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HomeMy WebLinkAbout10-7269UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE-200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udrea.com PNC Bank, National Association €COURT OF COMMON PLEAS ~,.~ ~ ~ 3232 Newmark Drive :CIVIL DIVISION c:: s M"~ Miamisburg, OH 45342 ,'~z ~ ~ ~ Plaintiff Cumberland County M~~"Fl ~ ' ~'~=- v . ...~ ~ ~ `_`~ ~ Jared A . Pyke ~ ~ a° ~ ~__ a,~ C'~ Trisha A. Pyke NO. ~b -~ ~~ ~~-_'-~ ~~~ 1349 W. Trindle Road - .~y Carlisle, PA 17013 ~ ~ ~~ Defendant (s ) ~ -`` COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOIILD TARE 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 YOII 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 717-249-3166 800-990-9108 U ~-~pa'~ ~a~ AVISO Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la demands en contra suya sin previo aviso 0 notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. LLEVE ESTA DEMANDA A IIN ABOGADO I~EDIATAMENTS, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SIIFICIENTE DR PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CIIYA DIRECCION SE ENCIIENTRA ESCRITA ABAJO PARR AVERIGIIAR DONDE S$ PUEDL CONSEGIIIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 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. Plaintiff is successor by merger to original mortgagee National City Mortgage Co dba Accubanc Mortgage. 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. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 1349 W. Trindle Road MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township COUNTY: Cumberland DATE EXECUTED: 9/30/04 DATE RECORDED: 10/12/04 BOOK: 1884 PAGE: 582 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/10/10: Principal of debt due $120,082.46 Unpaid Interest at 6.5~ from 4/1/10 to 11/10/10 (the per diem interest accruing on this debt is $21.38 and that sum should be added each day after 11/10/10) 4,745.61 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $253.40 and that sum should be added on the first of each month after 11/10/10) 1,424.40 Late Charges (monthly late charge of $41.88 should be added in accordance with the terms of the note after 11/10/10) 251.28 MIP/PMI 78.05 Recoverable Balance 550.00 Attorneys Fees (anticipated and actual to 5~ of principal) 6,004.12 TOTAL $133,740.92 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $133,740.92 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~iM~ ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A NAIL IN THE CENTER OF THE TRIlVDLE ROAD; THENCE BY LAND NOW OR FORMERLY OF ROBERT KOSER AND LAND NOW OR FORMERLY OF RICKY HAIR, SOUTH 27 DEGREES 4 MINU'rE5 EAST 462.57 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CLARENCE HAIR, SOUTH 82 DEGREES S2 MINUTES 10 SECONDS WEST 100 FEET TO AN IItON PIN; THENCE BY THE DIVIDING LINE BETWEEN LOTS N05. 1 AND 2 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, NORTH 27 DEGREES 4 MINUTES WEST 462.57 FEET TO A NAIL IN THE CENTER OF THE TRINDLE ROAD; THENCE 'BY THE CENTER OF SAID ROAD, NORTH 82 DEGREES 52 MINUTES 10 SECONDS EAST 100 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 2 ON THE SUBDiViSION PLAN OF LOTS OF IRVIN F. HURLEY AND MILDRED B. BURLEY, HIS WIFE, AS RECORDED IN PLAN BOOK 41, PAGE 131. AS DESCRIBED IN MORTGAGE BOOK 1884 PAGE 582 ~ ~~~ MUFI'li~:~` P.O. Box 1820 Dayton, Ohio 45401-1820 August 3, 2010 53231-0000025-001.001-000-000-000 PYKE,TRISHA A 1349 W TRINDLE RD CARLISLE PA 17015-9746 VIII Ilnlllll I~II~N~III PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937) 910-1200 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 ~~HIBIT A DATE: August 3, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached sages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help o cave yoLr home Thi Notice exn~lains how th program-m wn~ks, To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when you meet with the Counseling Agency. The_name_ addrecc nd phone nLmber of one Amer redit otnceling Agencies cep=wing your Coi ntv e en o ~~ o i voL ave,~r~v_ a ~ c ions , o ~ may call the Pe~~ncvlvania I,ToLCing Finance Asencv toll free at 1-800-342-2397. (Persons with impaired hearinc can call (7171780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency maybe 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 NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIbN OBTENGA UNA TRADUCCI~N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PYKE,JARED A PYICE,TRISHA A PROPERTY ADDRESS: 1349 W TRINDLE RD LOAN ACCT. NO.: 0003042343 ORIGINAL LENDER: n/a CURRENT LENDER/SERVICER: PNC Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORF.C',T.04 TRF AND T p y0 RSA F TRF IL~ORT A PAS ~~ET`iTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'hieeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETIN = Mi ~T O TR WiTAiN (331 DAYS OF THE DAT OFT NOTI F TF YO DO NOT APPLY FOR EMER[TENCY_MORTC~AGE A~STST T`TCF YO Itilr ST B Tl`rC`T YO TR bIORT TAT TP TO DATE. THE PART OF THT4 NOTT(;F. f:Ai.T.Ri) "HOW TO , TRF. YniTR Mnu'rrer_~ i~tr~errr T~~ L^VTT ....~ HOW TO B TN YO TR MORT A TIP O DA CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addressee and telenhonenLmbers of dP i;natP~ ~o c ,mer ere i ~o m eling,~gencies for ire ^7nnfiv ~n which the nronerty is locates a_rP set forth at h .end of h~. Notice. It is only necessaryto schedule one face-to-face meeting. Advise your lenderimmediatelvofynur 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 Emei'gencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARg DATE OF THIS NOTICE AND FILE AN APPLICATION R'ITH PHFA R7THIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED "TEMPORARYSTAY OF FORECLOSURE': YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION RILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENI'UALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'SSALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR 1~ORTGAGB DEFAULT (Briag it up to dat®). NATIIRS OF TH8 DSFAIJLT -- The MORTGAGE debt held by the above lender on your property located at: 1349 W TRINDLE RD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) May O1, 2010 to August O1, 2010 and the following amount(s) are now past due: Monthly Payments 4,364.20 Corporate Fees 0.00 Late Charges 125.64 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 18.00 Less Suspense Balance .00 Total Amount Past Duo $4,507.84 HON TO CIIRS THS DSFAIILT - You may cure the default within thirty (30) days of the date of this notice BY PAYING TH8 TOTAL Aa[OIINT PAST DII8 TO THS LSNDSR, OPHICH I3 54,507.84, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must he mariA n;rhe,- r,.. .. ~w.,._,_ _L__,_ ____. ..