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HomeMy WebLinkAbout10-3838s ~ i GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY LD. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF ! ~1 {l.. ~ 11' V~ ~ ~ ~}(~ (~ t,.' '~ I. 331~J L13~U ..~l.ii~ c~.fr~~ .;, . ,:~ ~jt , ,r, i ., ,, n ,-~. CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaint vs. BII.,LIE J. MULLEN A/K/A BILLIE J. INFANTINO Mortgagor and Record Owner 10 Bloserville Road Carlisle, PA 17013 Defendant Term 1©_ 3 ~3 ~' C'~' l CIVIL A ~N' MO~GAGE NOTICE FQf~~`l''~-°!~~~1~~ You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION ~q~.- o d /`~ ~~y 2 Liberty Avenue ek *' ,~ 3 3 3 ~~ Carlisle, PA 17013 2~~y3 ,yam AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate 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 continuer la demanda en contra suya sin previo aviso o notification. 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 pare usted. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ' LLEVE E5TA 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 PARR 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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: 717-243- 9400 or . 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.phfa.org/consumers/homeowners/real.asnx. 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.nhiladelphiafed.org/foreclosure! 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~~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 93249FC. Para information 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 CITIFINANCIAL SERVICES, INC, 1111 Northpoint Drive, Building 4 Suite 100 Coppell, TX 75019. 2. The names and addresses of the Defendant is BILLIE J. MULLEN A/K/A BILLIE J. INFANTINO, 10 Bloserville Road, Carlisle, PA 17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described. Original mortgagor John Mullen is hereby released of record. 3. On February O1, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to CITIFINANCIAL INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1939 Page 2006.. 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 10, 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 ....................................................................................$41,162.25 Interest from 02/10/2009 through 05/31/2010 at 11.1960% .....................$5,952.00 Per Diem interest rate at $12.63 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,058.11 Late Charges from 03/10/2009 to 05/31/2010 ..............................................$746.85 Monthly late charge amount at $49.79 Costs of suit and Title Search (Estimated) ...................................................$900.00 Deferred Interest ..........................................................................................$594.13 Bpo ................................................................................................................. $ 84.00 Property Inspection ........................................................................................$16.00 Insurance ......................................................................................................$124.26 $51,637.60 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 Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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 Defendant 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 Defendant 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 Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $51,637.60, together with interest at the rate of $12.63, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mor age and Sheriff's Sale of the Property. By: ~ GOLDBECK MCC Michael McKeever a Gary McCafferty Lisa Lee Pa. ID 78020 & MCKEEVER ~ 56129 42386 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATION I, i °~ a ~Sr ~. ~,' as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~-~ / , Date: /~ ).9 P y ~~ #93249FC -JOHN MULLEN and BILLIE J. MULLEN A/K/A BILLIE J. INFANTINO 10 Bloserville Road Carlisle, PA 17013 ~Fii6it A ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Pennsbora Township, Cumberland County, Pennsylvania, bounded and described pursuant to a survey by Thomas A. Neff, Registered Surveyor, on March 11, 1968, as follows: BEGINNING at a point in the center of L.R. 21035, said point being the northeastern corner of land of Erma F. Jumper, et al; thence by said land, South 59 degrees 49 minutes West 246.62 feet to a stake; thence by land no~v or formerly of Maynard Weary, North 52 degrees 45 minutes West 41 feet to a paint; thence by land being retained by the Grantors, North 46 degrees 5 minutes 50 seconds Bast 229.25 feet to a point in the center of L.R. 21035; thence by the center of said Road, South 53 degrees 20 minutes Bast 100 feet to the place of BEGINNTNiG. CONTAINING .367 acre, more or less, an8 being improved with a dwelling house known as 10 Bloserville Road, Carlisle. BEING THE SAME PREMISES which Kevin C. Bear and Jodie L. Bear, husband and wife, by their deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Billie J. Infantino. ~Fii6it ~ ACT 91 NOTICE DATE OF NOTICE: O1/15/2010 TAKE ACTION TO SASE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILT. BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortg_a~e 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 MORTGAGE ASSISTANCE PROGRAM lHEMAP) 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 CounselingAgen_cy. 