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HomeMy WebLinkAbout10-7097 t 5 ..~ UDREN-LAW OFFICES, P.G. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE .ALAN M. MINATO, ESQUIRE ~CHANDRA M. ARKEMA, ESQU; ADAM L. KAYES, ESQUIRE Plaintiff Cumberland Country v. Mike E . Ford ~ r~ _~~~ Jennifer L. Jenkins _`NO. V 1&5 Valley Drive Carlisle, PA 17013 Defendant(s) - ID #043.02 - ID #45362 - ID #34576. - ID #75860 IRE - ID #203437 - ID #86408 ~1!~lARGUERITE L. THOMAS, ESQUIRE - ID #204460 ]DANIEL S. SIEDMAN, ESQUIRE.- ID #306534 ~JEROME B. BLANK, ESQU:LRE - ID #49736 Tni00DCREST CORPORATE CENTER :111 WOODCREST ROAD, S172TE 200 ~~HERRY HILL, NJ 08003-3620 X356-669-.54`00 ~~leadings@udren.com PNC Bank,-National Association :COURT OF COMMON PLEAS 3232 Newmark Drive 'CIVIL DIVISION Miamisburg, OH 45342 c'y c~ -rt ~' ~ _ ~ ~='x°I :~ '" ~y a t3 ~ ~~ t-'-,~ ~ ~ ~+ ~~' ~~ ~~ ~~ c~ ~ a~- COMPLAINT IN MORTGAGE- FORECLOSURE Y'OU HAVE BEEN SUED IN COURT. If you wish to defend against the .claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served,: by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the ease may proceed without you and a judgment may be entered against you by the Court without further notice for. any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other -fights important to you. YOU SHOL7LD 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.. P1tOVIDE YOU WITH INFORMATION. ABOUT HIRING A LAWYER. IF YOU .CANNOT :AFFORD TQ IiIRE A' LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RIEDUCED FEE OR NO' FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ~ ~~°~ ~~ 2~ asoc~ S~ S AVISO Le han demandado a ~a.sted en la Corte. Si usted quiere defenderse de estas demandas ex:puestas 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 1as demandas en contra de su persona. Sea avsado que si usted no se dafiende, la Corte tomara medidas y :puede continuar la demanda en contra suya sin previo aviso 0 :notficacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisones de esta demanda.. Usted puede perder dnero 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 SERVICIO, VAYA EN l?ERSONA O LLAME POR TELEFONO 'A LA OFICI1~iA CUYA DIRECCION' S'E N~NCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within :30 days after receipt of this Notice and the attached document that the validity of the stated.. debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify ius in writing of a dispute within the 30 day period, we will obtain verification of the debt or ~~ copy of a judgment against you, and mail it to you. Tf you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, .Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. Current assignments of mortgage of record are as follows. Assignor: First United Mortgage Services Assignments of Record to: Integra Mortgage Company Recording Date: 11/:L/93 Book: 457 Page: lla6 Plaintiff is successor by merger to Integra Mortgage Company.. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the :real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage, hereinafter described, at the instance and request of Defendant(s), Plaintiff. (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was .executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 7L019 (g) , 7'he information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 165 Valley Drive MUNICIPALITY/,TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland LATE EXECUTED: 10/29/93 SATE RECORDED: 11/1/93 BOOK: 1174 PArF~ 77ti The legal description of the mortgaged .premises is attached hereto and made part hereof. 4. Said Mortgage. is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or L refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pair the installments of principal and interest when due in the amounts indicated below;. (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of :11/2/10: Principal of debt due $72,875..12 Unpaid Interest at 6.750 from 12/1/08 to 11/2/10 (the per diem interest accruing. on this debt is $13.48 and that sum should be: ..added each day after 11/2/10) 9,441.64 Title Report. 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/ (Balance) (The monthly escrow on this account is $186.37 and that sum should be added on the first of .each month after 11/2/10) 4,307..36 Late Charges (monthly late charge of $32.35 should be added in accordance with the terms of the note after 11/2/10) 6'14.65 Other Fees 172.50 Attorneys Fees (anticipated and actual to 5% of principal) 3,6.43.76 TOTAL $91,660.03 7. The attorney's fee set forth above are in conformity ~w:ith the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, :reasonable attorney's fees will be charged in accordance with the :reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date ~~ppearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not :been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $91,660.03 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LA,~ni ~C~.FfFICES, P . C . BY: ox~eiys Plaintiff RK J. U RE ESQUIRE STUART WI NE o, ESQUIRE LORRAINE OYLE, ESQUIRE ALAN M. INATO, ESQUIRE C;HANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL SIEDMAN, ESQUIRE JERON[E B. BLANK, ESQUIRE :.rs~. ~f,k+i` CEZtT,~~N lat ttf groc±ne3 s:itzixtc ~.rt eYes Township :~fi ~~+kd~.~s,ax, Cour..t}~ 4f Cu€ak~4rl~nd rind StatE oY= t~eatnwyXvania, more }~tx'~:S.du~.atr3y~ tsaaunc3ad aafci da~a~r<ir~r«a arscnrdit~s~ to Flzah +~~ Lots $Cn l6l8S aas Clt~v~uzi~xa..r Aaxas I¢a, z, : a~.cl ~~,an vx Zdi:s Maiasq rms;:>Ed~Ct Sat the ~EPi-~a +a~ the Raccr~e~ oT ~iae(i;: ras' a~una~arlund Cc+u~tt~r, Pann~syl^~ania, in Asia ~aok xo, s, 1',ygo $3, as ~ollat~a: arGYtaNiidr at ~ gairtt, acid paint hckn9 the NortYi.VaSt corner ur Snt>;.reection at Vailey 6rive ant ~t~xk Wa} Rven~~:; 2H~#YC= a;lc~ng the t?r~,tsrr, Qid~ ~i~ t?ar3~ way Avenue in a tt~aa~tners.y airgctxnn; x.20 ~eetr x€are ar ].sw~, i:d ~ point; THE#xCE ~jraisa~c~i.3~5 iti b ;vesLC~Y.Iy direGtiatt 7? ~~at +a2o~ta3 t,tte sasstherr~ sic o!: Nail Uriua_ to h paint: ~';i~H€~ St: a southerly Aix~etian r~lc~Ytci the ea~td eit ri~~ rj~ iot $~3, 1aU £u~t, mars or Lr~as, ra ~ pctiztt on unSicy LrrivN, T~tEktu~ ixt ren eatst~sl.F kta:eLtian tiw test akcNC,~ 'the nfirthea~n xiaa of tiizal7, ~Y arise to a ptrfhC, tkse gslaee of 8k'aYNP;INi3, B€IP3G :,c3t ~iE3, ~5~etia~rr ~tr=1°, ~sn saazd Pid*; ~f Lats. ~&ae above risa~rit~ed Ss~t ie a€r~~sot to f:3Yn 2~uiitiing ra~t:-icti.c~nY asad -^hv~nants attsehs~ to ~t3c9 applicable to szsid Yl,et3. E1~ZkFG the same pr-cmi;rae± Chat. ~'eftoY~~~ &~y~xt sraitlx a»d Arad~'cat ycxe Silt~,tn, nasbana anc3 satfe, by their decd '.r}ated tite day of , b$~3, Aria recoY;"tlsd in th+? r~Fti,:e of tlxs fte.-.aYxtkx' tie C;cedet, in aaa~ i'or Cnmb~3letsd ~oi;n'~lt. ~~r3naylvania, ah 4Sae+3 t`sook ~' u~riustta Pala g~rrt~ct nnta Mike ~, a~azc~ end ~'erst'e'ifer L. e'en#cih~,P nth s:in~le pcrso>ZS, tha NsnY"trlt54Csk.'~ Ycare3.n: :t! ~'riv Sftl4s 9g ~5 ;~. ,i,; c,i:~;t 3nr ihr e'd~bs'LNs1~ 4ti ta;:+~r' fir, •:,YCraS GoS+~ ~. .' ~7 J.t > '' ac refer ~~" EGbY ~. ~. }~~ €'h6i ~~ ~l~v 4 ~~1~ ~~:51m PO~~/~1~ ~ti1lt~312~Ti~ `I b.4$:3~ RNF t:,t1ME3~~LRP~CJ CIJU~6TY [ass#,#'[5~t33747 • P~ga 7 c~~ Y P.G{. Box 1820 ia~~~on, onio 4~4a1-182a March 29, 201a 4s~ 2a-ao~os 7 ~-oo ~ -~~ 1-aoaac~o-QOo FORL, ~1IKE E 165 V?1LLL'Y LR C~RI,ISLE Pt? 17013-8852 VIII!!I!ililu!VP!~Iii119~V!l ll~ PNC Mortgage 3292 Newmark drive Miamisburg, Onio 45342 Telephone: (9371910-1200 Maoiir~g ~,a~ress: P.O. Box 182a Day~#on, Ohio 454fl1-1820 L3~,T~: 1V~a,reh I9.2D10 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE l~{;~~l2E0~'NER'S N~IE(S}; FQRI);MIKL E ~~ FORI},JENNIFER L PIi;C1PERTY ADDRESS: 165 VALLEY L}R L C )~ '~ A C: f'. T . N t : 3 .: OO~J84795b6 {{ ''~~ y ` ~ p ; T 7 '' p7" 7 ' ~ 7'] il Z'i& i J il V t1 1 ~ L.L i 1 V Li ~ t `~.. ~ / ~ ~ . f p Tj 7 g ~ p ~] ' g ' ~ 7 ry 7' '( } ( 7~ q p/" L l.i=1L`s3.:i!ti 1 L.~1M S.J1:.A4.•~fJl%R 1~1L,ER. 7 y ' ~ 7 r l~1V l.• ~: E~ ~~ 'S EN~~ i TC~~C~E SS~S'T ~E PR ~~ YOB l~~v 1~E I/LI~IBI~1/ ~~R 1~~nL~l~cr~z ~sslsT~I~TCE ~~H~Cx CAS s~~~1~ YC~~~ x~l~l~ ~R~~ IiC~RFCI:os >r~l~ ~Nl~ HEZP Y®~ 1~~~E F 1°~~R~ l~~z~T~i~ T~ >~~Y~E~TS. I Y~I? ~:C?MPLY WITH TIIE P'RO~~SIONS (?F TIIE ~I®~?IEO6i'NE.R'S E.I~IEI2GE.NCY ~'It4Id'i'Gr~GE ASSISTANCE ACT' I;~I' I93 (TIIE "At;4'"); YQU _l%[,~~' BE ELIGIBLE .FOR E~VIERGE\'CY ~'[ORTGAG.~ ASSIST'ANC:Ec ][F'L'OUR I~E~'~#,l1I,T IIAS BEEN CAUSEI} I3'~' C;IRCUI~ISTA.NCES ~E~€IND'4'OUId CON'I'{}L, J~F YCIET ~'E A ItEASC1NABLE I'RGSPECT (~!~ BEING ABLE TO I'AA' 3~OUR ~IORTGACaE IbL~YMENTS, ANT} lF YGU tiIEET I?TIIER ELIGIBILI'T`Y REQUIRE~II`JNTS ESTABLISII~I) BY TIIE PENNS~'I.,~'A~NI_~ HOUSING FINANCE AGE~C~'. TEMPORARY S'Cr~~' ®)~ F~7FtE~1"+CBSLT~g1E - finder the .Act, you are entitled to a temporary stay of foreclosure on ,~a~ur mortgage for thirty (30) daYS fi-om the daie oft}pis Notice (plus three {3} days for mailing). I3uring t1-~at time you must al-a-ange• and attend a "face-tc~-face'lneeting with one of the consumer credit counseling agencies listed at the end of tlii.s l~~tice. TH.iS ME~,TIlYG ]~'fUST.d~~''t~" ~tR imt=ir>,r rz7~ r~<,.tT~ g,~~.,s>a>n n.:„r .-.~.._.__,... ___-._.__ -- ~.~.,uan~it.ouaatti;a ~a~unL t;UUZatiellllU a~eneleS Ta]" the CC?I1ntV It1 wl~ich'tlie ro ertyis loeatedare set forth. at tlaeend oftha4'~lotice, It is onlynecessaryto schedule one face-to-facemeetinb. ~.clvise your ]ende~-anrm,_ ec]iatevcf your intentions. APPJ[,I+; CATION ~'~R 1VIC7RTGr~GE ~~SSIS'~'~NCE -- Yaur mortgage is it~l default for the reasons set forth later in this l~otic.e see following pages for specific information about the nature of your' default.) You heave the right to apply for fmanc,ial assistance fi-oln the. F-lomeowner's llmergencyl~Toatgage 4ssstance Pragrarn. To da so, you must fill out, sib ~l and file a coanpleted Ilomeo~~aler'sEmergency Assist~aaice Program application with one of the designated: consuiiier credit counseling agencies listed at the end of this Natiee. Qnly coa~sumer credit counslhng agencies ha~re applications far the prograrr~ and. they will assist you. in submitting a complete application to the Pennsylvania f-lousing Finaiiee Agency. To temporarily stop the lender frown fi]ing a foreclosure ~actian, your application MI3ST be fort~,7arded to PHFA and. received u7ithin thirty. (30) days of your face-to-fare meeting with t11e counseling agency. Y~Lj ~'H(J~i'Ll~ ,T'IL~ ~ HK11~Ad' AI'PZ,ICf#TICIV AS St}®l~rr AS PCISSIRLE IL' Yp~,~ I~'A~'E A HKETL?~'C~ 1v8TTH A C~~1VS1sL~l~G AGE1V C,'Y T~TTHIL'4 33 I~14:YS ®F THE R~S7'/EL4RK HATE t:~F THI,~ N~TI~'L° A~~'Z71~'I~E Ater ~PPLICATl~L'~% WITH I'~IIFA ~I'ITHI1~' 3lf DAYS ®F TId"fIT tiIEETLt'YU, THEM' THE LE?~DER It'ILL I~'E TEt1IP~R~4RILY 1'REF~'i~TED PR~,~g1'.S/T~AgRT7IL'{Y+CF A F/~t~~^IZ,~/CL~t~:(S~'~pR~E`gACAI..?~TST Y®UR PRClPL'RTI; AS EXPL,9Li7Ell AB®VE, I11' TIIE SL`CTI®L'~L`ALL.~'I) ffT~L~l E~i.~dll9RljJTAd i.Jd' ~VRii a.lLilS4~'il.8i ~. g/~d__ __r __ _ ,~.s~T..y~ie..~.:±. .. .._~.a+. i-~~rys i.a ac,~ta L7'.~Y G~1AY~°+dS.,tG.Y~rC*,JnIY~iU l.*(j~~t',~c}T~,i,'y l{~jf~'!]~' ~?~+'.[t.~flDJ7l~il, pA~* LlAy TTGp.~ APPLI L.fi4I[/t~4T r/g~L 1~'T®T L"REYZ:,'YT TIZL'` L.b:i'Y.LV.g;~R d'Rv1~.~3 TAt4Tl`: T'rV !1 I'7f{IEi.,L~:7Vt4.~AL TI®L~j ,u g,iT If' Y41 R.~~Ll. APPLICt9Tin,'dT IS ~'L~';'4TITALLI'APPR~~I) ATAVYTIr1LE BEFf9REA ~.SIIL'RIFF:SSALE, THE F~3REC'L~SLRE TT'ILL RE ~'Td~'I'RED. CONSUMER CREI<}IT CO~NSEL)<NG AGENCIES -- If y • -- • cau meet with: one ofte con.suaner ca-edit counselin<= ate ' ~enetes acted at tl~e end of this nonce the lender may NAT take action against you for thirt~r {3~l} days after the date of this meetln~~_ ~F Y1ATYlf C a~ar~ra~cAn .,,,.a +n1,,:.,1. .<,.._.__._v_ _._ ~ . A~ENCI' ACTION -- Available funds for. emergencymortgage assistance are very limited. They mill be disbursed by the Agency under the eligibility criteria established by the Act. 'The Pennsylvania dousing Finan€Je:~gencyhas sixty {6U} days to make a decisionafter it receives your application. During that time, no foreclosurepri~ceedintis ~~xi1l be pursued against you if you have inet the time requirements set forth above. ~''ou v~ill be notified directly by th.e .Pennsylvania dousingFin.ance .A.gen.cy o.f its decision on your application. ~dOTIa IF YOL? ARE CIJRRLNTLI' PI~OTECTEI} III' THE TILING OF A PETITION IN IiANIs~RUPTC~; TH'~ TOLLO`3'INC PART OT THIS NOTICE IS FOR INT01214~IATIO\7 P OSES ONLY ANII SI-ICIITLID NOT I±E CONSIIYEREII AS AN ATTE10!IPT TO COLLECT THE I}EI;T. e {If you h.ati-e ftl.ed bankruptcy you cats. still apply for E~nerge~tcy c~rtgage Assi.sta»ce.) ~iC}W TQ CI.TRE Y'C}€7R ~l~~RTAE ~}EFALT'L°T (Br~n~ it. u~ to dale) . NATURE OF TFIE'DEFAtTLT -- The MORTGAGE debt held by the above lender on you-~° property located at i65 VALLEY DR CARLISLE PA 17013 IS SERIQL7SLY IN DEFAULT because: YQli ?3~VE NOT MADE MONTHLY MORTGAGE PAYMENTS for .the following months} ~7anuary 01, 2009 to March 01, 2010 and the following amount(s) are now past due: i~tonthly Payments 833.38 Corporate Fees 0.00 L~~te Charges 388.20 R?on-Sufficient Funds 20.00 Fax Fees 20.00. Px'operty Inspection Fees 99.00 Less Suspense Balance .~~ `I°cyteal Amc~uaxt Past Due $13, 038.9 HOi~ TC) CURE THE DEFAULT - You may cure the default 'v7it12in thirty ;30) days of the date of this notice EY PAYING THE TOTAL AMOUI3T PAST DUS TO THE IEENDER, WHICH IS $13,038.95, PLUS A~VY MORTGAGE PAYMENTS AND LATE CHARGES s~?HICH' BJCOME DI7E DL3RII~rG THE THIRTY ,30} DAY PERIOD. ~~m~r °~ m~a~'- hP martP Pi thcr ~av raShi r>r' ~ rho^k rare-, ~= a~ rhPrk a~~ nr m~L'ies% nr~3pr mangy r'~a~rahlP ark S~ni- t-n; PNC Ivtortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, an~r in_ormation obtained will be used for that purpose. Enclosure DR672 Imo' I'()U DO NAT SURE T 131~FA[1LT -- If you do not cure the default within ~'I~IR'fY {30} D~.YS afthe date of this Notice, the lender intends to exera:ise its rights to accelerate the mort~a~e debt This means that the enti:~-e outstanding balance of this debt will be considered. due lmmec3iatelyand you may lose the chance to pay the mortgage in monthly installments. If Full payment of the total amount past due i.s n.ot made urthitl TII.IRTY {3t1} DAYS, the lender also intends to instruct i.ts attonzeys to start legal action. to foreclose neon vour xrlort sued ro 'erty. - IF '1[sliE 1~'[GRTG.~GE IS F(~12ECLQSE~ UPON -- The mortgagedpropel-ty will be sold by the Sheriff to pay off the; mortgage debt. If the lender refers your case to its attorneys, but }Tou cure tl~e delinquencybeforelhe lender begins, legal proceedings against you, you. will still. be required to pay the reasonable attorneys fees that ujere actually incurri~d, up to $50.00. however, if legal proceedings are started against you, you wi11 have to pay all reasonable attonrey's fees actually incurred by the lel~der even if tiaey exceed $50.00. Any attorney'sfees will be added to the amount you Dore the l.en.der, ivhicll lnay also include other reasonable costs. If' ~rot~ cure the clef°auit ~~ithin the T RTI' 1301 ITdAY irleriad, you ~ti711 not be required to i~ai~ attorney's fees ~?TJfIER LFI<Tp3Eld. RE1~~EDIES -- The lender mayT also sue you persanally for the unpaid principal balance and all other Sums due under the mortgage. RIGHT TC3 CURE TIDE DEFAULT P ~3R T~} S1=IERIFF'S S.~I1E -- If you. have not cured the default uritl>in the 'fI-ARTY {30} DAY periad and foreclosure proceedings leave begun, ou still, l~ati-e the right t~ r.,,r~- tl,r ~nf~„t+ _._ , - ., ,s~a~~,aixiaiiy~„_x~v vizicrt iLt~uttt;ltl~zi~5 ullacr isle moI't~?'a~e. d.:Urtn~T your default in the manner Set forth in this notice 3ritl a-e,store vaul• mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHEFPI:I<F'S SALE DATE -- It is estimated that the earliest date that such a Sh.ez-iff s Sale of the mortgaged property could be held would be approximately nine.- ten months from the date of this 1Votice, A notice'of the actual date of the Sheriffs Sale ~~•ill be sent to yot~ before the sale. Of course. the amount needed to cure the'. default ~~~ill increase 1:1~e longer you. wait. You may find caul at any time exactly uThat the required payment or action well be by contacting the lender. ~I~ TG CQI~TACT THE LENDER EI1FECT (7F SI3E FF'S SALE -- You. should realize that a Sheriff's Sale will end your ownership of the mortgaged prope~~T and your right to occupy it. If you continue to live in the property afier the Sheriff s Sale, a lawsuit to remove you and your furnishings atad other belongings could. be started by the lende~° at ally time. ASSUi~~TI®N t<7F 11'I~DRTGAGE -- You $nay or may not ~ {CN11CK ~NiE} sell or transfer your home tea a buyer ar transferee who will assume the mortgage debt, provided that all the outstanding payrrlents, charges and atta;;y's fees and costs are paid prior to or at the sale and that the ether requirements of the mortgage are satisfied. ar A ress: oss. it,gat~on apncmort~age.co YQI1 I~IA~ ALS® IIA~TE 'I'~IE ItI~IIT: ~ TO SELL THE PROPERTY Tt~ OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FRONT ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ® TO I-3~~1t~'E T`FIIS DEFA.LTLT CLTg,ED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ~ TO I~A.VE THE ?e~C7.RTGA.GE .RESTORED TC) TI-IE SAME PC)SITION AS IF NO DEF'.A6.7LT IIAD OC;CUI~RED, IF YOU CURE TIIE DEFAULT. {FIO~VEVER, YOU DO NOT HAVE THIS RIGHT TO ~;UR.E YOUR. DEFAULT MORE THAN THREE TIMES IN ANY C.ALEI'~'DAR. YEAR.) • TO .,gSSERT TIIE NONE~'ISTENCE OF A D.EFAL~L,T IN A?.'~r FORECLOSURE PROCEEDING O.R A,.NY OTHER LAWSUIT II`~.TSTI~'UTED CINDER 'THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTI-TER DEFENSE YOU BELIEVE YOU I~'IAY HAVE TO SUCH ACTION BY TIIE LENDER. • TO SEED PROTECTION UNDER T. HE FED.ERA.L B ANKRUPTC~' LAW. ~f~NSLTI~7ER ~I2EDIT ~"E~I1\SELING A~E~T~IES SEI2~TI'~TG Y~I:31~ ~~~I'~I 1~.C). Box 9824 [3a~~ton, 0hia45449-9824 ~41a~~~ i9, 2410 49120-OddO913-dd1-001-OOO-ddd-Odd F'C}?Z~, JED7i~IF:EFc L 16 5 VALLEY %R CARLISLE PA 17013-8852 lilll!!!!"Ililnlu~!IIIi~I~I~!I~ PNC Mortgage 3232 Newmark Drive Miamisburg: C3hia45342 Telephane: {937} 994-9244 Ma6ling ~4ddress: P.CS. Bax 9824 Daytan; Ohio 454fl1-1824 I)AT~: IVlarch 19.2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official neatiee that the ~rt~a~e nn y€rur hnme is in default, and the lender intends to foreelnse. Spee~f~e ~nfc~rrnatic~n abaut the nature €~f the defanit is prnvided in the attaehed ~a~es ~'he nname. address and t~bane number ~rf C'c~nsu~ner ~'redit ~'~unselin,,,~ A6encze~ servin,~~~o~r ~'au, n~tv are ~IS~P~ t3~ ~be eTIC~ f}f tht~ ~tlf1C'P Tf r~n,t 11av~ ~~ir (,,,ort:,-.,,r ,..,., .__.._. __it .e. __ This :~d~tice ~t~ntains irnp~rtant legal infnrrnati~n. Tf y7ou have easy- cluestic~ns, represeaatati~es at the otasdetner credit C'auns~ling Agency rnay~ be able tca help explain it. ~~~ nta~ also wait to contact an attarney in ~~atar area. The local her association nlay be Abele to help you find a l.a«yea-. H4~1~EQWNER.'S NAME(Sl: FORD;I~IIKE L FORD;JEN£.~IFER L PROPERTY ADDRESS: 165 VALLEY DR LO~:'~1 ACCT. I`~0:: OOOb479586 ORt{ ANAL LENDER: n{a CURRENT I.ENDEI~.r"~'ER'l%ICER: I'NC. Bank ' E ti~T~E 'S E _ ~~N~~ '~'~, ASS~ST`1~.1v~E Ca A.l~!~ IF ~'GU ~:®~'IPL~' 1~'I'f'II 'PIKE FR(~~rISI®NS ®I+' T.IIE FIOI?IEOWiTER'S El~!IEI2GEdCY tIORTG~GE ASSISTANCE ACT ~iE I983 {~'I-IE "AC'F"~, ~'~}I,T yI~Y BE ELIGIBLE I+CI.R E:'.~'iE1;sGE'vC~' :~%EC3R~'GAGE ~1SSIS'~',4\CE: IF' YGlURI1E)N`AULT IIAS BEEN' CAUSER BY C:IRCCiI±lIST~"4'CES BEY€~NI}'t'GL7I~ CC3NTItOL, ® ]~F Y(j~J IIAAVE A I~ASGN ABLE I'RGSPECZ` OF' BEING ABLE T€3 PAS' 3'UIJR ~It'JRTGAGE I' ~:~'a~IENTS, AiVD l:~' Y®LF 1~1EE.T {~T~IER ELIGIBILITY I2EQUIRE~VIENTS ESTA~LISITEII BY TIIE PENNSYL~jAA?dIA PI4)USING 1~~~'AN~'E AGENCY. TEl~'IP(~i~AFtY STAY ~}E ~+®RECL.'0-SU.F~E Under the Act, you are entitled to a temporary stay of foreclosure on Tour mortgage for thirty (3[}) days fi-om the date of this Notice (plusthree {3) da~rs for 7nai.]ing), During tlaf time. you ar~ust at-~-ange and attend a "Vface-to-face'meeting with one of the con.suarter credit couilsel,ing agencies ]fisted at th.e end of this Notice. TH.:tS NIEE°I'I<NG tbll;,iS~ ®CCB:FIt ~'ITI-IIN €""i`Il 1DAYS OF THE SATE £;}F THI4 1~®T1C~:.:IF YC)t T TlC~ 'VrIT Li. T3T~T U L'(1D L'n ,r r^nr rar H~~% TCI BRINC'r YnIJR VIC~RTC3~C'T1=~ ITP TC~ I~A'TE. CC~I`dSl:,?It~fE-R CR.ET3IT CI~L'NSEL~NG AGEl~TC>fES -- If you meet with one o.f th.e consumez• credit counseling agencies Bated at the end of this notice, the lender may NAT take action a~aTnst you for thiT-ty (3oj days after:' the date of this meeting. 'The names.:. addresses and tele . honenumbers c.~f desi Sated consumer credit ccaunselittU a~enciea' fbi- the countv.in. urhich the~aronertt~T is ]ocatedare act forth. at the end ofthis Notice. It is on]y necessaryto schedu]e one face-to-face meeting, Advise y€.~ur ]enderi_m~rie~ d_ iatelvaf your intentions. APPI.ICATI~N FGit 1.44~IOI~TGAGE ASS~T~'`dCE -- Your mortgage. is in default for the reasons set foT•th later in this hz€~tic~ ;see follo~~•ing pages. for specific inforrn~ttion about the i3ature of your default.} Yoe have the right to apply for financial assistance fi•oin the Ilomeounaer's Emei-gencyiVlortgage Assistance P~-ogia~n. To do ao, yotT must fill out, sign and file a csa~npleted I~omeo~vner'sEnzergency Assistance Pi-ograTn Application with one of the designated,.consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have a~aplications for the prograzr~ and. they will assist you in submitting a complete application to the Pennsylvania 1=lousing P'inat2ce Agency. To tem~oraril~ atop the ]ender fi•om filing a foreclosure action, your application MUT be forwarded to PHF`A and received urithin thiT-ty (30} days of ~rour face-to-face meeting Eiritlz the counseling agency. Y~L' 5.~~4lL'LD ~`dLE ~ fLE~AP fI~'PLIC"IIT'I®1'!' fI,! .SIC3t~1~4'' fI.S' 1'~3,SiS"Pd~~~ II' ~'®Zl 1'~AG'E' A 1i~L"~~'1~ivCi ~'dT~l A C~£il~%~ELI~G ~4C~1tiCY T~7~'HI1V ,33 II14I'S d?~' THE' P~,~7'IVI<~RI~ 1}fiTE OF T~IIS ~i~1filC'E ~~'~~ FILE Alt'~4PPLICATIa1V TYITH ~'~F1L YT ITHIr't 3t1 DAYS (?F 7'DA7` ltLEETL?VG, TLIE1l 7'HE LE_11t'DEI~ Y6'ILL I$E T'EMI'~}~4RILY PdtEVE1~rTED Fi~2Qt2'.ST,4RP"'II~C ~# ~f?RECLtISL~RE' AG:4~1t:S'T YOZIR d?R~1PE~TY, AS.E~d'LAI.I~ED ,4B~iJE, d~V BILE ,SECTIO1t C~LLL'l3 "7'L'1~'~iR,9:IZ3':S7'19Y" Off' .FDREC~(1SL7RE ". pp~~AA33r ppt^~ +~ /~1 ig~ ~+ p~7 #, ~p.~g~^ £ ___ - 7s !~ {*7+ 7~~.*~a.7. .,~~.+u.~q:l eel vnreT Eyn~yGa~.)y.Cn p~11161~~~*71'7L"~.1Y11py~13.~p3*: f~ L~f~B a~'Ey A£l"Llt~r~a^Fay.pll~J2i~Br7CCr~I.~L^TLTt~L~T~Tl7~ fL"p.[l~~iYA~(71~t7t~~pll~lTi~L'7tl.t~,7~DgE~Ii4r.7~+i~7Y,VTl-~ixi~7?fL~/~l~ipd~[LtfT~gs~gf~l p~p'•P~TJ~\p~f'sqC*tei+i,ClaTlETlll~L^'egaf~i,Xad~®~ytl'y~+LTlt~7~'LT~~y~`T IYFi~aa~7ltlyt ~r~+i"~e~d CtBpI~I LIi. Y~ f..al f~YB:.t~Yi Vf9.L~,.YIl.L-.&"LI.C/f I:' LP !iL lE;7tC X.L.`.YB.L: l3.Lil'LJlIL: f2. a7.IY~24.i.!'.L'rJ a3tBI.L"~, .f.23E FVli.ELLV~lJ.R.L'. YlIYIi A~EIV~I' ACT~~N -- available funds far emer~encymartga~e.assistance are very- Iim.ited. They F~=ill be disbursed by the agency under 'the eligibility criteria established by the act. The Pennsylvania IIausing Fin.an.s~e a~er~cyhas sixty (6t)) da~Ts to make a decisianafter it receives year applicati.an. During that time, na farec,la5ure praceedings will be Pursue:I against you if you have met the time requirements set Earth abave. au. u,ilI be ratified directly by the Pennsylvania FIausinb .Finance Agency of its decisian an year apfalicati.an. NC9TIs: IF Y®U aI3E CURRENTLY PItCDTECTLI} I3Y TI~II1 FILING t~F A PETITION I~ dl~tl~2I,TpTC~>, TITS F®LLOZ'~'ING I'~RT C9F THIS NGTICE IS I~ 63R INFORIYI.4TIt3N PURPOSES QNL~' ~NLi SIIC)ULI) Nor r~E c~vsl~ElzED ~s .~N .~TT~~~pT To coLLI;cT TILE DEI,T. (If you .have filed t~ankruptcy you. can still apply for iv~ner~encyI~IoL-t~age .Assi.Statace.} IOW 'I'Q CtTR.E Y'C?UR Mt~RTGAGE DEFAULT {~~i.~.g i~ u to dale} . NATURE C3F TFiE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 165 VALLEY DR CARLISLE PA X7013 IS SE`RiOL~SLY IN DEFAULT because; YOU HAVE NOT Pa,ADE MONTHLY MORTGAGE PAYMENTS for the following month(si January Q1, 2009 to P~Iarch (31, 2010 and the following amount f s } are nova past due ; Monthly Payments .Corporate Fees 833.35 Late Charges 0.00 388.20 Nan-Safficient funds Fa.x Fees 20.00 Property Inspection Fees 20.00 Less Suspense Bala_rsce 99 00 00 Total Amount Past Due $13,038.95 HOW °TCs CURE THE DEFAUI;T - You may cure the default within thirty {30) days. o= the; date of this notice BY P.~iYING THE TOTAL AMCtUNT PAST DUE TO THE LEI3DLR, WFIICH IS $13, 038. °5, PLUS AItTI' MORTGAGE PAYMENTS AND LATE CHARGES INFiZCH' BECC}ME EUE ~URINv TEE THIRTY (30) DAY PERIC?D. ?aa ,nFnTS mi~at i, ~~ ~k ~.,_- ~ matir.~ ai i-har T-iv raahi ar' ~ ~ ,-•p,~r~ -F= Rra ,-}-~ ~, asl~ nr m,~~v ('77^ftPy mariP n ',i-•~,. ,•n ar~r~t 1-n; PNC Mortgage Collections Center 3232 :~Teiamark Dr Miamisburg, OH 45432 This i;s an attempt to collect a debt, any in=ormation obtained will be used for that purpose. Enolosz~re DR673 :lF rt~<)U l]E3 NGT' ~U THE I)EI+':~UI.,T -- If you do not cure ti7e default w~ithiri T1~1RTY (30) I~A~ S of the. date of this .Notice<the lender intends to exercise its rights to accelerate the amart~a~e debt This means that the entire outstanding balance of this debt u~ili be considered due immedzatelyand you may lose. the chance tv pay the. mortgage in znoi~thly ii~stal.lmeiits. .If full. payment of the total amount past due i:s n. of made within. THIRTY (30) Dq`i'~;, the lender also intends to instruct its attorneys to start legal action. to .fareclase u,~n vaur martga~ed ro aerty. IF THE M~}RTGAGE IS F~RECL()SE.D UP®N -- The mortgaged property u-ill be sold by the Shei-iffto pay off the mortgage debt... If the lender refers your case to its attorneys, but you cure tl2e delincluencybeforefhe lender begins legal proceedings against you, you u~i11 still be required to pay the reasonable attorney's fees that Fvere actually incurred, up to ~St}.Op. IIo~•ever, if legal proceedings are started against you, you will have to pay all z-easoizable .attorney's fees. actually ii~curi-ed by the lender even if they exceed $St1.{l0..Aizy attorney's fees kill be added to the amount yogi awe th.e l.en.der; which ma.y also include ether reasoi3abie .costs, Ifyouu cure the default wyithin the TJI-IIR'I'Y t301 1DAY heriiid you will net be required to paF~ attorney-', tees TITHER I,El~7I3ER MEDIES -- The lender may also sue you personally for the unpaid. principal bal7rice and. all otltei sums due under the mortffage. RIGHT TG ~'URE T"HE IIEFALTLT PRI®R TCI SI~ERIFF'S SALE -- If you havenot cured the default within the TI-ARTY (30) IyA1' period and foreclosui°e proceedings have be~un_ vni~ .crilt h~z,~ tt,n r;~i,+ t~; ,,,,,.~ ,,ate .~~~ ._,;. L~.,i~~,~~,~uiG adze una env orner costs .connected with the Sheriff's Sale as s ecf"ied in writing b the lenderYand by ~sei-formin~ env other reciuii•ementsunder the ait~a~e. wring your default in the manner set forth in this native wv~ll. resters year mortgage to the same pcisitian as ityou had never defaulted EARLIEST POSSIBLE SIIE]R.IFF'S SAIsE MATE -- It is estimated that the earliest date that such a Sheriff's Sale of the 7nortgagcd pr©pcrty could be held would be appra~imately- nine -ten months fram the date af' `this Native. 4 notice of the aetual date of the Sheriff's Sale u•ili be sent to you before the. sale. 4f course, the amount needed to cure the default will increase th.e longer you wait. You may f?ifd out at any time exactly urhat the required paytizeilt or action will be by contacting she lender. HO~~' '~Q ~'ONTA~'T THE IJENI)ER EFFECT CIF SHERIFF'S SALE' -- You. should realize that a Sheriff's Sale will end your cywnership of the mortgaged property and. youi° right to occupy it. If you continue to live in the pi°opci-ty after the Sheriffs Sale. a lawsuit to remove you and your furnishings and other bclorigings could be started by the lender at airy time. ASSUMPT'I®N :(IF M~IRTGAGE -- You may or may not X (CHE~'K ONE} sell or transfer youz- home to a buyer or transferee who v~=ill assume the mortgage debt, pto~-~ided that .all. the outstanding pay=ments, charges and attoe~;'s fees anal costs are paid prior to or at the sale and that. the other requirements ofthe mortgage are satisfied, ~..:(lI1La£$ L`ed'9an; 4.,OlleCtianS enter Y~~J ~~ ALSO I~.~'6T:~ TIDE I~~~ITt ® TO ,SELL THE PROPERTY. TQ OBTAIN- MONEY TO PAY OFF THE MORTG~A.GE DEFT OR TO BORROt~' h>IO~TEY FROM ANOTHER LENDING INSTITUTION TO PAY CUFF THIS DELI. ~ TO HAtrE THIS DEFAULT CL~;ED BY ANY THIRD PARTY ACTING ON YOUR .BEHALF. ~ T'O II.At~'E THE MO'RTG:AC.;E RESTO.RE.D TO TFI..E SAME POSITION- .AS I:F NO DEFAULT HA.D ~`>CCI:~`KED, IF YOU CURE TIIE DEFAULT. (IIOtVEt'ER, YOU DO NOT ILAVE THIS RIGHT TO CI1RE YOUR. DEFAULT MORE THAN THREE TIMES I-N ANY CALEI~~DA.R YEAR..} TO f1SSERT THE NONEXISTENCE OF A DEFAULT IN ANT FORECLOSURE PROCEEDING O.R ANA OTHER LA~TSL7.I'I' INSTITUTED UNDER TFIE MORTC:zA~TE DOCUMENTS. ~ TCD ASSERT AI>IY OTI-IER DEFENSE YOU BELIEVE- YOU MAY IIAt~E TO SUCI-I ACTION BY TIIE LENDER. ~ Tt;~ SEEK PROTECTION UNDER. TIIE FEDERAL B ANKRUPTCY LAt~%. C ~.l~S6.1...611~. ~HSL'' ~6T {,,, q.l V.~5~7E'.JJ..Ii.Y Cl~ ~X.FEiy~fE:7 63L' II~~'.[.._.'Y I.A ~Ti.1 l~Vi'ffi~~T P V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, ~. corporation unless designated otherwise; that he/she is authorized to make this Verification and does so ]~ecause of the exigencies regarding this matter, and because ]Plaintiff must verify much of the information through agen.ts,. and because he/she has personal knowledge.: of some of the facts averred in the foregoing pleading; and that the statements made eLn the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and repori~s of Plaintiff°s agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 49x4 relating to unsworn falsification to authorities. /~ UDREN S, P. C. BY : ~_ Atto y or P aintiff MARK J. U R N,SQUIRE STUART WI N G, SQUIRE LORRAINE OYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. AR MA, ESQUIRE ~~ L• - 'ESQUIRE.. MARGUERITE L. THOMAS, ESQUIRE DANIEL S. SIEDMAN, ESQUIRE JEROME B. BLANK, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???tr ql ? utnbrr}? Jody S Smith ' Chief Deputy Richard W Stewart c r7jCD Solicitor aF sc? - E ?.a?? .C -0r rte- ko C F-1 PNC Bank, NA vs ;z bq* Ndrnbe #-"7 . 210-797 Mike E. Ford (et al.) SHERIFF'S RETURN OF SERVICE 11/15/2010 10:53 AM - Jody Smith, Chief Deputy, who being duly sworn according to law, states that on November 15, 2010 at 1053 hours, she served a true copy of the within Complaint to Mortgage Foreclosure, upon the within named defendant, to wit: Mike E. Ford, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. JOD S. SMI DEPUTY 11/16/2010 08:14 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 2014 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer L. Jenkins, by making known unto herself personally, at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 November 17, 2010 RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF +cj CountySuite Sheriff, Teleosoft. Ine. UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 PAIGE M. PRONOVOST, ESQUIRE - ID#309091 LEE SCHOTTENFELD, ESQUIRE - ID#91654 HARRY B. REESE, ESQUIRE - ID#310501 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadinas(a)udren.com PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff V. MIKE E FORD 165 VALLEY DR CARLISLE, PA 17413 JENNIFER L JENKINS 165 VALLEY DR CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL, DIVISION CUMBERLAND County NO. 10-7097 AMENDED COMPLAINT IN MORTGAGE FORECLOSURE C's C c? -4 0 -- W oa 7d? x G) v 2© ' tv YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la cone. 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 notificaci.on. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la. demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede deci.dir a favor del demandante y requiere que usted cumpla con todas ]as provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 M The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $32.35. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage, The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $91,831.77 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. PA BAR # 308367 NJ BAR # 13862010 '4 P.O. C Box 1820 Dayton, Ohio 45401-1620 March. 1-, 2:010 Nlik'dI?P?IInINgll!JI9?IIlil? 7107 83381 6540 2104 1970 PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937) 970-12W Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 4512(1-OCN,,G912-^PSi-DO? -4"•0.00-0Gf7 FORD, N,Ir;S E 155 VALLEY DR CARLISLE. PFD 1 013-5852 EXHIBIT A DA'FT': ?;rch 19, 20 10 ACS' 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) way be able to help to save dour home This Notice explains hove the grogram works. To see if HENIAP can help, you must MEET WITH A. CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice w Lh you when you meet with the Counseling Agenev. The name. address a p-hone number Consumer CTedit Counseling, A«e C S ming your h, are S the end of this Notice. If you have a ns v may call. vNv is Bousin¢ Finance Agency toll free at 1-840-342-2397. (Persons with impaired hearing can call (717) 780-1,86 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 SU.MA IMPORTAN`~NCIA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ES`IA NOTIFICAC16N O.BTENGA UNA TRADUCC16N IiNMEDIATAM-ENTE LLAMANDO ESTA AGE_NCIA (PENNSYLVANIA HOUSING FLN IAINI CE AGENCY) SIN CARGOS AL NUNIIERO MENCIONA.DO ARRIBA. PUEDE SER ELEGIBLE PARR UN P.RESTAMO POR EL PROGRAIVIA LLAMI ADO "H.OMEOWNER°S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA. DE LA PERDIDA DEL DERECIIO A REL?IMIR SU IiIPOTEC.A. HOMEOWNER'S NAME(S): FORD,MIKE E FORD,IENNTFER L PROPERTY ADDRESS: 165 VALLEY DR LOAN ACCT, NO.: 0008479586 ORIGINAL LENDER: n/a CURRENT LENDER/SERVICER: PNC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WINCH CAN SAVE YOUR HOME FROM FORECLQ0L°RE AND HELP YOU MAKE FUTURE MORTGAGE PAYNfENTfi. IF YOU COMPLY WITH' TIIE PROVISIONS OF THE HOMEOVI'WER'S ER'IERGENCY MOR'J)GAGE ,A.'sSI, ANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCE' 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 ESTASLISH:ED 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). Dtn-ing that time you must ar: ange and attend a "face-to-face'ineeting with one of the consumer credit. counseling agencies listed at the end of this Notice. TIFI)i?S MEETING MUST OCCUR WITHIN (33) DAY OF THE DATE OF THIS NOTICE IF Ynt) DO APPLY NQJ F ASSISTANCE. Y MUST BRINCYOUR M i• P TO QLU, THE PART F F NOTICE W T. R JR M. T r. ' I Xf L.A3NS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseliTLg agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the daate of this meeting. The names, e es a t enumbers Si t consurnei- -credit gotinseling 1 i for the county it which theDrpe is ncatedareset foTtjtat theendof this NO I.iisonl.ynecessarytoscheduleon.eface-to-facertectinn. Advise your lendedmmodiately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you. must fill. cut; sip 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) davs 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 RYTH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AN 3 FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGALA4ST YOUR PROPERTY; AS EXPLAXED ABOVE, IN THE SECTIOAi CALLED "TEVIPORL9 RY STA I' OF FORECLOSURF. ". YOU HAVE 77TE RIGHT TO FILE A FIEXAP APPLICATION EVE1' BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTU4LLYAPPROVED AT ANY TIME BEFORE A SIIERIFF'SSALE. TIE FORECLOSURE WILL BE .STOPPED: AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. Trey will be disbursed by the Agency under the eligibilityr criteria established by the Act. The Pennsylvania Housut; Finance Agency has sixty (60) days to rnake a decision after it receives your application.. Duaing that t4,me, no farecl.OSI re proceedings will be puisvoed against you if you have met the time requirements set forth above. You -xrill be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CL)RRENTLY PROTECTED BY TITE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS ?NOTICE IS FOR INFORMATION PURPOSES ONLY AND S- HOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yi)u have fled bankruptcy you can still apply for.Emergency \4origage .hssistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to bate). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property ::ocated at: 165 VALLEY DR CARLISLE PA 17013 IS SERIOUSLY IN, DEFAULT because: YOU HAVE NOT MADE M09T:4LY MORTGAGE PAYMENTS for the following month(s) January 01, 2004 to March 01, 2010 and the following amount(s) are now past due: Monthly Payments 833.35 Corporate Fees 0.00 Late Charges 388.20 Non-Sufficient Funds 20.00 Fax Fees 20.00 Property Inspection Fees 99.00 Less suspense Balance .00 Total Amount Past Due Si',038.95 HOW TO CURE THE DEFAULT - You may cure tae default within thirty (30), days of the date of this notice- BY PAYING THE TOTAL, AMOUNT PAST DUE TO THE LLIMER, WHICH IS 513,038.95, PLUS ANY MORTGAGE PAYMENTS AND LATE CYLARGES WHICH BECOME DUE DURIhrG THE THIRTY (30) DAY PERIOD. A pr t he ar?A Pit-nor hu- rash Pr'a r-k- r°rtjf`Phi rhP?k ^aan nr mangy nrder m-C]a na iblp an A_ sent nn: PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, any infor-oration obtained will he used for that purpose. Enclosure DR&72 IF YOU DO NOT CURE THE I)EFAi ILT _ If you do not cure the default within. TPURTY (30) DAYS o", 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 NOU 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 Trade within THIRTY (30) DAYS, the lender also intends to instruct. its attorneys to start Legal action. to foreclose upon yo?lr mortgaged rp opert. IF THE MORTGAGE IS FORECLOSED UPON - The rnortgagedproperry will be sold by the Sheriff to pay off the mortgage dent. 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 tees that were actually incurred, up to $50.00. Idowever, 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 -Mll be added to the amount you owe the lender, which may also include other reasonable costs. If von cure the default within the THIRTY (30) DAY period, you will not he rectraired to nay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid. principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default, wit.vn. the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour bef-= the Sheriff's Sale You may do so by pavi ? the total amount 12erfJotming any other reW_?.rernents undrrr the morn. Curing your default in the manner set forth in this 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 mortbaged property could be held would be approximately nine - ten months from the date of thiss Notice. A notice of the actual. date of the Sheriffs Sale will. be sent to you. before the sale. Of course; the amount neededto cure the default will increase the longer you wait. You may ind out at any time exactly what the required payment or action will be by contacting the lender, HOW TO CONTACT THE LENDER : Nance of Lender.: PNC Mortgage Address: 3232 Newmark Dr, 'amisburg, OH 45432 Phone Number: l.- 00-523-8654 Pax Number: 937-41.0-4009 Contact Person: Collections enter ail Address: Lass. t ationta nernortgage.cotu EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgagged 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 ONES sell or transfer your borne to a buyer or transferee who will assume the mortgage debt, provided that all fhe 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 MA.Y 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 IAA ,,T THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAti'E THE MORTGAGE RES'T'ORED TO 713E SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (.HOWEVER, YOU DO NOT HAVE THIS RIGHTTO CURE YOUR DEFAUL'T' MORE THAN THREE TIMES IN .ANY CALENDAR. YEAR. ) • TO ASSERT THE NONE)OSTENCE 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 SUCFI ACTION BY 'l HE LENDER. • TO SEEK'PR.OTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY T P.O. Box 1820 Dayton. Ohio 45401-182C March 19, 2i 1G 494 20.000[7913.001-001.000-000-000 FOP.L,JEta7IFER L 165 VALLEY DR CARLISLE PA 17013-8852 ?II?IIiIIIliN15bIIIIIIINI?I? 7107 8381 6540 2104 1987 PNC Mortgage 3232 Newmark Drive Miamisburg, Ohlo 4.5342 Teiephone: (937) 910-120Q Mailing Address: P.O. Box, 1620 Dayton; Ohio 45401 - 1820 DATE: March 19, 20) 0 ACT 91 NOTICE TAKE ACTION TO SASE YOUR HOME FROM FORECLOSURE This is an official notice that the mortene on nur home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached jjaXes The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE JPROGRA.M: (HF', VIAP) 4. ma? be able to hdq to sly . the work To see if HEMAP can help you must M- FET WITH, A CONSUMER CREDIT COUNSELING AGENCY WITHTN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice wfth you when you meet with the Counseling A,Zenc??. The i address purnber of Consumer t Counseling Agencies S vi your Coun-ty are listed. the end of thi?s Notice, n Question,-;. you may- call the Pe-n-nsylvani i Finance Avency toll free at 1-800-342-2397(Persons with impaired hearing, can call (71.7) 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.. NOT IFICAC16N EN' ADJUNTO ES DE SU.MA IMPORTANCIA, PUSS AFECTA. SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENEDO DE ESTA NOTincACION OBTENGA UNA TRADUCC16N INl4'IEDIAT'431ENTE LLAM4.NDO ESTA AOENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUNIERO M.ENCIONADO A.RRIBA. PUEDE SER ELEGIBLE PARA VN PRESTAMO POR EL PROGRANIA LLAIVEADO "'HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAl[2 SU CASA. DE LA PERDIDA DEL DERECFIO A REDIMIR SU HIPOTECA. NakIEOWNER'S NAAIE(S): FORD,MII£E E r FORD?ENfiIIFER L PI.WPERTY ADDRESS-, 165 VALLEY DR LOAN ACCT. NO.: 0008479586 ORIGINAL LENDER: nia CURRPN7. , LEN-DERISERVICER: PNC Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECT OSCIE AND BEL YQU Kr FUTURE MQ TGAGE. PAYlvll 1T S, IF YOU COMPLY WITH. THE PROVISIONS OF TI4E ROMEOVVNER'S EIWERGE'W-V 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. AIORTGAGE PAY.MENTs, AND • IF YOU ;MEET OTHER ELIGIBILIT3' 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 H T .l T' OCCUR WITHIN 33 F THE T THIS NOT-l", I U D NOT APPLY FOR EMERGENCY M.QPTQA.QE ASSISTANCE. L C T - TO DATE. THE PART F TI.RS NOTICE C Y TO CURE U MORTGAGE DEF&ULT". IQW TO BRING YOUR MMTGAQrR UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meetwith one of the consumer credit counsel.i.naagencies 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 name& a s' t u e of designated consumer crodit counseling agggricies fn' t Z,. in whi gh the pro em is located are get forth at & end of this Notice. It is only n.ecessaryto schedule one face-to-fee meeting. Advise your Iende Mediatelyof your intentions. -APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set for Ch later in this Itiotace (see following pages for specific information about the nature of your default." You have the right o apply for financial assistance from the Homeowner's Eme gencyMortg*age Assistance Program. To do so, you must fill ouN , si.P and file a completed Homwwner'sEmergency Assistance. Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit courESaling 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 PTTFA and received within thirty (30) day e, 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 WIIWIN 33 DAYS OF THE POST31ARK DATE OF THIS -NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 34 DAYS' OF THAT )KEETING, THEN THE LENDER WILL BE TEMPORARILY PRE f ELATED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY ASS EXPL.A.,?k'ED AB'OI/E, IN THE SECTION"C',4LLED "TEMPORAR F' STA Y OF FORECLOSU'RE". YOU HAVE THE RIGHT TO FILE A NEMAP APPLICATION' EVEN BEYOND THESE- TIME PERIODS A L:47F APPLICATION' ?FILL NOT PRE'TIENT TUE LENDER FROM ST:A.RTING A FORECLOSURE ACTION, BUT IF YOUR APPLIC4T1Oh` IS EVENTVALLYAPPROFED AT ANY 77ME BEFOI?E A SHERIFF'S SALE, THE FORECLOSURE WILL ICE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. -11ey will be disbursed by the Agency under :be eligibility criteria established by the Act. The Pennsylvania blousing Finance Ageneyhas sixty (60) days to make a decisionafter it receives your application. During that time, no foreclosure praceetlings will be pursued against you if you have met the time requirements set forth above. You will be n.oti.fied directly by the Pennsylvania Housing Finance .A^*ency of its decision on your application. NOTE. IF YOU ARE CURR NTLY PROTECTED BY THE FILING OF A PETITION IN RA-NKRLTTC V, THE FOLLOWING FART OF THIS NOTICE IS FOR INFOR-NIATIOTS PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (Tf you have filed bankruptcy you can still apply for Emergency.N4ortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender an your property located at: 1-65 VALLEY DR CARLISLE. PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) „anuary Oi., 2009 to March 01, 2010 and the following amountts) are now past due: . Monthly Payments 833.35 Corporate Fees 0-00 Late Charges 388.20 Non-Suffic-s_ent Funds 20.00 Fax Fees 20.00 Property Inspection Fees 59.00 Less Suspense Balance .00 Total fimount Past Due $13,0-48-95 HOW TO CURE TADS DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO TER LENDER, WHICH IS $13,036.95, ipLUS XITY. MORTGAGE PAYMENTS AND LATE CILDO GES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. pairman-a mi•gt- ha madF airhar by rachiPr'4 chp-nk c-rrified rheck. rash or nay nrdar math ?aaynhl a and rant rn; PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OR 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 DEEM -- 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 outstared ng balance of this debt will be considered due irnmediatelyari.d 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 M} DAYS. the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortgaged rp . operty. IF THE MORTGAGE IS .FORECLOSED UPON - The mortgaged property will be sold by the Sherifftc pay or 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 stilt 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'sfees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the TMRTY (301 DAY period, van will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance ar3.d all other sums due under the mortgage. the THIRTY (30) DAY period and foreclosure - If you have not cured the default within ?rmi Q any outer reou rem ne ts under the mortgage. Curing your default in the manner set restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHF.RIFF''S SALE DATE - It is estimated that the earliest date that such a Sh.erif, s Sate of the motgaaged property could be held would be approximately nine - jCn months from the state 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 Mortuage _ Address: 3232 Newmark Dr, Miamisburg, OR 45432 Phone Number: 1-8W523-8654 Fax umber.: 937-910-4VOq Contact Person: Collections enter F,Nlail Address: ss. ti ation r)pnemor gage.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 fin-nishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may or may, not X (CHECK ONE) sett or transfer your borne to a buyer or transfer= who will aM_me the morrgage debt; provided that all the outstanding payments, charges and attorney's fees and costs are paidprior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO KkNrE THE RIGHT: • TO SELL THE PROPERT'Y TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MON11EY FROM -ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACmTG ON YOUR BEHALF, • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF.ALI:T HAD OCCURRED, IF YOU CURE THE DEFAULT. ;HOWEVER, YOU LSO NOT HAVE THIS RIGI1 T TO CURE YOUR. DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR..} • TO ASSERT THE NONE7sISTENCE. OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR AIv r' 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 CREI?IT COUNSELING AGENCIES SERVLNG YOUR COUNTY VERIFICATION I yl\ to a?? ?' ??cA? f , as an g ec? Sb,ncr of the Plaintiff, PNC Bank, National Association, do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: l sw . C10H s Name: A i±olL ShAr Title: f AICIV ( 31?qI ntr Company: PNC BanTc, National Association. MIKE E FORD; JENNIFER L JENKINS; MJU # 10110059-2 Cumberland County, Pennsylvania UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ATTORNEY FOR PLAINTIFF pleadings(audren.com PNC Bank, National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff = Cumberland County V. Mike E. Ford Jennifer L. Jenkins NO. 2010-12007 Defendants CERTIFICATE OF SERVICE 4) CAP W -40 1?40fl c: ?Z N -c I, Amy Glass, Esquire, hereby certify that I have served true and correct copies of the Plaintiffs Amended Complaint in Mortgage Foreclosure upon the following person(s) named herein at their last known address or their attorney of record. xxxxxx_ Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: December Z 2011 TO: Mike E. Ford Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 Defendant 165 Valley Drive Carlisle, PA 17013 Defendant LAW, A , P.C. AMY bLA9S, ESQ. PA BAR # 308367 NJ BAR # 13862010 . j W OFFICES P C ATTORNEY FOR PLAINTIFF UDREN LA WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 =Cumberland County Plaintiff :MORTGAGE FORECLOSURE V. Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: c. m :3:- r- Zr N x? 7 25 Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Mike E. Ford and Jennifer L. Jenkins for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 8/10/11 to 2/29/12 Late charges per Complaint From 8/10/11 to 2/29/12 $91,831.77 2,749.92 226.45 TOTAL $ 94,808.14 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. AMY GLASS, ESQ. PA BAR # 308367 J ?--, NJ BAR # 13862010 LB Y: tt? or r Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : 3Il ILa Uom PA ATTq PRO Y C?` o1y81D e*- c77J&D. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingseudren.com ATTORNEY FOR PLAINTIFF PNC Bank, National Association =COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 Plaintiff °. Cumberland County V. Mike E. Ford rGt Jennifer L. Jenkins N0. ?b v I 165 Valley Drive Carlisle, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE ? ca 0=-s C YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 7 0'o/? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor PNC Bank, NA vs. Mike E. Ford (et al.) OFRCE Case Number 2010-7097 SHERIFF'S RETURN OF SERVICE 11/1512010 10:53 AM - Jody Smith, Chief Deputy, who being duly sworn according to law, states that on November 15, 2010 at 1053 hours, she served a true copy of the within Complaint to Mortgage Foreclosure, upon the within named defendant, to wit: Mike E. Ford, by making known unto himself personally, at The Cumberland County Sheriff's Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. /\f JOMI?, DEPUTY 11/16/2010 08:14 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 2014 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer L. Jenkins, by making known unto herself personally, at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. RONALD HOOVER, DEPUTY SHERIFF COST: $49.40 SO ANSWERS, November 17, 2010 RON R ANDERSON, SHERIFF inc 1 ^tiECod ,1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10110059-1 PNC Bank, National Association Plaintiff V. Mike E. Ford Jennifer L. Jenkins Defendant(s) TO: Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7097 Date of Notice: December 7, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. l / - A?dn In, minato, Esquire PA ID 75860 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10110059-1 PNC Bank, National Association Plaintiff V. Mike E. Ford Jennifer L. Jenkins De f endant (s) TO: Mike E. Ford 165 Valley Drive Carlisle, PA 17013 ATTORNEY FOR PLAINTIFF :`COURT OF COMMON PLEAS `CIVIL DIVISION .Cumberland County NO. 10-7097 Date of Notice: December 7, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA., DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEER LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Alan M. Minato, Esquire PA ID 75960 Woodcrest Corporate Center Ill Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County Mike E. Ford :MORTGAGE FORECLOSURE; Jennifer L. Jenkins Defendant(s) :NO. 10-7097 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 ° C= - -? M .n n - c t c-, ZG (ji THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s),Mike E. Ford and Jennifer L. Jenkins, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa. C. S . §4904 relating to unsworn fqersi`?ica,t_i.Qn to authorities. y\for Plaintiff AN* GLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-29-2012 07:47:55 ;. Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service ame Agency FORD MIKE Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fag/bis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 2/29/2012 Request for Military Status "age 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:NT2UD5INGH https://www.dmdc.osd.mil/appj/scra/p,opreport.do 2/29/2012 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-29-2012 07:49:50 <: Last First/Middle Begin Date Active Duty Status Active Duty End Date Service enc A Name y g Based on the information you have furnished, the DMDC does not possess JENKINS JENNIFER any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). M. %A f fflA4 14 . 4A4 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL htto://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 2/29/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:PTI2R3S I SF https://www.dmdc.osd.mil/appj/scra/popreport.do 2/29/2012 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7097 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, National Association, Plaintiff (s) From MIKE E. FORD and JENNIFER L. JENKINS (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: $94,808.14 L.L.: $.50 Interest from 3/1/12 to Date of Sale 6/6/12 Ongo ing per diem of $13.48 to actual date of sale including if sale is held at a later date ----- $1,321.04 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $188.90 Other Costs: Plaintiff Paid: Date: 3!112 .? id D. Bu 11, Prothonotary (Sea]) Z . , Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, JU 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 308367 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association =COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. ::Cumberland County . a3 ;Z; -?; -wrn ' r- e MORTGAGE FORECLOSURE Mike E. Ford ::NO. 10-7097 rte- ; Jennifer L. Jenkins C-; }'' 3 °` Defendant(s) =s ?. ' ' - 5c: ..-.. i . PRAECIPE FOR WRIT OF EXECUTION -! -' . TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $94,808.14 Interest From 3/1/12 1,321.04 to Date of Sale June 6, 2012 Ongoing Per Diem of 13.48 to actual date of sale including if sale is held at a later date (Costs to be added) O c18. so Po ?rry syq.vd 1, it w. . 76 ? 0 P wL c* a'811 P-9 c27/8C0 RE f)r 4 d UDREN LAW OFFICES,, P.C. BY At PA BAR # 308367 NJ BAR # 13862010 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff .CIVIL DIVISION "•7 V. .Cumberland County C rno) a -° rn -? € MORTGAGE FORECLOSURE Mike E. Ford € NO. 10-7097 Jennifer L. Jenkins Defendant (s) -- ?-% CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: -< I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X-C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership X E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. lF AttA3,rrkv-T"'f6r Plaintiff AMY-GLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins Defendant(s) C E R T I F I C A T E C-) C PV Q 4 ro 3 M ^' -+ y M : x I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 36 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. AMY GLASS, ESQ, PA BAR # 308367 NJ BAR 4 1386,2010 "'UDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff ::CIVIL DIVISION V. :Cumberland County C-a a c :MORTGAGE FORECLOSURE :;r.M x?- Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins Defendant(s) <c C7; - AFFIDAVIT PURSUANT TO RULE 3129.1 > r - C..') crs PNC Bank, National Association, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 165 Valley Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mike E. Ford Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 165 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name PNC Bank, National Association the last recorded holder of every mortgage Address 3232 Newmark Drive Miamisburg, OH 45342 i r rn q cr Countrywide Home Loans, INC. 4500 Park Granada, A Corporation Calabasas, CA 91302-1613 Integra Mortgage Company Its 116 Allegheny Center Mall Successors and/or assigns Pittsburgh, PA 15212-5356 Atima 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 165 Valley Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 29, 2012 UDREN LAW OFFICES, P.C. or Plaintiff AMY-ULASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 -? ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P•C- WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsGudren.com OF COMMON PLEAS PNC Bank, National Assofiation :COURT "CIVIL DIVISION Plaintif -Cumberland County V. MORTGAGE FORECLOSURE ..03 M Mike E. Ford NO. 10-7097 cnr ti ' Jennifer L. Jenkins Defendant(s) w C.: , ry NOTICE OF SHERIFF'S SALE OF REAL PROPERTY , TO: Mike E. Ford 165 Valley Drive Carlisle, PA 17013 Your house (real estate) at 165 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 6, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $94,808.14, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights.. The sooner you contact one, the more chance you will have of stopping the sale. (See notice or page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money- bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO PLAN OF LOTS KNOWN AS CLOVERLEAF ACRES NO. 2, SAID PLAN OF LOTS BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK NO. 8, PAGE 43, AS FOLLOWS: BEGINNING AT A POINT, SAID POINT BEING THE NORTHWEST CORNER OF INTERSECTION OF VALLEY DRIVE AND PARK WAY AVENUE; THENCE ALONG THE WESTERN SIDE OF PARK WAY AVENUE IN A NORTHERLY DIRECTION; 120 FEET, MORE OR LESS, TO A POINT; THENCE PROCEEDING IN A WESTERLY DIRECTION 77 FEET ALONG THE SOUTHERN SIDE OF HALL DRIVE TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN SIDE OF LOT #9,140 FEET, MORE OR LESS, TO A POINT ON VALLEY DRIVE; THENCE IN AN EASTERLY DIRECTION 65 FEET ALONG THE NORTHERN SIDE OF VALLEY DRIVE TO A POINT, THE PLACE OF BEGINNING. BEING LOT #10, SECTION "G", ON SAID PLAN OF LOTS. THE ABOVE DESCRIBED LOT IS SUBJECT TO THE BUILDING RESTRICTIONS AND COVENANTS ATTACHED TO AND APPLICABLE TO SAID PLAN. AS DESCRIBED IN MORTGAGE BOOK 1174 PAGE 726 BEING KNOWN AS: 165 Valley Drive Carlisle, PA 17013 PROPERTY ID NO.: 43-11-3069-037 TITLE TO SAID PREMISES IS VESTED IN MIKE E. FORD, SINGLE PERSON AND JENNIFER L. JENKINS, SINGLE PERSON BY DEED FROM JEFFERY BRYNN SMITH AND ANDREA SUE SMITH, HUSBAND AND WIFE DATED 10/29/1993 RECORDED 11/1/1993 IN DEED BOOK P 36 PAGE 922. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Mike E. Ford Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 Defendant(s) NO. 10-7097 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 CD Plaintiff, by its/his/her Attorney hereby verifies that: CID F5 R L.. 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B" 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May ?, 2012 UDREN LAW OFFICES, P.C. `L BY: Attorneys for Plaintiff ,k1W"*wASSALL, E5k ph it) 77788 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff `-CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 165 Valley Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mike E. Ford Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 165 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Bank, National 3232 Newmark Drive Association Miamisburg, OH 45342 Countrywide Home Loans, INC. 4500 Park Granada, A Corporation Calabasas, CA 91302-1613 Integra Mortgage Company Its 116 Allegheny Center Mall Successors and/or assigns Pittsburgh, PA 15212-5356 Atima Waypoint Bank 449 Eisenhower Boulevard Harrisburg, PA 17111 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 165 Valley Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED : 9-//0// UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff N*-H? ? , E54 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff V. Mike E. Ford Jennifer L. Jenkins Defendant(s) ATTORNEY FOR PLAINTIFF € COURT OF COMMON PLEAS CIVIL DIVISION € Cumberland County NO. 10-7097 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Mike E. Ford Jennifer L. Jenkins PROPERTY: 165 Valley Drive (Middlesex Township) Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 6. 2012, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. E=XHIBIT A C- (D _ v p a CD mm r -n O L Q.. (D Cn 0 O O Cn n c a- CD C1 I I y O U) n? 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SHERIFFS OFFICE OF CUMBERLAND COUNTY f Ronny R Anderson Sheriff a; at M COO, Jody S Smith Chief Deputy Richard W Stewart Solicitor ' tiRIFF PNC Bank, NA Case Number vs. 2010-7097 Mike E. Ford (et al.) SHERIFF'S RETURN OF SERVICE 03/19/2012 01:00 PM - Sergeant Jason Vioral, being duly swom according to law„;served the requested Real Estate Writ, Notice and Description, in the above titled action, by making 1%iown its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Mike Ford at 1 Courthouse Sq. Carlisle Pa. 17013 Cumberland County Sheriffs Office, Cumberland County. 03/2012012 04:27 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jennifer L. Jenkins at 165 Valley Drive, Middlesex Township, Carlisle, PA 17013, Cumberland County. 03/20/2012 04:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 165 Valley Drive, Middlesex Township, Carlisle, PA 17013, Cumberland County. SHERIFF COST: $90910 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF EXHIBIT' B PNC Bank, National Association, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAi4lx -' vs. MORTGAGE FORECLOSURE Mike E. Ford NO. 10-7097 Jennifer L. Jenkins, T Defendants PETITION TO VACATE MORTGAGE FORECLOSURE DEFAULT JUDGMENT AND NOW, comes Petitioner, Jennifer L. Ford, by and through her counsel of record, Bradley L. Griffie, Esquire and the law firm of Griffie & Associates, and Petitions the Court as follows: 1. Your Petitioner is Jennifer L. Jenkins, n/k/a Jennifer L. Ford, the above named Defendant, currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is PNC Bank, National Association, the above named Plaintiff, currently represented by Amy Glass, Esquire and the law firm of Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, New Jersey. 3. The instant action was initiated by a Complaint in Foreclosure, which was filed on November 9, 2010 by Respondent against Petitioner, as well as Petitioner's former husband, Mike E. Ford. 4. Due to divorce proceedings between the Defendants named in this action, the Mortgage in this matter became delinquent. 5. Petitioner promptly addressed this matter with her prior Mortgage Company, National City Mortgage, in the Summer and Fall of 2009; the contacts with National City Mortgage are referenced on Exhibit "A", which is attached hereto and incorporated herein by reference. 6. In late 2009 or early 2010, Petitioner became aware that Respondent herein purchased, or otherwise assumed, her Mortgage from National City Mortgage. 7. Upon notification that Respondent was her new Mortgage company, Petitioner contacted them relative to their loss mitigation procedures available to reduce her mortgage payment, or other opportunities available to resolve the delinquencies on her Mortgage. 8. Respondent referred her to Home Retention Services as an outside agency that was to assist her and Respondent relative to the inordinate amount of modification requests being made at that time. 9. From her initial efforts to resolve this matter to the date of filing the instant Petition, Petitioner had contact with Respondent's representatives by telephone, correspondence, voicemail, faxing of documents, mailing of documents, or emailing of documents, to Respondent or its representative, Home Retention Services, more than sixty-five (65) times, the vast majority of which contact was initiated by Petitioner; the contacts with Respondent's representatives being referenced on Exhibit "B", which is attached hereto and incorporate herein. 10. Petitioner has been advised repeatedly by multiple individuals representing Respondent that Petitioner should not be concerned with the instant foreclosure proceedings and that her compliance with all requests that Respondent has made, including providing multiple copies of financial documents over the past two years to multiple individuals representing Respondent at multiple locations, the foreclosure action would not proceed to sale. 11. Petitioner advised Respondent, upon Respondent's request, that Petitioner had saved THREE THOUSAND AND XX/100 ($3,000.00) DOLLARS and was prepared to pay that to Respondent at its request and as part of Respondent's proposal to mitigate or modify Petitioner's mortgage. 12. Default Judgment was taken in this matter by the law firm representing Respondent, at which time Petitioner contacted legal counsel. 13. Legal counsel for Petitioner contacted legal counsel for Respondent and was advised that Respondent would need some direct contact from the representatives of Respondent with whom Petitioner was working in her loss mitigation process in order to vacate the Default Judgment or no longer pursue the Sheriffs sale proceedings. 14. This information was passed by counsel to Petitioner, who provided it to the representative of Respondent with whom Petitioner had been working at that time. 15. Respondent's representative advised Petitioner and her legal counsel that although she was fully aware of the Herculean efforts made by Petitioner to resolve this matter and Respondent's poor, dilatory and convoluted handling of Petitioner's ease, the representative was advised by her supervisors that she was not permitted to assist Petitioner by advising Respondent's foreclosure counsel of the details of this case. 16. Respondent's representative with whom Petitioner had been working in the Spring of 2012 had repeatedly and consistently advised Petitioner that Respondent would finalize her loss mitigation process and that the sale of her home will not take place on June 6, 2012. 17. Petitioner continued to work with the representative of Respondent and had trusted in their commitment that this matter would be resolved and she would not need to resort to litigation to vacate the Default Judgment nor to stay the Sheriff s sale proceedings. 18. Petitioner and her children have continued to reside in the home. 19. Petitioner and continued to cooperate in every conceivable manner possible with the representatives of Respondent in the loss mitigation process so as to avoid the instant foreclosure proceedings and the pending Sheriff s sale in this matter. 20. Petitioner has provided months, and at times years, of financial documents, including, but not limited to, multiple years' tax returns, multiple years of monthly bank statements, child support Orders, copies of her Separation Agreement, copies of the Divorce Decree, photocopies of a Deed conveying the property from Petitioner's former spouse to Petitioner, and a wide array of documents that Respondent's representatives demanded be completed and submitted as part of the loss mitigation and loan modification process. 21. This documentation has been faxed and hand delivered to no less than four representatives of Respondent at four different locations of Respondent in four different cities over the past three years. 22. At 4:00 p.m. on Tuesday, May 30, 2012, Petitioner was advised that all of her efforts to modify the loan or otherwise renegotiate her mortgage have been denied. 23. Petitioner has now received statements from Respondent's representatives that she "should have been put on a repayment plan at the time of the hardship", even though Petitioner was never offered any repayment plan pending the resolution of the mitigation process. 24. Substantial equity exists in the real estate at issue. 25. Representatives constantly and consistently lead Petitioner to believe, at various stages, that her request for mitigation or modification would be received well in advance of any sale of her property through a Sheriff sale. 26. On May 31, 2012, Petitioner was advised for the first time that she is now dealing with Freddie Mac. 27. On May 31, 2012, Petitioner was advised by a representative of Respondent that a Request for Postponement of the Sheriff sale had been submitted to Respondent. 28. Based on the three year fiasco in which Petitioner has been involved with Respondent, Petitioner does not believe Respondent's representative's statements that they are going to postpone the Sheriff sale. 29. Various representatives of Respondent over the past three years have expressed regret and dissatisfaction, and have apologized for the conduct of Respondent in their dealings with Petitioner, recognizing that Petitioner had complied with every request made by Respondent with less than satisfactory results. 30. The conduct of Respondent and its representatives is dilatory, vexatious and obdurate and illustrates misrepresentations and fraudulent conduct which will provide the basis for separate litigation against Respondent that Petitioner is exploring and contemplating relative to her financial losses, expenses, fees, her lost wages from lost time from employment and her emotional distress, all of which were involved in her ongoing efforts to comply with every demand and request made by Respondent's representatives relative to their loss mitigation and loan modification process over the past three years. 31. To allow Respondent to conduct itself in the manner in which it has, creating justifiable reliance by the Petitioner through the negligent and fraudulent misrepresentations of Respondent's representatives, while pursuing foreclosure and Sheriffs sale of the property through its legal counsel is unfair, unjust and does not comply with the obligations that Respondent has under state and federal laws to deal fairly in this matter. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any it has, as to why the Judgment in this matter should not be opened and vacated to allow Petitioner to file an Answer or other appropriate pleadings in her defense and, further, why the Sheriff s sale presently pending for June 6, 2012 should not be stayed pending further resolution of this matter. Respectfully submitted, ,/rjriffie, Esquire for Petitioner Supreme Court ID No. 34349 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. 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. DATE: r L. Forte PNC Bank, National Association, Plaintiff vs. Mike E. Ford Jennifer L. Jenkins, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE FORECLOSURE : NO. 10-7097 CERTIFICATE OF SERVICE S? 1, Bradley L. Griffie, Esquire hereby certify that I did, the day of June, 2012, cause a'copy of the within Petition to Vacate Mortgage Foreclosure Default Judgment to be served upon the Respondent, PNC Bank, N.A, by serving its attorney of record by first class mail, postage prepaid, at the following address: Amy Glass, Esquire Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 DATE: C I 1 , Griffie, Esquire for Petitioner National City Mortgage 7/21/09 Fax to Charmaine - Resource Dept (937) 913-7402 8/20/09 Fax Attn: Brian (937) 913-7433 9/2/09 Fax Attn: Mr. Capers ID: T GO 10/8/09 Followed up with phone call 10/8/09 Spoke with Josh Moore (HOPE) - credit counselor as referred by Mortgage Co. 10/15/09 Fax additional info to National City Mortgage as per their request Exhibit "A" PNC - Home Retention Services (referred by PNC) 2010 3/12/10 Spoke with Melissa - Home Retention Services (HRS) (877) 422-1905 ext. 2064 3/17/10 Spoke with Susan (Melissa no longer in that dept). She had me contact Jerry from PNC to send additional info date? Spoke with Martha (supervisor) at HRS - status 2-3 weeks to process - will escalate to upper mgmt. to see why its taking so long 3/29/10 Contacts with Tammy from PFHA (717) 780-4336 3/26/10 Called HRS - Martha will call back per Crystal (877) 422-1905 3/29/10 Called HRS - spoke with Claudia - Martha off on Mondays - message left for Martha that this is urgent and requested return call 3/30/10 Called HRS - Regina cannot give info on account because of "Jenkins" - once again left message for Martha (supervisor who was aware of name chg) 3/30/10 (6 p.m.) Spoke with Sarah (HRS) name still a problem - Martha on another call, has 4 more calls to make and leaves at 7 p.m. 3/30/10 Message left on my phone that they were returning the call for Martha 3/31/10 Spoke with Jennifer (HRS) who spoke with Martha and she would expedite 4/7/10 Spoke with Carlos (HRS) - Martha not available 4/28/10 Called PNC - Jennifer (collections) balance $13,918 - PNC has held foreclosure because of review 515110 Went to local PNC - spoke with Loren Disque (mortgage advisor) - worked 2 hours that day with phone calls and faxing - Disque spoke with Tomeka - faxed financial info summary and paystubs - then spoke with Pam Poole (my "advocate") - a packet would be mailed to me and I was to take it to Loren to Fed Ex - loan would be modified and late fees forgiven Loren advised me (Advised by Pam Poole that HRS had been "sitting on loans" so they were no longer being used. Work with PNC directly.) 5/?/10 Loren Fed Exed the completed packet of info 5/27/10 PHFA declined - suggested I work with lender on modification ** Could not locate Loren at PNC - later found he had left PNC because "the left hand doesn't know what the right hand is doing" 6/7/10 Fax (937) 910-4009 to PNC - Pam Poole (800) 367-9305 ext. 50340 6/9/10 Pam did not receive Faxed additional info - 2 bank statements/loan # on every page Exhibit "B" 7/13/10 Fax to PNC child support order 5 pgs. 7/15/10 Re-faxed above 7/21/10 Fax to PNC bank statements again 20 pgs. 7/26/10 Rec'd letter "Modification incomplete" - called Pam Poole - got Sandy Forte - "everything requested was rec'd". Sandy 800-367-9505 ext. 58297 9/14/10 Fax to PNC - Jason - 4506T Form/utility statements/pay stubs 10/13/10 Letter rec'd from PNC - "modification complete and denied" 10115110 Letter rec'd from PNC - "need more info for modification review'' 10/20/10 Spoke with Doreen (Carlisle PNC) - cell: 385-1599 - Doreen explained that I must be in the process several times - Doreen to talk to Manager to see if he has any ideas 10/29/10 Fax to PNC - Homeowners Assistance Dept - (937) 910-4009 -11 pgs. Including hardship letter 11/1/10 Rec'd letter from PNC that my loan was referred to their attorneys - Urden Law Offices 11/4/10 Called PNC Homeowners Asst. Dept. 800-367-9305 - Chris (collections) `'workout package forwarded for review 10/29 - 2 - 12 weeks to wait for review - "Foreclosure Dept. has to wait until review complete". Colleen Castro handling claim - message sent to Colleen for urgent review 11/4/10 Called Doreen to see what she found out - she said she couldn't get through - she will try a special number and call me back 11/16/10 (8:20 p.m.) Sheriff delivered complaint - 9 p.m. I called Homeowners Assist. Dept. and operators were currently unavailable 11/17/10 Called PNC - Tonya - "no sale date @ this time - workout package still in review - no addl. info needed at this time". Cannot connect to Colleen - she will call me when a decision is made 11/17/10 (10 a.m.) Doreen called back - "Yikes" - she's going to call in house customer service and have someone call me 11/19/10 Called PNC Mabel - 800-367-9503 - status - request add'1. info - financials summary/child support order/faxed ... again 11/19/10 Went to Mt. Holly Springs PNC branch - spoke with Judy (branch mgr) 11/19/10 Judy made copies of recent fax - said she would speak with her boss - 4 p.m. Judy called me and said a new package would be arriving - take to her when complete and she would fax again - also to call 800-523-8654 - option 0 for collections and explain situation and mention her name 12/16/10 Fax to PNC by Judy to Loss Mitigation - 12 pgs - hardship letter/financial info/pay stubs/bank statements main. 12/17/10 Confirmed fax was recd 2011 3/3/11 Bernadette (collections) - "review started -12 wks showing - no info needed at this time" 3/25/11 Refaxed by Judy - 19 pgs. - Judy noted under comments "info as requested 2 times faxed" 6/10/11 Fax to PNC - Customer Advocacy Dept. 937-910-4009 - 10 pgs - child support summary 10/21/11 Yolanda Oliver - PNC - 800-367-9505 ext. 9040920086 "modification approved - 40 year mortgage - need quit claim deed and divorce decree granting me the house - payment per month 799.06 for 40 years". It would start Jan 2012 and with payment of $3,000 from savings. 10/21/11 Called legal counsel to get quick claim deed 10/21/11 Left message for Yolanda r/t call to Brad 10/24/11 Called Yolanda - left message to call me 10/26/11 Called Yolanda - left message to call me 10/31/11 Yolanda - talking to underwriter regarding quit claim deed. "Decide by Nov 4 to accept or sent to foreclosure" by notifying Lisa Krezo - underwriter - ext. 9040920191 11/1/11 (11:10 a.m.) Called PNC - left message for Lisa Krezo for info by mail to review for modification 11/1/11 (4 p.m.) Left a message again for Lisa 11/2/11 (2:30 p.m.) Left a message for Lisa 11/3/11 (10:20 a.m.) Left a message again for Lisa 11/10/11 Yolanda called to ask of my decision for modification and I told her the deadline was Nov 4 and why hasn't she or Lisa called me back or sent me any information on this modification - she could only say "sorry" 12/15/11 Fax to PNC - proof of social security number - also Felicia is my new case manager and would be sending me a new workout package 800-367- 9305 ext. 90409200781 2012 1/24/12 Rec'd letter from PNC that my request was withdrawn at my request (even though a new workout pkg was coming) - I called and reminded PNC that I did want to be in the Modification Review and had not withdrawn any requests 2/13/12 Rec'd letter that request for hardship is being reviewed by Loss Mitigation 2/28/12 Fax to PNC (by Judy) for add'1. info -15 pgs - pay stubsibank statements/4506T form/divorce decree/2010 tax return/hardship letter (again) date? Rec'd letter requesting Form 710 -1 called to have them send it and it took 2 weeks to arrive - in that time PNC was calling almost every day to ask if I had any questions and I reminded them that the form still had not arrived. 3/20/12 Sheriff here at 4:20 p.m. to deliver the Sheriff sale notification 3/24/12 Form 710 arrived finally 3/29/12 Fax to PNC (by Judy) Form 710/child support order/pay stubs/divorce decree (main) 3/30/12 Notified Brad 4/12/12 Meeting with Lisa at PNC 4/18/12 Alexandria - emailed Lisa 4/19/12 Fax 4/12/12 Called PNC to check status 4/23/12 Email with Lisa at PNC 4/30/12 2 emails with Lisa at PNC 5/7/12 Email with Lisa at PNC 5/17/12 Email with Lisa at PNC 5/30/12 Phone call with Alexandria 4:20 p.m. 5/30/12 Phone call with Lisa Gibson at 4:30 p.m. 4 PNC Bank, National Association, Plaintiff VS. Mike E. Ford Jennifer L. Jenkins, Defendants ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this 14 44` day of w"A- 2012 presentation and consideration of the DEC> EED that: (:") r-.? c. , IN THE COURT OF COMMON PLEAS.,, CUMBERLAND COUNTY, PENNSYL I4= MORTGAGE FORECLOSURE -. -u' cn NO. 10-7097 Q Fi N.1 within etition, it is hereby ORDERED upon and 1. A Rule is hereby issued upon the Respondent/Plaintiff, PNC Bank, National Association, to show cause, if any it has, as to why Petitioner/Defendant, Jennifer L. Jenkins, n/k/a Jennifer L. Ford, is not entitled to the relief requested; 2. Respondent/Plaintiff shall file an Answer to Petition within twenty (20) days of service upon the Respondent/Plaintiff, 3. The Petition shall be decided under Pa.R.C.P. No. 206..7; 4. --ger"sitims - °--? _UW -servrce--apron 5. Hearing shall be held on the day of , 2012, at ,'tom ?.m. in Courtroom # of the Cumb rlan County Courthouse, Carlisle, Pennsylvania; 'f'"`` - I€-lteirrs i an ill be 7. PENDING A RESOLUTION OF THIS PETITION, THE SHERIFF'S SALE PRESENTLY SCHEDULED FOR JUNE 6, 2012 IS STAYED AND FURTHER PROCEEDINGS ON THE MORTGAGE FORECLOSURE ACTION ARE STAYED. 8. Notice of entry of this Order shall be provided to all parties by Petitioner/Defendant. -1, D< the Co , T ;-- J. cc: Amy Glass, Esquire Attorney for Plaintiff Bradley L. Griffie, Esquire Attorney for Defendant toen --1v ?N i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r. ? Jody S Smith Chief Deputy Richard W Stewart Solicitor PNC Bank, NA vs. Mike E. Ford (et al.) Case Number 2010-7097 SHERIFF'S RETURN OF SERVICE 03/19/2012 01:00 PM - Sergeant Jason Vioral, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Mike Ford at 1 Courthouse Sq. Carlisle Pa. 17013 Cumberland County Sheriffs Office, Cumberland County. 03/20/2012 04:27 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jennifer L. Jenkins at 165 Valley Drive, Middlesex Township, Carlisle, PA 17013, Cumberland County. 03/20/2012 04:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 165 Valley Drive, Middlesex Township, Carlisle, PA 17013, Cumberland County. 06/05/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $750.64 SO ANSWERS, June 06, 2012 -0N-N 17 R ANDERSON, SHERIFF 71.E 3 !c Coy,^.?Vsu,tr:: ShenPf. felac;s'"5`t. l,n;. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 165 Valley Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Mike E. Ford Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 165 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name PNC Bank, National Association the last recorded holder of every mortgage Address 3232 Newmark Drive Miamisburg, OH 45342 Countrywide Home Loans, INC. 4500 Park Granada, A Corporation Calabasas, CA 91302-1613 Integra Mortgage Company its 116 Allegheny Center Mall Successors and/or assigns Pittsburgh, PA 15212-5356 Atima 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 165 Valley Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 29, 2012 UDREN LAW OFFICES, P.C. sor Plaintiff AMN-GLASS, ESQ. PA BAR # 308367 NJ BAR 4 13862010 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff `CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Mike E. Ford -NO. 10-7097 Jennifer L. Jenkins Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 Your house (real estate) at 165 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 6, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $94,808.14 obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Mike E. Ford :NO. 10-7097 Jennifer L. Jenkins Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mike E. Ford 165 Valley Drive Carlisle, PA 17013 Your house (real estate) at 165 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on June 6, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $94,808.14, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO PLAN OF LOTS KNOWN AS CLOVERLEAF ACRES NO. 2, SAID PLAN OF LOTS BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK NO. 8, PAGE 43, AS FOLLOWS: BEGINNING AT A POINT, SAID POINT BEING THE NORTHWEST CORNER OF INTERSECTION OF VALLEY DRIVE AND PARK WAY AVENUE; THENCE ALONG THE WESTERN SIDE OF PARK WAY AVENUE IN A NORTHERLY DIRECTION; 120 FEET, MORE OR LESS, TO A POINT; THENCE PROCEEDING IN A WESTERLY DIRECTION 77 FEET ALONG THE SOUTHERN SIDE OF HALL DRIVE TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN SIDE OF LOT #9,140 FEET, MORE OR LESS, TO A POINT ON VALLEY DRIVE; THENCE IN AN EASTERLY DIRECTION 65 FEET ALONG THE NORTHERN SIDE OF VALLEY DRIVE TO A POINT, THE PLACE OF BEGINNING. BEING LOT #10, SECTION "G", ON SAID PLAN OF LOTS. THE ABOVE DESCRIBED LOT IS SUBJECT TO THE BUILDING RESTRICTIONS AND COVENANTS ATTACHED TO AND APPLICABLE TO SAID PLAN. AS DESCRIBED IN MORTGAGE BOOK 1174 PAGE 726 BEING KNOWN AS: 165 Valley Drive Carlisle, PA 17013 PROPERTY ID NO.: 43-11-3069-037 TITLE TO SAID PREMISES IS VESTED IN MIKE E. FORD, SINGLE PERSON AND JENNIFER L. JENKINS, SINGLE PERSON BY DEED FROM JEFFERY BRYNN SMITH AND ANDREA SUE SMITH, HUSBAND AND WIFE DATED 10/29/1993 RECORDED 11/1/1993 IN DEED BOOK P 36 PAGE 922. WRIT-OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-7097 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, National Association, Plaintiff (s) From MIKE E. FORD and JENNIFER L. JENKINS (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: $94,808.14 L.L.: $.50 Interest from 3/1/12 to Date of Sale 6/6/12 Ongoing per diem of $13.48 to actual date of sale including if sale is held at a later date ----- $1,321.04 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $188.90 Other Costs: Plaintiff Paid: Date: 3/1/12 David D. Bell, Prothonot (Seal) Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, JU 08003-3620 TRUE COPY FROM RECORD In Tesdmony w meof, I here unto set my hand and as1 of said at isle, Pa. TlAs s-...L-day .201.a - Prothonotary Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 308367 On March 15, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, known and numbered 165 Valley Drive, Carlisle, PA 17013 more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 15, 2012 By: For Claudia Brewbaker, Real Estate Coordinator The Patriot-News Co. 020 Technology Pkwy Suite X00 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE t4ePatriot-News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/27/12 05/04/12 05/11/12 . . . . . . _ . . . . . . . tefo , . ? i Sworn to and b ibme this 2 d M?y, 2012 A.D. Notary P6blic COMMONWEALTH OF PENNSYLVANIA NotarlaI seal Sherrie L. Owens, Notary Public Lower Paxton Twp„ Dauphin County My Commisslon E)Ormes Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2010-7097 Civil Term PNC Bank, National Association VS Mike E. Ford. Jennifer L. Jenkins Atty: Amy Glass All That Certain Lot Of Ground Situate In The Township Of Middlesex, County Of Cumberland And State Of Pennsylvania, More Particularly Bounded And Described According To Plan Of Lots Known As Cloverleaf Acres No.2, Said Plan Of Lots Being Recorded In The Office Of The Recorder Of Deeds Of Cumberland County, Pennsylvania, In Plan Book No.8, Page 43, As Follows: Beginning At A Point, Said Point Being The Northwest Comer Of Intersection Of Valley Drive And Park Way Avenue; Thence Along The Western S' le Of Park Way Avenue In A Northerly I _rection; 120 Feet, More Or Less, To A F lint; Thence Proceeding In A Westerly Lirection 77 Feet Along The Southern Side Of Hall Drive To A Point; Thence In A Southerly Direction Along The Eastern Side Of Lot #9,140 Feet, More Or Less, To A Point On Valley Drive; Thence In An Easterly Direction 65 Feet Along The orthern Side Of Valley ive To A Point, The Place Of Beginning. Lot #10, Section "G", On Said Plan ,ts. The Above Described Lot Is jet To The Building Restrictions I Covenants Attached To And .,plicable To Said Plan. o Described In Mortgage Book 1174 Page 726 Being Known As: 165 Valley Drive Carlisle, Pa 17013 Property Id No.: 43-11-3069-037 Title To Said Premises Is Vested In Mike E. Ford, Single Person And Jennifer L. Jenkins, Single Person By Deed From Jeffery Bryon Smith And Andrea Sue Smith, Husband And Wife Dated 10/2911993 Recorded 11/1/1993 In Deed Book P 36 Page 922. 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 an? State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Lav 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 regularl? 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: 27, May 4, and May 11, 2012 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 subjec, 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. Lis Marie oyne, Ed for SWORN TO AND SUBSCRIBED before me this 11 da of May, 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-7097 Civil Term recorded 11 / 1 / 1993 in Deed Book P 36 Page 922. PNC Bank, National Association vs. Mike E. Ford Jennifer L. Jenkins Atty.: Amy Glass ALL THAT CERTAIN lot of ground situate in the Township of Middlesex, County of Cumberland and State of Pennsylvania, more particularly bounded and described according to plan of lots known as Cloverleaf Acres No.2, said plan of lots being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book No.8, Page 43, as follows: BEGINNING at a point, said point being the northwest corner of intersection of Valley Drive and Park Way Avenue; thence along the western side of Park Way Avenue in a northerly direction; 120 feet, more or less, to a point; thence proceeding in a westerly direction 77 feet along the southern side of Hall Drive to a point; thence in a southerly direction along the eastern side of Lot #9, 140 feet, more or less, to a point on Valley Drive; thence in an easterly direction 65 feet along the northern side of Valley Drive to a point, the place of BEGINNING. BEING LOT #10, Section "G", on said Plan of Lots. THE ABOVE DESCRIBED Lot is subject to the building restrictions and covenants attached to and ap- plicable to said Plan. As described in Mortgage Book 1174 Page 726 BEING KNOWN AS: 165 Valley Drive, Carlisle, PA 17013. PROPERTY ID NO.: 43-11-3069- 037 TITLE TO SAID PREMISES IS VESTED in Mike E. Ford, single per- son and Jennifer L. Jenkins, single person by Deed from Jeffery Brynn Smith and Andrea Sue Smith, hus- band and wife dated 10/29/1993 55 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: HARRY B. REESE, ESQUIRE- ID #310501 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 f. , 856-669-5400 pleadings ,udren.com c r -? "= PNC Bank National Association € COURT OF COMMON PLEAS -= - € CIVIL DIVISION Plaintiff/Respondent € Cumberland County V. Case No. 10-7097 O - Mike E. Ford Jennifer L. Jenkins Defendants/Petitioners PLAINTIFF'S RESPONSE TO DEFENDANTS PETITION TO VACATE MORTGAGE FORECLOSURE DEFAULT JUDGMENT PNC Bank, National Association (the "Plaintiff") by and through its undersigned counsel, responds to Defendant Jennifer L. Jenkins' Petition to Vacate Mortgage Foreclosure Default Judgment (the "Defendant") as follows: 1. Admitted. 2. Admitted in part and denied in part. It is denied only that Amy Glass currently represents Plaintiff. Plaintiff is currently represented by the undersigned counsel at Udren Law Offices, P.C. Amy Glass, Esquire, is no longer employed at Udren Law Offices, P.C. 3. Admitted. 4. Admitted in part and denied in part. It is admitted only that the mortgage became delinquent and then went into default. The remaining averments are denied as Plaintiff is without sufficient information to form a belief as to the truth or falsity of said averments. 5. Admitted in part and denied in part. It is admitted only that Defendant so alleges. Insofar as Plaintiff does not have access to the communication logs of its predecessor in interest, National City Bank, Plaintiff is without sufficient information to form a belief as to the truth or falsity of said allegations. 6. Admitted. It is admitted that PNC Bank, N.A. "assumed" the Mortgage by its merger with National City Bank. 7. Admitted. It is admitted that Defendant contacted Plaintiff with regard to loss mitigation workout options. 8. Admitted in part and denied in part. By way of further response, Plaintiff had ongoing direct loss mitigation contact with Defendant from at least as long ago as August 25, 2009 through June 12, 2012. Insofar as Plaintiff is without sufficient information to form a belief as to the truth or falsity of remaining allegations, the same are deemed denied. 9. Admitted in part and denied in part. It is admitted that there were many loss mitigation communications between Plaintiff and Defendant by various methods, and initiated by both Plaintiff and Defendant during the time Defendant's loan has been in default. The remaining allegations are denied. 10. Denied. By way of further reply, on or about May 30, 2012 Plaintiff informed Defendant on that her loan modification application had been denied, that a Sheriff's Sale had been scheduled or was going to be scheduled, and that the only remaining loss mitigation options available were liquidation or non-retention options. 11. Admitted. By way of further reply, on or about May 30, 2012, a representative of Plaintiff advised Defendant that the $3,000 payment would not be sufficient to enter into a loss mitigation plan to retain the property. 12. Admitted in part and denied in part. It is denied only insofar as Plaintiff is without knowledge as to the time Defendant retained counsel. The remaining statements are admitted. 13. Admitted in part and denied in part. It is admitted to the extent that Defendant's counsel contacted Plaintiff s former counsel, and that Plaintiff s former counsel informed Defendant's counsel that Plaintiff s counsel does not have independent authority to postpone Sheriff s Sales for loss mitigation without the consent of the client. The remaining allegations arol { denied. 14. Admitted in part and denied in part. It is admitted only that Defendant so states. E The remaining averments are denied as Plaintiff does not have a record of being informed of the 5 within allegation. 15. Denied. By way of further response, Plaintiff's loss mitigation representatives work together with foreclosure counsel. Moreover, as of May 30, 2012 Defendant was informed by a representative of Plaintiff that her application for a loan modification had been denied. Therefore, Plaintiff s loss mitigation representatives would have had nothing actionable to relay to Plaintiffs counsel. 16. Denied. By way of further reply, Plaintiff incorporates its responses in paragraphs 10 and 11 hereinabove as if fully set forth at length. 17. Admitted in part and denied in part. It is admitted only that Defendant continued to communicate with Plaintiff s loss mitigation department. The remaining averments are denied. f 18. Admitted in part and denied in part. It is admitted only that Defendant resides in the Property. The remaining averments are denied as Plaintiff is without sufficient information to form a belief as to the truth or falsity of said averments. 19. Admitted. It is admitted that Defendant continued to attempt to achieve a loss mitigation workout. By way of further response, even the most diligent efforts to obtain a loss mitigation workout will not be successful if the financial documentation submitted does not meet the guidelines set by the investor. Moreover, Plaintiff incorporates its responses in paragraphs 10 and 11 hereinabove as if fully set forth at length. 20. Admitted. It is admitted that Defendant provided documentation in support of her effort to obtain a loss mitigation workout. 21. Admitted in part and denied in part. It is admitted only that Defendant provided documentation in support of her effort to obtain a loss mitigation workout. The remaining averments are denied as Plaintiff is without sufficient information to form a belief as to the truth or falsity of the number of times and places at which Defendant submitted documentation. 22. Admitted in part and denied in part. It is admitted only that Defendant was informed on May 30, 2012 that her modification request had been denied based upon investor guidelines. The remaining averments are denied. 23. Admitted in part and denied in part. It is admitted only that Plaintiff issued statements to the effect that Defendant "should have been placed on a repayment plan at the time of the hardship." The remaining averments are denied as Plaintiff is without sufficient information to form a belief as to the truth or falsity of said averments, because upon information and belief, the hardship initially occurred when the loan was serviced by Plaintiff's predecessor in interest, National City Bank. 24. Admitted in part and denied in part. It is admitted only that there appears to be equity in the property. It is denied to the extent that Plaintiff cannot verify at this time whether or not said equity is "substantial." 25. Admitted in part and denied in part. It is admitted only that Defendant's requests for a loan modification and efforts to pursue the same by both the Plaintiff and Defendant were ongoing from near the time of Default, and said request was received in advance of the scheduled Sheriff s Sale. By way of further reply, a "request for mitigation or modification," whether made near in time to the scheduled Sheriffs Sale date or not, is just a request, and is not a guarantee that said request would result in a modification. 26. Admitted in part and denied in part. It is admitted that after Defendant was informed on May 30, 2012 that all loss mitigation retention options had been denied, the file was sent for a second review by Freddie Mac. By way of further reply, on or about June 12, 2012 the second review by Freddie Mac resulted in a denial based upon the investor's financial guidelines. The remaining averments are denied as Plaintiff is without knowledge as to the Defendant's beliefs or mental state. 27. Denied. By way of further reply, Plaintiff s incorporated by reference its responses in paragraphs 10, 11 and 26 hereinabove as if fully set forth at length. 28. Denied. The within averments are denied as Plaintiff is without knowledge as to the Defendant's beliefs or mental state. 29. Admitted in part and denied in part. It is admitted only that Plaintiff s loss mitigation representatives make every effort to assist borrowers, and that such assistance may include empathize with borrowers experiencing financial difficulty. The allegation that "various representatives of Respondent over the past three years have expressed regret and dissatisfaction, and have apologized for the conduct of Respondent in their dealings with Petitioner" is denied as Defendant in her exhibits includes only one instance of a representative saying "sorry" on November 10, 2011. Moreover, "the less than satisfactory results" alleged by Defendant are not the result Defendant's "compli[ance] with every request made by Respondent," but were due to the fact that she did not qualify for a loan modification based upon the investor's financial guidelines. 