-. _ or money order made payable and sent to: PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR673 u ivu li . ryu, ~ _uKM: •rHM:. n~.s. srrr m __ If you do not cure the defauh within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose anon your mort a d ro IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybeforethe lender begins legal proceedings against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY ueriod. vnn will not hn ra....:rnri +., ..a., es.~,.__,._,~- : __ OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. ~-~u.. ~. Lr.rtiui.l rxi~x 1v srir:Klr'F'S SALE -- If you have not cured the default within (30) DAY period and foreclosure proceedineshave be~un_ vnu ct,tt t,aVP ri,o T:Ru+,.,, ,..,_e .,.,. a_r___,~ restore your mortgage to the same position as if you had never defaulted a manner set forth in this notice EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately nine -ten months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount neededto cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender. PNC Mortgage Address: 3232 Newmark Dr. ax um r: on erson: o ons en r - a ress: oss. ga on ncmo gage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgage property an your n t to occupy it. If you continue to live in the property after the Shenff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a uyer or trans eree w o assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ~~~ MUI~1~L'" P.O. Box 1820 Dayton, Ohio 45401-1820 August 3, 2010 53231-0000024-001-001-000-000-000 7107 8381 6540 2113 4016 PNC Mortya~p 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937)910-1200 Malang aadress: P.O. sox 1820 Dayton, Ohio 45401-1820 PYICE, JARED A 1349 W TRINDLE RD CARLISLE PA 17015-9746 DATE: August 3, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) your ome o c pYnlains how the r~1,,rQgrim w4~, To see if HEMAP can halo, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take t is Notice with ou when you meet with the Counseling Agency. The name_ ad recc anri phone nLmber of one Amer Credit Co Inc l;ng Agenci~ing voLr o ~ntv ~ o ~ vo ~ v a ~ ouec innc you may call the Panngvlv~,,;~ u Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearine can call (7171780-18691. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency maybe able to help ezplain 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 NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NO'TIFICACI~N OBTENGA UNA 'I'RADUCCIbN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PYKE,JARED A PYKE,TRISHA A PROPERTY ADDRESS: 1349 W TRINDLE RD LOAN ACCT. NO.: 0003042343 ORIGINAL LENDER: n/a CURRENT LENDER/SERVICER: PNC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORF.C'.T.O TRF p y0 T h~AKF TRF ABORT A PAI'MET`TT4 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'ineeting with one of the consumer credit counseling agencies listed at the end of this Notice. TffiS MEETING MUST O .['iTR Wi7'unv rz I DAye n~ rrv~ ,.. TT ,ter ,,,..~~ ~~~..,._..~ 1 1 ^~ L iry l r, li+ i ~ ~ ~ ~ ~ r YO T nn NOT APPLY FOR EMERGENCY MORTCTAGE ASSTSTATtiT .F._ YO b~ T B ii`T(~ YO Tit MnRTr:er.~ rm O DATE. THE PART OF THIS NnTtrF gar r Fn ++ HOW TO TRF Y(1T TR Mf1R Tr a r^~ n~~ e T n Tn ~vnr ,. ,,.T~ HOW TO B TIV T YO TR MORT TA TP TO DA CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleahonenLmbers of deciana~ co comer cre it ro m elin$~geneies for the o~nri+ m which the aroaerty is loc?t~ re cet fo hat th end o hs Notice, It is only necessaryto schedule one face-to-face meeting. Advise your lenderimm_ e_ diatelvof 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 Emet'gencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'sEmergency .Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETTNG R'ITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATTON WITH PHFA WITHIN 30 DAYS OF THAT MEETTNG, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOi'E, IN THE SECTTONCALLED "TEMPORARYSTAY OF FORECLOSURE' YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATTON EVEN BEYOND THESE TIME PERIODS A LATE APPLICATTON WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTTON, BUT IF YOUR APPLICATTON IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'SSALE, THE FORECLOSURE ii7LL BE STOPPER AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FII.ING OF A PETITION IN BANIfiiRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed banlQUptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATIIRB OF TH8 DBFAIILT -- The MORTGAGE debt held by the above lender on your property located at: 1349 W TRINDLE RD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) May O1, 2010 to August 01, 2010 and the following amount(s) are now past due: Monthly Payments 4,364.20 Corporate Fees 0.00 Late Charges 125.64 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 18.00 Less Suspense Balance .00 Total Amouat Past Due $4,507.84 HOgP TO CIIRB THS DBFAIILT - You may cure the default within thirty (30) days of the date of this notice 8Y PAYING TH8 TOTAL A~DONT PAST DIIS TO TIC L$NDSR, OiIiICH IS $4,507.84, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30} DAY PERIOD. Pavmenta m~iat hP maAo a;*hc,. },., ,.~..~,:,....,.. _'-__,- __-~_t or money order made payable and sent to: PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR672 i~ ~ruu !r~~ N! ri' (.;U F: ~rHr, nr.FA~it,T __ 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 morteage debt. This means that the entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mort a¢ d ro 1F THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriffto pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybeforethe lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings aze started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. ifyou cure the default within the THIRTY (30) DAY aeriod. you will not be required 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. ~ ar. L.r.r~ui,l rxiyx'1'u SHERIFF'S SALE - If you have not cured the default within Y penod and foreclosure proceedings have beeun. you still have the ,; ohr t~ M„p rl,a Hof „~+ LV11L1 .