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 andquestions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. {Persons with impaired hearing_can call f717) 780-1869.) This Notice contains important Legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notification en adjunto es de soma importancia, pues afecta su derecho a continuer viviendo en su case. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada amba. Puedes ser elegible pare un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el coal puede salver su case de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 -Mellon Independence Center. 70I Market Street Philadelphia, PA 19106 Fax (21 S) 627-7734 Date: 01/15/2010 Homeowners Name: JOHN MULLEN and BILLIE J. MULLEN Property Address: 10 Bloserville Road, Carlisle, PA 17013 Loan Account No.: 2000510271215 Original Lender: CITIFINANCIAL MORTGAGE CO. INC. Current LenderlServicer: CITIMORTGAGE INC. HOMEOWNERS' EMERGENCX MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three {3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. TffiS MEETING MUST OCCUR WITHIN THE NEXT (331 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE_ CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desi~ated consumer credit counseling agencies for the county in which theproperty is located aze set forth at the end of this Notice. It is only necessary to schedule one face to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth Later in this Notice (see foIlowing pages for specific information about the nature of your default.} You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU RAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED, AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60}days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. HOW TO CURE YOUR MORTGAGE DEFAULT Brine it ua to datel NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 10 Bloserville Road, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly gayment from 03/10/2009 thru O1/15/2010 (11 mos. at $497.05/month) $5,467.55 (b) Late charges from 03/10/2009 thru 01/15/2010 (11 mos. at $49.79/month) $547.69 (c) Other chazges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e} TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,015.24 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS 6 015.24 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents must be made either by cashier's check. certified check or money order madepavable and sent to: CITIMORTGAGE INC. PO Box 689196 Des Moines, IA 50368-9196 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 rishts to accelerate the mortaaue 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 fiilI payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attomeys to start legal action to foreclose anon your mortaaaed property. 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 brings legal proceedings against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey'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 t30) DAY period. vox will not be required to aav attorney's fees. OTHER LENDERREMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage_ RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri t to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due. plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the Lender and bx e~rforming any other requirements under the mort~e. Curing your default in the manner set forth in this notice wi[I 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 four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent tv you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIMORTGAGE INC. Address: 1000 Technology Drive O'Fallon, MO 63368-2240 Phone Number: 500-723-7906 Faz Number: 636-261-7716 Contact Persom: Adam Saab Email Address: ryan.ollier@citi.com EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your night to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY TIiIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCY.TRRED, IF YOU CURE THE DEFAULT_ (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEA.R..) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Adam Saab Phone Number: 800-723-7906 HEMAP Consumer Credit Counseling Agencies Report last updated: 11J27/2009 2:32:10 PM CCCS oT Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 DAUPHIN Courrty CCCS of Western PA 2000 Linglestovvn Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Center for Family Services, tna 2i3 Center Street Meadville, PA 16335 814,337.8450 Groater Fria Community Action Committee 18 West 9TH Sheet Erie, PA 16501 814.459.4581 Shenango Palley Urban League, Inc. 601 Indiana Avenue Farre!!, PA 16121 724.981.5310 St. itAartin Center 1701 Parade Street Erie, PA 16503 814.452.8113 CUMBERLAND County CCCS of Western PA 2000 Lirrglestewn Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Comnrunily Action Commission of Captiai Region 1514 Deny Street Hartfsburg, PA 17104 717.232.9757 AAaranetha 43 Phfladelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.7518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Conrrrrission of Captlal Region 1514 Deny Street Hanisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3040 800.342.2397 DELAWARE Courtly Advocates for Financaal independence 202 East Hinldey Avenue Ridley Partc, PA 19078 215.389.2810 American Credit Counseling Institute 775 Strafford Avenue Suite t Wayne, PA 79087 610.971.2210 888212_fi741 American Credit Counseling Institute 526528 Dekab Street Norristown, PA 19401 