HomeMy WebLinkAbout10-5823GOLDBECK 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
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PNC BANK, NATIONAL ASSOCIATION S/B/M
NATIONAL CITY MORTGAGE A DIVISION OF
NATIONAL CITY BANK OF INDIANA
3232 New Mark Drive
Miamisburg, OH 45342 Plaintiff
vs.
DANIEL L. CORRIGAN
LESLIE A. CORRIGAN a/k/a LESLIE R. CORRIGAN
Mortgagors and Record Owners
623 Third Street
New Cumberland, PA 17070 Defendants
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
10- SBaB Ciwi i Terrh
No.
CIVIL ACTION: MORTGAGE
FORF_:C1..r URF
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 (5)
8 Irvine Row
Carlisle, PA 17013ga.0o Qp t?t'M
717-243-9400 C`15µ5143
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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.
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 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 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.phfa.orv,/consumers/homeowners/real.gWx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www.philadelphiafed.orv/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 101906FC.
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 BANK, NATIONAL ASSOCIATION S/B/M NATIONAL CITY MORTGAGE A
DIVISION OF NATIONAL CITY BANK OF INDIANA, 3232 New Mark Drive, Miamisburg, OH
45342.
2. The names and addresses of the Defendants are DANIEL L. CORRIGAN, 623 Third Street, New
Cumberland, PA 17070 and LESLIE A. CORRIGAN a/k/a LESLIE R. CORRIGAN, 623 Third Street,
New Cumberland, PA 17070, who are the mortgagors and record owners of the mortgaged premises
hereinafter described.
3. On April 12, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to NATIONAL CITY MORTGAGE A DIVISION OF NATIONAL CITY BANK OF
INDIANA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County
as Book 1947 Page 1967. 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 April 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 ...................................................................
Interest from 03/01/2009 through 08/20/2010 at 6.8050%....
Per Diem interest rate at $42.68
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph
Late Charges from 04/01/2009 to 08/20/2010 .......................
..............$228,946.11
................$22,882.44
Costs of suit and Title Search (Estimated) ........................................
.$11,447.31
......$439.28
...... $900.00
Escrow Advance .......................................................................................$4,477.09
Total Fees .....................................................................................................$169.50
NSF Charges ..................................................................................................$32.00
Recoverable Balance ......................................................................................$50.00
Monthly Escrow amount $284.18
$269,343.73
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 $269,343.73,
together with interest at the rate of $42.68, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with t s the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure t Mo gage d Sheriff's Sale of the Property.
By:
GOLDBECK MCCAFFERTY & MCKEEVER
Michael McKeever Pa. ID 56129
Gary McCafferty Pa. ID 42386
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
D,?vid Fein Pa. ID 82628
,homas Puleo Pa. ID 27615
ATTORNEYS FOR PLAINTIFF
VERIFICATION
Twsa S. Clopp
as the representative of PNC Mortgage, A Division
of PNC Bank, National Association, as Attorney in Fact for 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 unworn falsification to authorities.
Date: QPi. C90(3
(-? W44- A Q?S&
P NC MORTGAGE, A DIVISIO F PNC
BANK, NATIONAL ASSOCIATION
Authorized officer
Teresa S. Clopp
#101906FC - LESLIE A. CORRIGAN and DANIEL L. CORRIGAN
623 Third Street New Cumberland, PA 17070
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IT HXXW TNX SJ PPJWBU MICH Donald F. Fields and Dorothy L.
Fields, his wife, by their Deed dated November 22, 1969 and
recorded in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, on December 05, 1969, in Deed
Book M, Volume 23, Page 178, granted and conveyed unto Gerald B.
Speck and Bride C. Speck, his wife.
IT ALSO MXXW T1M SAM
Pffice CH de C. Speck, unremarried
widow, by her Deed dated 2006, and
pRr ,
about to be recorded in the of the Recorder of Deeds in
and Cumberland County, Pennsylvania, granted and conveyed unto
Daniel L. Corrigan and Leslie A. Corrigan, husband and wife,
Mortgagors herein.
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PNC
f?Af)RMAGE "
P.O. Box 1820
Dayton, Ohio 45401-1820
April 2, 2010
49459-0000013-001-0014)00-000-000
1111 11
7107 8381 6540 2106 0803
PNC Mortgage
3232 Newmark Drive
Miamisburg, Ohio 45342
Telephone: (937) 910-1200
Mailing Address:
P.O. Box 1820
Dayton, Ohio 45401-1820
CORRIGAN,LESLIE A
623 3RD ST
NEW CUMBERLND PA 17070-2018
DATE: Apri12, 2010
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP)
may be able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving ,your Countv
are listed at the end of this Notice. If you have = questions, you may call the Pennsylvania Housing
Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact
an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): CORRIGAN,DANIEL L
CORRIGAN,LESLIE A
PROPERTY ADDRESS: 623 THIRD ST
LOAN ACCT. NO.: ?'
ORIGINAL LENDER: n/a
CURRENT LENDER/SERVICER: PNC Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face'lneeting 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 MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE LIP TO
DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURF. YOUR MORTGAGE DEFAULT". E PL. INS
HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in
which the proj2= is located are set forth at the end of this Notice. It is only necessaryto schedule one face-to-face meeting.
Advise your lenderimmediatelvofyour intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you must fill out, sign and
file a completed Homeowner'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 forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED
FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED
"TEMPORARYSTAY 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 E VENTUALL YAPPRO VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL
BE STOPPED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on
vour orooerty located at:
623 THIRD ST
NEW CUMBERLAND PA 17070
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s)
April 01, 2009 to April 01, 2010 and the following
amount(s) are now past due:
Monthly Payments 1,836.56
Corporate Fees 0.00
Late Charges 206.42
Non-Sufficient Funds .00
Fax Fees .00
Property Inspection Fees 72.00
Less Suspense Balance .00
Total Amount Past Due $24,091.74
HOPI 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 $24,091.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD-
P;;4ZMantc m„et be made pither by raahiprIp ehank c+ertifipd nhpek rash
or mnnp?z nrdpr madp payahlp and apnt tn:
PNC Mortgage
Collections Center
3232 Newmark Dr
Miamisburg, OH 45432
This is an attempt to collect a debt, any information obtained will be
used for that :purpose.
Enclosure
DR673
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the
date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the
entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
ro e
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybefore the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, if legal proceedings arc started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY (30) DAY period, you will not be required to pay attorney's fees
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default
foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by
performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice
will restore your mortgage to the same position as if you had never defaulted
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a 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 Sheriffs Sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required
payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER :
Name of Lender: PNC Mortgage
Address: 3232 Newmark Dr.
Miamisburg, OH 45432
Phone Number: 1-800-523-8654
Fax Number: 937-910-4009
Contact Person: Collections Center
ail Auaress: Loss."nganonUpncmortgage.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 Sheriff s Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
(DPNC
MOR11 L'
P.O. Box 1820
Dayton, Ohio 45401-1820
April 2, 2010
49459-0000012-001 -00 1 -000-"-000
1111111
7107 8381 6540 2106 0780
PNC Mortgage
3232 Newmark Drive
Miamisburg, Ohio 45342
Telephone: (937) 910-1200
Mailing Address:
P.O. Box 1820
Dayton, Ohio 4540 1-1 820
CORRIGAN,DANIEL L
623 3RD ST
NEW CUMBERLND PA 17070-2018
DATE: April 2, 2010
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to
foreclose Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP)
may be able to he1= to save your home This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your Countv
are listed at the end of this Notice If you have my questions you call the Pennsylvania Housing
Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact
an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN AD,TUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRASTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): CORRIGAN,DANIEL L
CORRIGAN,LESLIE A
PROPERTY ADDRESS: 623 THIRD ST
LOAN ACCT. NO.:
ORIGINAL LENDER: n/a
CURRENT LENDER/SERVICER: PNC
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face'ineeting with one of the consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST RRING 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 teleghonenumbers of designated consumer credit counseling agencies for the county in
which the proper is located are set forth at the end of this Notice. It is only necessaryto schedule one face-to-face meeting.
Advise your lenderimmediatelvof your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's 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 forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED
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 E VENTUALL YAPPRO VED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL
BE STOPPED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on
your property located at:
623 THIRD ST
NEW CUMBERLAND PA 17070
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s)
April 01, 2009 to April 01, 2010 and the following
amount(s) are now past due:
Monthly Payments 1,836.56
Corporate Fees 0.00
Late Charges 206.42
Non-Sufficient Funds .00
Fax Fees .00
Property Inspection Fees 72.00
Less Suspense Balance .00
Total Amount Past Due $24,091.74
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 $24,091.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD-
Pn=PntG muRt he made either h?4 caahier'n check earn fierl check naah
nr mnna?z nrr3er made p ayahl a and Sant tn:
PNC Mortgage
Collections Center
3232 Newmark Dr
Miamisburg, OH 45432
This is an attempt to collect a debt, any information obtained will be
used for that purpose.
Enclosure
DR672
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the
date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the
entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged
ro .
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybefore the lender
begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the
amount you owe the lender, which may also include other reasonable costs. If you cure the default within the
THIRTY (30) DAY period, you will not be required to pay attorney's fees
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within
the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default
foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by
performing any other reguiremen s under the mortgage. Curing your default in the manner set forth in this notice
will restore your mortgage to the same position as if you had never defaulted
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's
Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this
Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required
payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER :
Name of Lender: PNC Mortgage
Address: 3232 Newmark Dr.
Miamisburg, OH 45432
Phone Number: 1-800-523-8654
Fax Number: 937-910-4009
Contact Person: Collections Center
E-Mail Address: oss. ga ion Ca)pnemortgage.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 Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a
buyer or transferee who wi 1 assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR. DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
KML LAW GROUP, P.C.
Suite 5000 - BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
PNC BANK, NATIONAL ASSOCIATION
SB/M NATIONAL CITY MORTGAGE A
DIVISION OF NATIONAL CITY BANK OF
INDIANA
3232 New Mark Drive
Miamisburg, OH 45342
Plaintiff
VS.
DANIEL L. CORRIGAN
LESLIE A. CORRIGAN a/k/a LESLIE R.
CORRIGAN
(Mortgagor(s) and Record owner(s))
623 Third Street
New Cumberland, PA 17070
Defendant(s)
PROTNONOTAR"
Z12 ,!A!? l 7 AM 10= 03
Ct3MBERLANDICOUNTY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 10-5823 CIVIL TERM
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/ArGOLDBECK McCAFFERTY & McKEEVER
ichael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
-Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
_Andrew Gornall Pa. ID 92382
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
KML LAW GROUP, P.C.
Suite 5000 - BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
PNC BANK, NATIONAL ASSOCIATION
S/B/M NATIONAL CITY MORTGAGE A
DIVISION OF NATIONAL CITY BANK OF
INDIANA
3232 New Mark Drive
Miamisburg, OH 45342
Plaintiff
VS.
DANIEL L. CORRIGAN
LESLIE A. CORRIGAN a/k/a LESLIE R.
CORRIGAN
(Mortgagor(s) and Record Owner(s))
623 Third Street
New Cumberland, PA 17070
Defendant(s)
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 10-5823 CIVIL TERM
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 / - 12 - I12Z
DANIEL L. CORRIGAN
623 Third Street
New Cumberland, PA 17070
LESLIE A. CORRIGAN aWa LESLIE R. CORRIGAN
623 Third Street
New Cumberland, PA 17070
KML LAW GROUP, P.C.
FWA GOLDBECK McCAFFERTY & Me EEVER
1
By:
An a M. Smith , Legal Assistant
asmith@kmllawgroup.com
215-825-6325 (Direct Phone)