~~~.~ - ..v ,~~i rGuu~rCmenv~ mQer n mor~ags. Luring your default in the manner set will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately nine -ten months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: PNC Mortgage Address: 3232 Newmark Dr. r uvuc n uLlvci : 1~OV V-,LJ-a0~4 az um r: on erson: o ns en r ress: oss. ga n ncmo age.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgag property an your n t to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your fiunishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a uyer or trans eree w o vvi assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY V E R I F I CAT I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents. The statements made in the foregoing pleading are true and correct to the best of his/her information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~, P.C. BY: A o n v f 'wMrM1~Lp ~~1~~~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNSG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 3HERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQIIIRE - ID #204460 ADAM L. KAYES, ESQUIRE - ID #86408 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 pleadings~udren.com PNC Bank, National Association :COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 :Cumberland County Plaintiff v• No. ~o `~a~~l Jared A. Pyke Trisha A. Pyke 1349 W. Trindle Road Carlisle, PA 17013 Defendant (s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: C ,~, o "~~ 4a ~ ~~ _~ ~~ ~~ ~ ~~ ~~ ~~ ~c ;, ~ .~" ~ C? C; `~ f'T'i ~- Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Chandra M. Arkema, Esquire; Adam L. Kayes, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire and Jerome B. Blank, Esquire on behalf of the Plaintiff, PNC Baak, National Association in the above-captioned matter. P.C. BY: ~ ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY c2' Ronny RAnderson M ?Mr?? r,? rn-- Sheriff ` ' Jod S Smith Jody ? ? ? Chief Deputy `--j d t J 7' C"? C'-1 `n Richard W Stewart = c`? C.) C-) Solicitor r,FKICE',FT-ESF-ERIFF '' - v-j PNC Bank National Association vs. Jared A. Pyke (et al.) Case Number 2010-7269 SHERIFF'S RETURN OF SERVICE 11/22/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Trisha A. Pyke, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 11/23/2010 04:58 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2010 at 1658 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jared A. Pyke, by making known unto himself personally, at 1349 W. Trindle Road, 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. l ?- VALERIE WEARY, DEPUTY 11/24/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Trisha A. Pyke, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Trisha A. Pyke. Request for service at 1349 W. Trindle Road, Carlisle, PA 17013 the defendant was not found. Jared A. Pyke advised Deputies, Trisha A. Pykes is thought to be residing in Harrisburg, Pennsylvania. 11/26/2010 11:00 AM - Dauphin County Return: And now November 26, 2010 at 1100 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Trisha A. Pyke by making known unto Demei Vaughan, Step Daughter of defendant at 1211 N. 16th Street, Harrisburg, Pennsylvania 17103 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $70.40 November 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Iq GountySuite Sheriff, Teieosoft. Inc. of 14 v *I?-vr r.f William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin TRISHA A PYKE Sheriff s Return No. 2010-T-3547 OTHER COUNTY NO. 20107269 And now: NOVEMBER 26, 2010 at 11:00:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon TRISHA A PYKE by personally handing to DEMEI VAUGHAN 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 1211 N 16TH STREET HARRISBURG PA 17103 STEP-DAUGHTER Sworn and subscribed to before me this 26TH day of November, 2010 _)P*2 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 PNC BANK NATIONAL ASSOCIATION VS So Answers,! Sheriff o Dauph Cony; Pa By r" Deputy Sheriff Deputy: S WEVODAU Sheriffs Costs: $41.25 11/24/2010 A OFFICES P C ATTORNEY FOR PLAINTIFF UDREN LAW WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE :L00 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~,udren. com ~ _ _ _ _ _ __ _ PNC Bank, National Association ~ COURT OF COMMON PLEAS CNIL DIVISION Plaintiff ;Cumberland County ~_ v. , NO. 2010-7269 Civil Trisha A. Pyke Jared A. Pyke Defendants MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT IN MORTGAGE FORECLOSURE _; .~ Plaintiff, PNC Bank, National Association, by its Counsel, Udren Law Offices, P.C., by and through the undersigned Attorney, respectfully requests that this Honorable Court enter an Order granting Plaintiff leave to file its Amended Complaint in Mortgage Foreclosure. for the following reasons: 1. Plaintiff s original Complaint in Mortgage Foreclosure was tiled on No~~ember 19. 20l 0. ~'. Plaintiff desires to amend its Complaint in Mortgage Foreclosure in order to correct the amounts claimed due and the designation of the Plaintiff. ;. A true and correct copy of the verified Amended Complaint in Mortgage Foreclosure that Plaintiff seeks leave to file is attached hereto as Exhibit "A". MJU#1007079-E. Lit/pam WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant the Plaintiff leave to file its Amended Complaint in Mortgage Foreclosure. Respectfully submitted, -~ UDREN L'AW OFFICES, P.C ~ --~ -.~ -~~, ~~ ; ~ t,~ ~ f ~ ,~, ~ ~~ Attorney o % laintiff Paige M.,$er ino, Esquire PA #309091 MJU#1.0070?59-6 Lit/pam 1 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE .200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(u,,udren. com PNC Bank, National Association ;COURT OF COMMON PLEAS ;CIVIL DIVISION Plaintiff Cumberland County ~~. NO. 2010-7269 Civil Trisha A. Pyke Jared A. Pvke ' Defendants UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that I have served or caused to be sen ed true and correct copies of the Motion for Leave to File an Amended Complaint in Mortgage Foreclosure upon the following person(s) named herein at their Iast known address or their attorney of record. __xxxxxx___ Regular Ffirst Class Mail Date Served: OctobeG~ ), 2012 TO: Jared A. Pyke 1349 W Trindle Road Carlisle, PA 17013 Trisha A. Pyke 1349 W Trindle Road Carlisle, PA 17013 UDREN I,,~W OFFICES, P.C. . " ; ~~ .~ ~ r ~ ~ - Attorney for ntiff Paige M. lino, Esquire PA #309. 