610.971.2210 888212.6741 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Phiatielphia, PA 19125 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 405 West Germantown Pike Nonistovm, PA 19403 287.228.7903 800.490.3038 Amercan Financial Counse8ng Services Inc. 175 Stratford Avenue Suds One Wayne, PA 19087 267.228.7903 800.490.3039 Page 8 of 21 HEMAP Consumer Credit Counseling Agencies Report last updated: 11/27/2009 2:32:10 PM American Red Crosa of Chester FOB CDC 1729 EdgemorK A~nue 1201 West Olney Avenue Chester, PA 19013 Philadelphia, PA 19141 610.874.1484 215.549.8755 ~'M Germantown Settiatnertt 600 W Diamond Street 5538 Wayne Avenue Philadelphia, PA 19122 Bldg C 215.235.8070 Ph~laddphia, PA 19144 (267) 953-4615 215.849.3104 Carroll Park Community Council, Inc RACE 5218 Master Street 167 W. Allegheny Avenue Ph~adelphia, PA 19131 lid FI 215.877.1157 Philadelphia, PA 19140 CCCS of Delaware VaNay 215.426.13025 113 East Main Street ibusing Partnership of Chester County 2nd Floor 41 West Lancaster Ave Nortisiown, PA 19401 Downingfovm, PA 19335 215.563.5665 610.518.1522 CCCS of Delaware Yalhey laEedia FeUowshlp House 1001 East Lincoln Highway 302 South Jackson Street Suite 102 Media, PA 19063 Coatesvilb, PA 19320 610.565.0434 215.563.5665 lrprihwpat Counseling Service CCCS of Delaware Valley 5001 Narfh Broad Street 4400 North Reese Street Philadelphia, PA 19141 Ph7adelphia, PA 19140 215.324.7500 215.563.5665 Phga Council For Community Advmnt CCCS of Delaware Valley 1617 John F Kennedy Blvd 790 E. Market SL Suite 1550 Suite 170, Marshall Building Pldiadefphia, PA 19103 West Chester, PA 19382 215.587.7803 215.563.5665 800.930.4663 CCCS of Delaware Valley Urban league of Philadelphia 1608 Wakiut Street 121 S Broad St 10th Floor g~ Floor Philadelphia, PA 19107 Phladelphia, PA 19107 215.563.5665 215.985.3220 CCCS of Dekaware valley ELK County 280 North Provktence Road Media, PA 19063 Northam Tier Community Action Corp. 215..563.5865 P.O. Box 389 135 West 4th Stn;et Chester Community Improvement Project Emporium, PA 15834 412 Avenue of the States 814.486.1161 PO Box 541 fester, PA 19016 ERIE County 610.876.8663 Booker T. Washington Center Diversified Community Services 1720 Holland Sleet Dixon House Erie, PA 16503 1920 South 20th Street 814.453.5744 Philadelphia, PA 19145 215.336.3511 Page 9 of 21 HEMAP Consumer Credit Counseling Agencies Report last updated: l l/27/2009 2:32:11 PM CCCS of Western PA 4402 Peacfi Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 St. Marlin Center 1701 Parade Street Erie, PA 16503 814.452.6113 Voices for independence 1107 Payne Avenue Erie, PA 16503 814.874.0064 800.838.98!10 FAYETTE County Action Housing, Inc 425 6th Avenue Suits 950 Pitlsburgh, PA 15219 412.281.2102 800.792.2801 Southwestern Pennsylvania fugal Services lne. 45 East Main Street Suits 200 Uniontown, PA 15401 724.439.3591 Tableland Services Inc. 535 East Main Street Somerset, PA 15501 814.445.9628 800.452.Of 48 FOREST County Warren-Fonu:t Counties Economic Opportunity Council 1209 Pennsylvania Ave, West P.O. Box 547 Wamsn, PA 16365 814.726.2400 FRANKLIN Couftty American Red Crass -Hanover Chapter 529 Carlisle Street Hanover, PA 17331 717.637.3768 CCCS of Western PA 2000 Linglestown Road Hatrisblsrg, PA 17102 888.511.2227 888.5112227 CCCS of Western PA 1 North Gate Square #2 Garden Center Drive Greensburg, PA 15601 888.511.2227 888.511.2227 Community Action Southwest 58 East Greene Street Waynesburg, PA 15370 724.8522893 Fayette Co, Communty Action Agency, Inc. 108 North Beeson Avenue Uniontown, PA 15401 724.437.6050 600.427.INF0 NeighborWorka of Western Pennsylvania 710 5th Avenue Suite 1000 Pittsburgh, PA 15219 412281.9773 CCCS of Westsm PA 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 888.511.2227 Community Action Commission of Csptial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Maranalha 43 Philadelphia Avenue Waynesboro, PA 17268 717.782.3285 PA IMerfaid~ Community Programs Inc 40 E High Street Gettystwrg, PA 17325 717.334.1518 FULTON County CCCS of Wastem PA 55 Clover H81 Road Dallastown, PA 17313 888.511.2227 888.511.2227 Page 10 of 21 KML LAW GROUP, P.C. ' Suite 5000—BNY Mellon Independence Center �rfSi6 701 Market Street , 04 j Philadelphia, PA 19106-1532 p?6 215-627-1322 C'UI ^ "'lQr ZJQ' °Ca CITIFINANCIAL SERVICES, INC yt VAQj)yT Y 1111 Northpoint Drive IN THE COURT OF XMMON PLEAS Building 4 Suite 100 Coppell, TX 75019 OF CUMBERLAND COUNTY Plaintiff vs. BILLIE J. MULLEN A/K/A BILLIE J. No. 10-3838 INFANTINO (Mortgagor(s) and Record owner(s)) 10 Bloserville Road Carlisle, PA 17013 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERTY& McKEEVER By: Michael McKeever Pa. 6129 Jay E.Kivitz Pa.ID 2 Lisa Lee Pa.ID 78020 Thomas Puleo Pa.ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Ksalvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center • 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC Plaintiff IN THE COURT OF COMMON VS. PLEAS OF CUMBERLAND COUNTY BILLIE J. MULLEN A/K/A BILLIE J. INFANTINO CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE Defendant(s) FORECLOSURE No. 10-3 83 8 CERTIFICATE OF SERVICE Angela M. Smith ,hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant,by first class ? mail, postage pre-paid, on � �`�� BILLIE J. MULLEN A/K/A BILLIE J. INFANTINO 10 Bloserville Road Carlisle, PA 17013 KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERTY&McKEEVER By: /, 24�? *An ith, egal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone)