road, North 82 degrees 45 minutes 15 seconds But a distance of 100.00 feet to a point on the southern right-of-way line of Senseman Road, said paint also being the northwestern comer of Lot #38; thence along the western property line of Lot #38, South 07 degrees 14 minutes 45 seconds East, -a distance of 90.00 feet to a point on the northwestern property comer of Lot #37, said point also being the southwestern property comer of Lot #38; thence along the western property he of Lot #37, South 57 degrees 44 minutes 14 seconds West, a distance of 82.76 feet to a point on the northeastern property comer of Lot #36, said point also being the southwestern property comer of Lot #37; thence along the northern property line of Lot #36,South 82 degrees 45 minutes 15 seconds West, a distance of 25.00 feet to a point on the northern property line of Lot #36, saidptintalso being the southeastern comer of Lot #33 thence along the eastern property fine of Lot #33, North 07 degrees 14 minutes 45 seconds' West, a distance of 125.00 feet to apointon the southern right-of-way line of Senseman Road, said point being the point and place of BEGINNING. TAX PARCEL #:10-16.1060.188 BEING KNOWN AS. 1413 Silver Creek Drive, Mechanicsbur& PA 17050 BEING the same premises which Randall C. vathis and Andrea M. Vathis, husband and wife by Deed dated 5120/2003 and recorded 5/29!2003 in Book 257 Page 1323 granted and conveyed unto Donald L. McGlone and Susan B, McGlone, husband and wife.