91. MJU#10070759-6 Lit/pam UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin~s(a,udren.com PNC Bank, National Association C/O PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff s TRISHA A PYKE 1349 W TRINDLE RD CARLISLE, PA 17013 JARED A PYKE 1349 W TRINDLE RD CARLISLE, PA 17013 Defendant(s) ATTORNEY FC)R PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 107269 AMENDED COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages. you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing ire writing with the Court your defenses or objections to the claims set forth against you. You are war~~ed that if yoi.~ 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 ~:~r other rights important to you. ti~ ~l tip- ~ ~ 7c 75`~ -(~ 1~+~~~b+ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU UO NOT HAVF. A LAWYER GO TO OR TELEPHONE THF, 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 AV1SO Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notifieacion. 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 amtinuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, Sl 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 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. if you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If yc-u do not dispute the debt, it is not an admission o1' 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. [f 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 I . Plaintiff is PNC Bank, National Association. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage. it is by the following Assignments of Martga~~c, all of which have either been recorded or Plaintiff is in the process of formalizing, the actual Assignment of Mortgage in Plaintiff s favor: Assignor: n/a Assignee: n/a Date of Assignu~ent: n/a Recorded Date: n/a Bool:/[nstrument #: n/a Page: nla ~. Upon information and belief Defendants} and/or their predecessor: Jared A. Pyke and Trisha A. Pyke (hereinafter "Defendants"), are the owners of property located at 1349 W TRINDLE RD, CARLISLE, PA 17013 , by virtue of Deed dated 09/30/2004 and recorded 10/12/2004 in Official Records Book 265 at Page 3481 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. Or- 09/30/2004, Defendant(s) and/or their predecessor: JARED A. PYKE & TRISHA A. PYKE promised to pay to the order of National City Mortgage Co dba Accubane Mortgage ,the principal sum of $ 132,525.00 payable with interest thereon provided in the Note. 4. ~y Mortgage dated 09/30/2004, Defendant(s) and/or their predecessor: JARED A. PYKE & TRISHA A. PYKE to secure the Note, mortgaged to National City Mortgage Co. dba Accubanc Mortgage , the Property which is the subject of this action. The Mortgage was recorded on 10/12/2004 in Official Records E3ook 1884 at Page 582.. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(rl. A legal description of the mortgage premises is attached hereto and made a part hereof. >. Said mortgage is in default in that the payment due OS/O1/2010, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the ether charges authorized by said Mortgage and itemized below, shall be immediately due.. E,. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a} 13y failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below.. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $120,082..46 Accumulated Interest $16,017.11 Accumulated Late Charges 5251.28 $7,606.92 Escrow Deficit/(Reserve) Pro Rata MIP/PMI $156..10 Property Inspections $199.50 Grand Total $144,133.37 The abo~~e figures <~re calculated as of 04/20/2012. The interest rate is subject t:o adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.50000 %. The per diem interest accruing on this debt is $21.38 and that sum should be added each day after the above date. I'he 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 $41.88. ?. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of }'ennsylvania and, if applicable, 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 $144,133.37 plus ongoing interest, costs and attorney's fees and for sale of the Mortgaged premises. UDREN LAW OFF[CES, P.C. /~ // BY: VERIFICATION ~ ~~~~ ,~h~ /~\ l } ~.. _ The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penaltie~~, of l R Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:_~j~l,l_ (~ a,D ~ i Jusfin Pierce Company: PNC Bank, National Association MJl I #: 10070759 CASE #: 10070759-2 PAIGE M. Bt~u~~~, ~-~~- PA ID 309091 Title: Authorized Signet ~++~ --.7C11eChlle C -Land Description Number IA-2004-347-c I! ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylva~lia, bounded and described ~e follows: BECINNiNC at a nail in the canter of the Trindle Road; thence by land now or formerly of Robert Koser and land now or formerly of Ricky Hair, South 27 degrees 4 minutes East 462.57 feet to an iron pin; thence by land now or formerly of Clarence Hair, South 82 degrees 52 minutes 10 seconds West 100 feet to an iron pin, thence by the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lota, North 27 degrees 4 minutes West 962.57 feet to a nail in the center of the Trindle Road; thence by the canter of said Road, North 82 degrees 52 minutes 10 seconds East 100 feet to the Place of-BEGINNING. BEING Lot No. 2 on the Subdivision Plan of Lote cf Irvin F'. Hurley and Mildred B. Hurley, his wife, as recorded in the Office of the Recorder of beads for Cumberland County in Plan Book 41, Page 131. P.O Box 182q Dayton, Ohio4S40 1-1 112 0 Augu-,~_ t ZO1~ 53231-OOir~025-001-6G1-000-060-000 ~YKF, :'R~SFiI, A CARD?~.T~F, 'A 17015-9746 ~IIIIII~IINIbIIINIINI~NNIIIIV PNC Mortgage 3232 Newmark Drive Miamisburg, CYhio 4542 Tetepho~e'. ;93~) 9"; t)-1200 Malting Address: P.O. Box 182D Dayton.. Ohio 45401-'.$20 ~ . DATE: .Augast 3, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR. HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pa6es 1'he HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP} may be able to help to cave your home This Notice explains how the program warks. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name- address and phone number of '`"onsumer redit Counseling Agencies serving fur ounty arm listed at the end of this Notice If v_~t~ have any~uPstions you may call the Pennsylvania No_nSln~ Frnance A~encv toll free at 1-800-342-2397. (Persons with impaired hearing can call (7l 7) 780-1869). This Notice contains important legal information. if you have any questions, representatives at the Consumer Credit Counseling Agency maybe able to help explain it. You may also ~i~ant to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO;\~ EN ADJUNTO ES DE SOMA IMPURTANCIA, PLIES AFECTA SU DERECHO :a CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CON1`EVIDO DE ESTA NOTIFiCAC10N OBTENGA UNA 'TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS ,A,L NIIMERO MENCIONADO ARRIBA. PUEDE SER ELEGYBLE PARR UN PRESTANIO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPO`I'E(:A. H03VIE;C~bb'iVFR`S >v'A>V1E(51: PYKE,JARED A PYKE.ThISHA A PROPERTY ADDRESS: 1;49 W "1'RINDLL RD LOAN ACCT. NO.: 0003042343 ORIGINAL LLNDi~R: n/a CC!RRENT L>/NDF.R./SERVICI'R: PNC I3aFik __ HOMEOWNER'S EMERGENCY 1VIOR1'GAGE ASSISTAl`TCE PROGRAM. Y'OU MAY >=3E ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE FOUR HOME FROM FORECLOSURE AND HEI P YOU MAI~1~, F TURF I4'IORTGAGE PA~'MFNT~. IF YOU CO~gPLY 'l~'ITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF' 1983 (TAE "ACT"), l'OI~ MAY BE ELIGIBLE FOR ENtERGE'_VCY ~10RTGAGE ASSTS'T'.ANCE: • IF YOt1R DEFAULT HAS BEEN CAUSED I3Y CIRCUATSTANCES BEYOND YOUR CONTRC-L, IF YOU IL1~ E A REASONAI3I.E PI20SPECT OF BEING ABLE TO PAY YOUR ~IOR"f'GAt:E P:~Y1II{,NT'S, AND • IF'' YOC MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYZ,V".NIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE --- Under the Act, you are entitled to a temporary ~tav of fi~reclosure on your martgage for thirty (30) days from the date of this Notice {plan three (3) days for mailing). During that time you must arrange and attend a "face-to-facc'ineeting with one of the eonsunzer credit counseling agencies listed at the end of this Nonce. THIS MEETING MUST OCCUR WITHIN (331 DAYS OF THE DATE OF THIS ~IOT7CE IF YOU DO NOT APPLY FOR EMERGENCY MORT A E ASSISTANCE YOU MUST BR_TN YO R MORTGA E IU' _TO I).ATE. THE PART OF THIS NOTICE ,CALLED "IIC)W TO CURE YOt1R MORTGAGE DFFAttI T", EXPT AIMS IIOW TO BRING YOUR MORTC'TAC'rE TO ATE. CONSL~VIER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counselingagencies listed at the cnd of this natice, the Iender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telenhonenumbers of desienated consumer credit counseling,,a~encics for the cotmty in ~~~hich the property zs located are set forth at the end ofthis Notice. It is only necessaryta schedule one face-to-face meeting. Advise your lenderimmediatelvofgour intentions. APPLICATIO>~i FOR MORTGAGE ASSISTAI~TCE -Your mortgage is in default for the reasons set forth Iatcr in this Nance (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you must fill out, sign. and file a completed Homeowner'sEmergency AssistL~nce Program. Application with one of the desi~n~ated 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 fozwarded to PHF<t and received within thirty i 30) days of your face-to-face meeting with. the counseling agency. YOU SHOULD FILE A HE~fAP APPLICATlOlti AS SOON AS POSSIBLE IF YOU HAVE ,~I MEETING WITH A COi1NSELI.'VG AGENCY u~THI.~' 33 DAYS OF THE POSTMARK DATF_ OF THIS ,'NOTIC'E AND FILE AIV ,AI'PLICATIOA' Tf7TH PHF9 ("I'ITHI,V 3D D.9f:S OF THAT MEETI.'NG, THEN THE LENDER WILL BE TEMPOILARILI' PREVF_NTED FROMST.9RTIJVG:9 FY)RECI_OSURF. AG.97NST YOUR PROPERTI; AS E,iPLAI.?NED ,4BUI'E, IN TH6 SECTIO.NCALLED "TEMPORAR Y STAY OF FOREC.'LOSURE ". I'OU HAVE THE RIGHT TO FILE A HEILIAP APPLICATION EVEn' BEYOND THESL• TIME PERIODS. A LATE APPLICATION WILD NOT PREVENT THE LENDER FROM ST,9KTING A FORECI,O.SURF_ ACTIOA; BLrT IF YO£JR APPLICAT70,~4' IS EGBNTUALLYAPPROVED AT .ANY TIME BEFORE A SHERIFF'S SALE, THE FORE('LOSURE WILL BE STOPPED. AGENCY ACTION' -- Available funds for emea-get~cymortgage assistance are very limited_ They la-ill he disbursed by the .A~,ency wader the eligibility criteria established by the Act The Pennsylvania f lousins, Finance Age~~c}~ has sixty (60) days to make a decsion after it receives yaui- application. During that. lime, iio foreclosure proceedings will he pursued against yon if you have met the time requirements set faith abc~~'~,. Yau will be notified directly by the Pennsylvania pausing Finance Agency of its decision on your apph~:atia~~_ NOTE: IF I'OU ARE-CURRENTLY PROTECTED BY THE EYEING OF A PETITION tN i3ANKRL;PTCl', THE FOLLUI~~ING PART OF THIS NOTICE IS F`OR INFORMATION PURPOSES O>TLY AND SHOE?LI) NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. ((f yo^ have fried bankruptcy you can still. apply for Emergency lVlortgagc Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date}. NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on year prepert:y _ccated at: 1349 W TRINDLE RD CARLISLE, PA 17013 IS SE3IOGSi,y' IPA DE,FAUL'3 because: YOL ~~.AVF, NO'S"wTFDE MONTHLY MJRTGAGE PAYMENTS for she following months) May O1, 2G"_[; tc Aug;ist O1, 2010 a.nd the following amcun~ `. <; ~ a~ :;: now past due Monthl} Pay*~ents 4,364.20 Corporate Fees O.OC Late Charges -_?.5.64 ?vo.l-Su'fici=nt Funds o0 Fax Fees .Op Property insper_tion Fees 18.00 Less Suscenae ]3alance _00 Total Amount Past Due $4,50?.84 HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING 'THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,507.84, PLUS ANY bSORTGAGE PAYMENTS AND LATE: CHARGES idHICH 3EC0"!E DL'E DURING THE THIRTY (301 DAY PERIOD. Favments must he made ether by cashi~>r's check certified chP~~k cash or money order made payable and sent to: PnTC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 Th.s is an at~em_ot to collect a debt, any information obtained will. be used for that purpose. E'-closure ~~~E:-;3 IF YOU DO NOT CURE THE llEFAULT -- If you do not cure the default within THIRTY (30}DAYS ofthe date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the ent7re outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the mortgage in monthly installments. If full payme:.nt of the total amount past due is nvt made within THIRTY {3f)) DAYS, the lender also intends tv insriuct its attorneys to start legal action to foreclose upon dour mortg_a~ed property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgagedprvperty will be svtd by he Sheriii'ty pay off the mortgage dept. If the lender refers your case to its attorneys, but you cure the delinquencyLicfore the lender begins legal proceedings against you, you wtll still be required to pay the reasonable attorney's fees that were actually incurred, up to $SO.t)0. I-Ivwever, if legal proceedings are started against you, you will have to pay all reasonable attvrney's fees actually incutYed by the lender even if they exceed $50.00. An.y attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue yvu personally for thv unpaid principal balance and all vther sums due under the mori~age. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S S~iLE -- If you have not cured the default within. the THIR'T'Y (~0) DAY period and foreclosure proceedings have begun, you still have the right tv cure the default and prevent the sale at anv time up to one hour before the Sheriff s Sale You may do so by paving the total amount then east due. plus anv late or other charte5 then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other cysts connected with the Sheriff s Sale as specified in writing by the lender and by performing, atn~r other rcau2rements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if yon bad never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the ear}iest date that such a Sheriff's Sale of the morgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of th.e Sheriff's Sale will be sent to you before the sale. Of course., the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action «,ill be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortaapse Address: 3232 Newmark Dr. Miamisburg, OH 45432 Phone Number: i-800-SZ3-8654 Fax Number: 937-910-4009 ontact erson: o ectEOns enter au naaress: Loss.Mitigation(tipncmortgage.com EFFECT OF SHERI:FF'S SALE -- You shauld realize that a Sheriff s Sale will end your vwnet>hip of the mortgaged property and your right to occupy it. Tf you continue to five in the property after the Shen ff'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 ((;HECK ONE) sell or transfer yoczr home to a buyer or transferee who v~~ill assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage core satisfied. YOU MAY ALSO HAVE TIC. RIGH"h: • TO SELL 'I'I-iE PROPERTY TO OBTAIN MONEY TO PAY OFF TI3E MORTGAGE 13EB~I~ i1K TO BORROW MONEY FROM ANOTHER L~E:~~VDING INSTITUTION TO PAY OFF THIS DEB'T'. • TO HAVP: '[7-IIS DEFAULT CURED BY A~'VY THIRD PARTY ACTING ON YOUR BEHALF. • TO DAVE TIIE MORTGAGE RESTORF;D TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT NAVE T1~~IIS I.T(Ii3T TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR I'EAR_) • TO ASSERT THE NONEXISTENCE OF A DEFAUL'C IN ANY FORECLOSURE PROCEEDING OR ANY O"TIIF.R LAWSUIT` INSTITUTED U~~ER THE MORTGAGI; DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH A('TION TAY THE LF,NDER. • TO SEER. PRO'T`ECTION UNDER THE FEDERAI. BANILRUI'TCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUN'T`Y ~~ ~~ x ~ . C" P.O Box 1820 Dayton, Ohio4540t-t820 7107 83$1 6540 2113 4016 Aug-:~~~~ ~, x.:10 say 3 t -oatooz;-oot-0a t -ox-ooo-ooo PNC Mortgage 3232 Newmark Drive Miamisburg, ~7hie 4 ;342 Telephone {937; 9^0-7200 Mailing Address: P.O. Box 1820 Dayion, Ohio 4 E>A01-t 820 PYK- , ~~~iR~~ F 134`_a '~~ T^'.iNDLE RD CAF,~ISLE ~?A 1?0~.5-9746 DATE_ !~ta~u~t 3, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official. notice that the mort#;a~e on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains hvw the arop~ram worl~s. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY ~~'1THIN 33 DAYS OF THE DATE OF THIS NOTICE. Tame this Notice with you when you meet with the Counseling A~encv. The name. address and phone number of Con~uaner Credit C'oun~eling Agencies 5ervin~your County are listed at the end of this Notice 1f you have any due tigns y9~av call the Pezrn~~(~~-ania Housing Finance Agency- toll free at 1-804-342-2397. (Persons with unpaired hearing can call (7 l7 j 780-1869). This Notice contains important legak 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 NOTIFICAC.ION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTL+'NGA UNA TRADUCCI()N INMEDI.ATAME~ITE LLAMA:~DO ESTA AGENCIA (PEN:~iSYLVANIA HOUSING FINA_'~'CE AGE'VCY} SLN CARGOS .AL :VUNiER0 MENCiONADO .4.RRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SA.LVAR SU CASA DE LA PERDIDA DE.L DERECIIU A REDIMIR SI1 HIPOTECA. HC>yEOWNBR'S 1v'A\9L(Sj; PYKB,JARED A ~-•~_-_-- PYKE;TRISHA A PROPERTY ADDRESS: 1.349 W TRINDLE RD LOAN ACCT. NO. 0003042343 ORIGINAL LENDER: nia CURRENT' LENDEIZISERVICER: PNC HOMEOWNER'S EMERGENCY MOR'T'GAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOLR HOME FROM FORECLOSURE AND HELP YOli MAKE FUTURE MORTGAGE PAYMENTS. IF YUU CU~SPLY V4'TTH TFIE PROVISIONS OF THE HOMEOWNER'S EMERGENCY i1iORTC:AGE ASSISTANCE ACT OF 1.983 ('CHE "ACT"), YOII NIAY BE ELIGIBLE RUR EMERGENCY MORTGAGE ASSISTA_VCF,: • IF YOItR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CUNTR(")L. • IE YOU HAVE A REASONABLE PROSPECT OF BE[.NG ABLE TO PAY YOUR MURT(~AGI~; P~hYiYIE:NTS, AND • IF YOU MEET UTHEI2 ELIGIBILITY REFIUIRE!VIE'VTS ES'TABLIS'HED BY"I'HE 1'ERNSV'LV~~\L4 HUIJSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -~- Under the Act, you are entitled to a temporary stay ~~'° foreclosure on your mortgage for thirty (3d) days from the date of this Notice (plus three (3) days for mailing). During ;hat time you must arrange and attend a "face-to-face'Tneeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIIIS MEETING MUST OCCUR WI'CI-IIN (331 DAYS OF THE DATE OF THIS NOTICE. IF YOU DC1 NOT APPLY FOR EMERGFurv MnlzTraC;>~ AC4ICTANCVF ynll MTIST RRTNG YOIIR R90RTCiAGE UP TO DATE THE PART OF THIS NOTTCE CALLED "NOW TO CURE YOUR MORTGAGE DEF~1t?LT" EXPLATNS HOW TO BR_TNG YOUR MORTGAGE tIP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meetwith one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30} days after the date of this meeting. The names addresses and telephonenumbers of designated consumer credit counseling agencies for the counri~ in which the ~gerty is located are set forth at the end of thus Notice. It is only neeessaryto schedule one face-to-face meeting. Advise your lenderimmediatelyofynur intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set firth later in this Notice (see following pages for specific information about. the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. Ta do so, you must fill out, sign and file a completed 1Tomeovv~ier'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 progi am and they ~~'ill 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 PHF:'~ and received within thirty ;30) d~~ys of your face-to-face meeting with the counseling agency. YDIJ SHOL`LU FII:E A HErFfAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE ,4 ~4-1F.E7']A'G LI'ITH A COUIITSEL7.