30. Denied. By way of further reply, Plaintiff acted appropriately in its dealings with i the Defendant, and complied with all relevant laws, rules and regulations, as well as with the terms of the subject Mortgage and Note. Moreover, Plaintiff does contend that Defendant was was noncompliant with documentation requests. Defendant submitted a full loss mitigation package and was denied because her financial documentation did not support a modification under the guidelines set by Freddie Mac. 31. Denied. By way of further reply, Plaintiff acted appropriately in its dealings with the Defendant, and complied with all relevant laws, rules and regulations, as well as with the terms of the subject Mortgage and Note. Moreover, in a mortgage foreclosure proceeding, the creditor may seek to settle the matter via loss mitigation workout options with the debtor while simultaneously proceeding forward with the mortgage foreclosure. WHEREFORE, the Plaintiff prays and respectfully requests this Honorable Court enter an Order denying Defendant's Petition to Vacate Mortgage Foreclosure Default Judgment and grant such additional relief as the Court deems just and proper. Respectfully submitted, UDREN LAW OFFICES, P.C. H . ESQUIRE Attorney for Plaintiff PNC Bank, National Association, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLY,,NIA c vs. MORTGAGE FORECLOSURE _ Mike E. Ford NO. 10-7097 ff Jennifer L. Jenkins, - ? Defendants PRAECIPE - ^-: Please mark the Petition to Vacate Mortgage Foreclosure Judgment filed in the above captioned matter as withdrawn and discontinued. Respectfully Submitted, Q,jr 7'1&IIA -;,Wey T!Griffie, Esquire GRIFFIE & ASSOCIATES Attorney ID# 34349 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 PNC Bank, National Association, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : MORTGAGE FORECLOSURE Mike E. Ford NO. 10-7097 Jennifer L. Jenkins, Defendants JUDGE EDWARD E. GUIDO ORDER OF COURT AND NOW this J 3 ay of _?w.1Y', 2012, upon notification of the filing of a Praecipe withdrawing the Defendant, Jennifer L. Jenkins, nWa/ Jennifer L. Ford's Petition to Vacate Mortgage Foreclosure Judgment, our Order of June 4, 2012 is hereby vacated and the hearing scheduled for Thursday, July 19, 2012 at 1:00 p.m. is cancelled. By the CouA- - EDWARD E. GUIDO, JUDGE Cc: ? Harry B. Reese, Esquire Attorney for Plaintiff Bradley L . Griffie, Esquire Attorney for Defendant -v 3 `rs (h rnW-7 cn c.- : p, Z; IG Cj 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Sheriff T114,c pROTHiONUr` �Y Jody SSmith ~ ~ Yg|���� �� �� K : 19 Chief Deputy ^°'~ '"`' ` —' — �chardVVStewart �����~ CH D COU�TY Solicitor OFFICE -HE pENNSYLVAM\A PNC Bank, National' Case Number vo. | 2O1O'70S7 Mike E. Ford (et al.) | SHERIFF'S RETURN OF SERVICE O1/O4/2O13 03:38 PM -Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 165 Valley Drive, Carlisle, PA 17013, Cumberland County. 01/14/2013 07:52 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Oeacripdon, in the above titled oction, by making known its contents and at the same time personally handing a true copy tno person representing themselves toba the Defendant, towit: Mike E. Ford at 759 Hamilton Court, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 01/25/2013 07:46 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy too person representing themselves tobe the Defendant, tuwit: Jennifer L. Jenkins at 165 Valley Drive, Middlesex Township, Carlisle, PA 17013, Cumberland County. 03/05/2013 As directed by Alan yNinato. Attorney for the P|aindff, Sheriffs Sale Continued ho4/3/2O13 03/28/2013 Ronny RAndemon. 8heriff, being duly sworn according to |ew, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $3.097.08 SO ANSWERS, May 03. 2O13 uOmmY mamuEwSum. SHERIFF leg r UDREN LAW OFI'ICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 W60DCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com PNC Bank, National Association ` COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION V. : Cumberland County MORTGAGE FORECLOSURE Mike E. Ford € NO. 10-7097 Jennifer L. Jenkins Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129 . 1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C. , sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 165 Valley Drive, Carlisle, PA 17013 1 . Name and address of Owner (s) or reputed Owner (s) : Name Address Mike E. Ford 165 Valley Drive Carlisle, PA 17013 Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 2 . Name and address of Defendant (s) in the judgment: Name Address SAME AS 41 ABOVE 3 . Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4 . Name and address of the last recorded holder of every mortgage of record: Name Address PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 f Countrywide Nome Loans, Inc. 4500 Park Granada A Corporation Calabasas, CA 91302-1613 Integra Mortgage Corporation 116 Allegheny Center Mall Its Successors and/or assigns Pittsburgh, PA 15212-5356 Atima 5 . Name and address of every other person who has any record lien on the property: Name Address None 6 . Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7 . Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: . Name Address Tenants/Occupants 165 Valley Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief . I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: September 28, 2012 UDREN LAW OFFICES, P.C. BY: ``� Attorneys for Plaintiff ELIZABETH L WASSALL, Est PA ID 77788 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com PNC Bank, National Association : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION V. : Cumberland County : MORTGAGE FORECLOSURE Mike E. Ford " NO. 10-7097 Jennifer L. Jenkins De f endant (s) NOTICE OF SHERIFF' S SALE OF REAL PROPERTY TO: Mike E. Ford 165 Valley Drive Carlisle, PA 17013 Your house (real estate) at 165 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff ' s Sale on March 6 , 2013 , at 10 : 00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $94 , 808 . 14 , obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff' s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney' s fees. To find out how much you must pay, you may call: (856) 669-5400. 2 . You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) ' h y' YOU MAY STILL 'BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS' EVEN IF THE SHERIFF' S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3 . The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 r UDREN LAW OF'F'ICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren.com PNC Bank, National Association : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION V. : Cumberland County MORTGAGE FORECLOSURE Mike E. Ford _` NO. 10-7097 Jennifer L. Jenkins Defendant (s) NOTICE OF SHERIFF' S SALE OF REAL PROPERTY TO: Jennifer L. Jenkins 165 Valley Drive Carlisle, PA 17013 Your house (real estate) at 165 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff ' s Sale on March 6, 2013, at 10 : 00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $94 , 808 . 14 , obtained by Plaintiff above (the mortgagee) against you. If the -sale is postponed, the property will be relisted for the Next Available Sale . NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) -669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney. ) YOU MAY STILL' BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF' S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association . 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO PLAN OF LOTS KNOWN AS CLOVERLEAF ACRES NO. 2 , SAID PLAN OF LOTS BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK NO. 8 , PAGE 43, AS FOLLOWS : BEGINNING AT A POINT, SAID POINT BEING THE NORTHWEST CORNER OF INTERSECTION OF VALLEY DRIVE AND PARK WAY AVENUE; THENCE ALONG THE WESTERN SIDE OF PARK WAY AVENUE IN A NORTHERLY DIRECTION; 120 FEET, MORE OR LESS, TO A POINT; THENCE PROCEEDING IN A WESTERLY DIRECTION 77 FEET ALONG THE SOUTHERN SIDE OF HALL DRIVE TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN SIDE OF LOT #9, 140 FEET, MORE OR LESS, TO A POINT ON VALLEY DRIVE; THENCE IN AN EASTERLY DIRECTION 65 FEET ALONG THE NORTHERN SIDE OF VALLEY DRIVE TO A POINT, THE PLACE OF BEGINNING. BEING LOT #10, SECTION "G", ON SAID PLAN OF LOTS . THE ABOVE DESCRIBED LOT IS SUBJECT TO THE BUILDING RESTRICTIONS AND COVENANTS ATTACHED TO AND APPLICABLE TO SAID PLAN. AS DESCRIBED IN MORTGAGE BOOK 1174 PAGE 726 BEING KNOWN AS : 165 Valley Drive Carlisle, PA 17013 PROPERTY ID NO. : 21-18-1363-015 TITLE TO SAID PREMISES IS VESTED IN MIKE E. FORD, SINGLE PERSON, AND JENNIFER L. JENKINS, SINGLE PERSON BY DEED FROM JEFFREY BRYNN SMITH AND ANDREA SUE SMITH, HUSBAND AND WIFE DATED 10/29/1993 RECORDED 11/1/1993 IN DEED BOOK P 36 PAGE 922 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-7097 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION,Plaintiff(s) From MIKE E. FORD and JENNIFER L.JENKINS (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 GARNISHEES)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: $94,808.14 L.L.: Interest from 3/1/12 to 3/6/13 Ongoing per diem of$13.48 to actual date of sale including if sale is held at a later date -- $5,001.08 Atty's Comm: % Due Prothy:$2.25 Atty Paid: $965.54 Other Costs: Plaintiff Paid: Date: 10/2/12 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: ELIZABETH L.WASSALL,ESQUIRE Address:UDREN LAW OFFICES,PC ' RUE COPY FROM RECORD WOODCREST CORPORATE CENTER In Testimony whereof,i here unto set my hand and the"#I of said Court at Carlisle,Pa. 111 WOODCREST ROAD,SUITE 200P_ 20� - CHERRY HILL,NJ 08003-3620 a Prothonotary Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 77788 On October 23, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 165 Valley Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 23, 2012 By: Real Estate Coordinator �� `v' E- i3o 1101 CUMBERLAND LAW JOURNAL Writ No. 2010-7097 Civil recorded 11/1/1993 in Deed Book P 36 Page 922. PNC Bank,National Association VS. Mike E.Ford, Jennifer L.Jenkins Atty.:Alan Minato ALL THAT CERTAIN lot of ground situate in the Township of Middlesex, County of Cumberland and State of Pennsylvania, more particularly bounded and described according to plan of lots known as Cloverleaf Acres No.2, said plan of lots being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book No.8, Page 43,as follows: BEGINNING at a point, said point being the northwest corner of intersection of Valley Drive and Park Way Avenue; thence along the western side of Park Way Avenue in a northerly direction; 120 feet,more or less,to a point;thence proceeding in a westerly direction 77 feet along the southern side of Hall Drive to a point;thence in a southerly direction along the eastern side of Lot#9, 140 feet,more or less,to a point on Valley Drive;thence in an easterly direction 65 feet along the northern side of Valley Drive to a point, the place of BEGINNING. BEING Lot #10, Section "G", on said plan of lots. THE above described lot is subject to the building restrictions and cov- enants attached to and applicable to said plan.As described in Mortgage Book 1174 Page 726. BEING KNOWN AS: 165 Valley Drive, Carlisle,PA 17013. PROPERTY ID NO.: 21-18-1363- 015. TITLE TO SAID PREMISES is vested in Mike E. Ford, single per- son,and Jennifer L.Jenkins, single person by Deed from Jeffrey Brynn Smith and Andrea Sue Smith,hus- band and wife dated 10/29/1993 47 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: January 25,February 1, and February 8,2013 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. r (,,,Pa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 8 da y of Februa ,2013 A 'o') J. ( WZZ�� Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 ,_= he Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 i CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSc CAR'I _E PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2010-M7Chdl oh This ad ran on the date(s)shown below: CBank,It'atlonal VS 01/22/13 Mike E.F Jennller L.d Ins 01/29/13 Atty:Alan MI 02/05/13 ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, . COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ACCORDING TO PLAN Sworn to and ubscribed before me this 14 day of February, 2013 A.D. . a y, ota ublic OP OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK N0.8,PAGE 43,AS FOLLOWS: BEGINNING AT A JOINT SAID POINT COMMONWEALTH OF PENNSYLVANIA BEING THE NORTHWEST CORNER Notarlal Seal OF INTERSECTION OF VALLEY Holly Lynn Warfel,Notary Public j DRIVE AND PARK WAY AVENUE; Washington Twp.,Dauphin County THENCE ALONG THE WESTERN My Commission Expires Dec.12,201b SIDE OF PARK WAY AVENUE IN A NbRTHERLY DIRECTION; MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES .120 FEET, MORE 1R T.E,s", TO A POINT, THENCE ING IN A WESTERLY DIRECTION 77 FEET ALONG TqE SOUTHER ,SIDE OF ,'T HALL DRIVE TO POW HENCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN SIDE OF LOT #9,140 FEET,MORE OR LESS,TO A POINT ON VALLEY DRIVE;THENCE IN AN EASTERLY.DIRECTION 65 FEET ALONG THE NORTHERN SIDE OF VALLEY DRIVE TO A POINT THE PLACE'OF BEGINNING.BEING LOT #10, SECTION "G", ON SAID PLAN OF LOTS. THE ABOVE DESCRIBED LOT IS SUBJECT TO THE BUILDING RESTRICTIONS ANDS COVENANTS. ATTACHED TO AND APPLICABLE TO SAID PLAN. ASS DESCRIBED IN MORTGAGE BOOK 1174 PAGE 726 BEING KNOWN AS: PROPERTY ID NO.: 165 Valley Drive CariWe,PA 17013 21-18-1363-015 TITLE TO SAID PREMISES IS VESTED IN MIO E.FORD,SINGLE PERSON, AND JENNIFER L.JENKINS,SINGLE pFRSON BY DEED FROM JEFFREY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County MIKE E FORD; JENNIFER L JENKINS; MORTGAGE FORECLOSURE et al Defendant(s) NO. 10-7097 ZO N O;r Z PRAECIPE TO MARK SETTLED, DISCONTINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED, upon payment of your costs only. DATED: LAW O e S BY Attorney for Plaintiff MJU#: 10110059 CASE#: 10110059-1 David Neeren, Esquire PA ID 204252