+~-G AGE.?~'C'Y WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE .9A' ,APPLIC.4 TIOIV WITH PHF9 WITH7111 3D DAIS OF THAT MEETING, THEN THE LENDER WILL BE TEMPOR.ARIL3' PREI~ENTED FRO~tfiSTAIlT114'G:-1 FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED AB01JE, IN TIKE SF.CTIONCALLED "TEMPORARY ST,9Y OF FORECLOSURE ". YOLT HAVE' THE RLGHT TO FILE A HEMAP APPLICATION- EDEN BEYOND THESE TI:CIE PERIODS. A LATF_ APPLICATION WILL NOT PREYEII'T THE LENDER FROM STARTING A FORECLOSURE :4CT'ION; RUT IF YOUR APPLLCATIO:~~ IS F.'VEI~'TL~9LL I'APPROVED AT ANY TIME BEFORE ,4 SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Avai}able funds for em~~rgcncymortgage assistance are verv limited. 'I1~iev ~~•ill l~< disbursed by the Agency under the eligibility criteria established by the Act_ The Pennsylvania housing Finance Agencyhas sixty (60~) days to make a decisionafter it receives your application. During that time, nc~ foreclosure proceedings will. he pursued against you if you have met the time requirements set forth abc~we You will. be notified direr-tly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOII ARE CURRENTLY PROTECTED BY THE FILL'VG OF A PETITION IN BANR~2UPTCY. THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SIiOULII NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEB`T'. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.] HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THS DEFAULT -- The MORTGAGE debt held by the above 'ender on your property located at: 7.349 ;4 TRINDLE RD CARLISLE, PA 1'7013 IS SERIOUSLL,Y ;_."~ llFFAJLT because: 'tOJ 3~;JE NO`'' MADE MONTHLY MORTGAGE PAYMENTS for the follow~.ng monthfs; May 0', 2:,7~~ to August Ol, 2070 aad the following amounts) are now past due: Mont:rly Payments 4,364.20 Corporate Fees 0.00 Late Chances 225.64 Non-Sufficen'~ Funds .00 Faa Fees .00 Property Inspection Fees 18.00 ::cuss SLSOense Balance .00 Total Amount Past Due $4,50'7.84 HOW TO CURE THE DEFAULT - You may cure the default within thirty ;30; da.r~:= ow the date: of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH I:S $4 ,.:07.84 , PLUS ANY MC>RTGAGE PAYMENTS AND LATE C.T3ARGES WHICB BECOME DUE D27RIN3 T'rIE THIRTY (30) DAY" PER70D. Payments must he made either by cashier's check certified check cash or money order made payable and sent to: T PNC Mortgage Collections Center 3232 Newmark Dr Miamisburg, OH 45432 This is ar! attempt to collect a debt, any information obtained will be used for that. purpose. Enclosure _,x'672 tF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default witlnn TIIIRTY i;30} I~AY~S of the date of this Notice, the tender intends to exercise its rights to acceterate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the mortgabe in montlyly installments. If full payment of the total amount past due is not made within TII3RTY {;0) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upan vour mortgaged ro e IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay of'f the mai~tgage debt. If the [ender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees tl~tat were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have fo pay all reasvnable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey'sfees will hr added to the amountvou owe the lender, which may also include other reasonable casts. If you cure the defautt within the THIRTY (30) llA1' period, you wilt not be required to pay attorney's fees OTHER LENDER REMEllIES -- The lender roay also sue you personally for the unpaid principal halanc~ and all other sums due under the mortgage. ttIGHT TO CURE TFiE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default within the THIKT~' (30) DAY period and foreclosure proceedings have bean, you still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheriff's Sale. You may d.o so by,payinu the totiil amount foreclosure sale and any other costs connected ~~ith the Sheriff s Sale as specified in writint; by the lender and by pertormina anv otherre~uirements under the morg~~. Curing your defautt in the manner set forth in this notice will restore vour mortgage to the same position as if you had never defaulted Er~IiLIEST POSSIBLE SHERIFF'S SALE RATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of the Shcri$'s Sale will be sent to you befare the sale. Of cuursc, 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 ar action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Ur. Miamisburg, OH 45432 Phone Number: 1-80U-523-8654 Fax Number: 937-910-4009 ontact erson: o ecttons enter ail Address: Loss.Mitigation~a),pncmortgage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your m~n~ership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff ~ Sale, a lawsuit to remove you and youiu furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You ma}~ or may not X (CI-1BCK ONE) sell or transfer your home to a buyer or trans eree who will assume the mortgage debt, provided that all the outstanding payments, charges and attome}l's fees and costs are paid prior to or at the: sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO FIAVE THE RIGHT: • TO SELL "i'IIG PROPERTY TO OBTAIN MONEY TO PAY OFF TEIE MORTGAGE DEEI"1' OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DL?BT. • TO HAVE 'T'HIS DEFAULT CURED BY AIv~`Y THIRD PARTY ACTI?~IG ON YOI1R BEIlAI_.F • TO HAVE TH£ MORTGAGE RESTOIZI:D TO THE SAME POSITION AS IF NO DEFAULT. HAD OCCURRED. 1F YOU CLRE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE 'T'HIS RIGHT TO CTJRE YOUR DEFAULT MORE THAN THREE T1MES IN ANA' CALENDAR PEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANA" FORECLOSURE PROC TEDING OR ANY OTIIER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAC' FIAVE TO SUCH ACTIC)N E3Y THE LENDER. TU SEEK PROTECTION UNDER. THE FEDERAL BANKRUPTCY" LAW. CONSUA~IER CREDIT COUNSELING AGENCIES SERVING YOUR. CO[1N'I,Y 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(a,udren. com _ -- PNC Bank, National Association ;COURT OF COMMON PLEAS ' CIVIL DIVISION Plaintiff ~ Cumberland County v. ~ NO. 2010-7269 Civil Trisha A. Pyke Jared A. Pvke Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR LEAVE TO FILE AMENDED COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff seeks leave of Court to amend its Complaint in Mortgage Foreclosure. The facts set forth in the within Motion are incorporated herein by reference as though fully set forth at length. The Pennsylvania Rules Of Civil Procedure state as follows: Rule 1033.2, Amendment A party, ... by leave of court, may at any time change the form of action, correct the name of a party or amend his pleading. The amended pleading may aver transactions or occurrences which have happened before or after the filing of the original pleading, even though they give rise to a new cause of action or defense. An amendment maybe made to conform the pleading to the evidence offered or admitted. Pa.R.C.P. 1033. In the instant Motion for Leave to File Amended Complaint in Mortgage Foreclosure, Plaintiff requests leave to file the original of the attached Amended Complaint. Pursuant to the Rules of Civil Procedure as above stated and the facts as set #orth in the attached Motion, Plaintiff requests that it be permitted to file the Amended Complaint in Mortgage Foreclosure. Respectfully submitted, UDREN LAW OFFICES, P.C. ,\ ~' ~, -, r BY: t `1fr Attorney fob Plaintiff Paige M. Bellino, Esquire PA #3QJ0~~ I ~ ~ ~-{; ~_ MJU#10070759-6 Lit/pam UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 = - 856-669-5400 pleadins(a,udren.com 1-uF3 -?? PNC Bank, National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff I Cumberland County - '-? v 2010-7269 Civil NO Trisha A. Pyke . I r`ti? Jared A. Pyke I Defendants CERTIFICATION OF CONCURRENCE / NON-CONCURRENCE I, Paige M. Bellino, Esquire, Attorney for PNC Bank, National Association, hereby certify that on OCTOBER 5, 2012, I served or caused to be served a true and correct copy of the within Motion for Leave To Amend Complaint and the proposed Order by pre-paid first class regular mail along with a request to the other parties to provide their concurrence or non- concurrence. The Concurrence/Non-Concurrence response deadline was October 17, 2012, and, as of October ?- , 2012, the other parties have not responded to the inquiry concerning concurrence. UDRE LAW OFFICES, P. I t r BY- Paige Beljmo, Esquire PA # 0909) DATED: OCTOBER 11b , 2012 MJU#10070759-6 Lit/pam 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION -~_ PNC Bank. National Association ' Plaintiff ~ :~ ~y c:~ c , ~~ ^, -~ `- - - , ~. ~3 -~ ~ i-, ' Trisha A. Pyke ~ ~~~ ! ~,~= Jared. A. Dyke ; NO 2010-7269 Civil 'T r~ ~ `- . Defendants ="•" `-' _- c~:: c-~ ~ ; c„~ s-. - rv RULE TO SHOW CAUSE AND NOW, this ~ day of 1V~ , 2011 upon considera tion of the foregoing Petition, it is hereby ORDERED that: 1. A Rule is issued upon. the Respondent to show cause why the Petitioner is not entitled to relief requested; ~~ ~.,h ,~ o ~,/~,yl 2. The Respondent may file an Answer try the no*~+;,,,, ..,, -- L _r_--- J ^~ 3. The Petition shall be decided under Pennsylvania Rule of Civil Procedure 206.7; 4-- i ~` wi,. t sd ~ `FAR. 1t. w t w t ,~' J. Argument shall be held ~- ''`t '~ ~- _._, ------- ~n-Eetrrt~ee~m-- , 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner. BZ' T'HE COURT: ..-~` - / 7 __ ~~ p~TRIBUTION LIST: Paige M. Bellino, Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 1 1 1 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadin~s(u~udren.com / J ed A. Pyke, 1349 W Trindle Road, Carlisle, PA 17013 ~sha A. Pyke, 1349 W Trindle Road, Carlisle, PA 17013 ~ ~ /'~.`at.l.~'Lk- MJU#10070759-6 Lit!pam 1 ! l ~l 2..~ ~~ UDREN LAW OFFICES, P.C. ATTORNEY FOR. PLAINTIFF WOODC'REST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin~s(a~.udren. com PNC Bank, National Association ~ COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION ___ Cumberland County ;... ._; v. ~ _ Trisha A.. Pyke NO. 2010-7269 Civil _~ ~ ''' Jared A. Pyke _._., ~ ~ ' ;, . -- : Defendants . " CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that I have served or caused to he served true and correct copies of the Rule to Show Cause with a Rule Returnable Date of NOVEMBER 26. 2012 with regard to Plaintiff s Motion For Leave to Amend Complaint upon the following person(s) named herein at their last known address or their attorney of record. xxxxx~. Regular First Class Mail Date Served: Novermber G, , 2012 TO: Jared A. Pyke 1349 W Trindle Road Carlisle, PA 17013 Trisha A. Pyke 1349 W Trindle Road Carlisle, PA 17013 UDREN LA.W OFFICES, P.C. BY: ~ t ~~~~ ~ ~~ Attorney for Plaintiff Paige M. Bellino, Esquire PA #309091 MJU#10070759-6 Lit/pam MARK J. UDRFIY", ESQUIRE NJ ,tifAN:9 G/NG ATTORNEY T/NA MARE RICH OFFICE AD.17L47STR.-1 TOR November ~ , 2012 Jared A. Pvke 1349 W Trindle Road Carlisle, PA 17013 UDRF,N LA W OFFICES, P. C. WOODCREST CORPORATE CEI~'TER Ill WOODCREST ROAD SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856.669._5400 FAX: -856. 669. 5399 FREDDIE MA C PENNSYLVANIA DESIGNATED COUl~'SEL Re: PNC Bank, National Association vs. Trisha A. Pyke Jared A. Pyke Cumberland County No. 2010-7269 Civil Dear Defendant: Please find enclosed a true and correct copy of the Rule to Show Cause with a Rule Returnable Date of NOVEMBER 26, 2012 with regard to Plaintiff s Motion For Leave to Amend Complaint in regard to the above captioned matter. The Motion had been served upon you on November 5, 2012. Please refer to the Rule and to the Cumberland County Local Rules of Court which set forth your rights and responsibilities herein. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR 'THAT PURPOSE. Sincerely, UDRF~LAW OFFICES, P.C. Paige~Y'B.ellino, Esquire PA #309091 PMB/pam Enclosure MJU#10070759-6 Lit/pam UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 aleadinssla~udren. com PN ATTORNEY FOR PLAINTIFF Plaintiff V. ~:;, ~ ~.~ ° ~ - - 4 ~ ~t ~ f~ 'T } ~ ~ ~ „r - ' ~~, ~ w' f :~ ..--4 ~' -- ~ :~~ °~": r .,cam ~• c~ -r~ Ica a ~;.. `.., ~-~ Trisha A. Pyke Jared A. Pyke Defendants COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County I N0.2010-7269 Civil CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that I have served or caused to be served true and correct copies of the Rule to Show Cause with a Rule Returnable Date of NOVEMBER 26. 2012 with regard to Plaintiff's Motion For Leave to Amend Complaint upon the following person(s) named herein at their last known address or their attorney of record. _xxxxxx Regular First Class Mail Date Served: Novermber , 2012 TO: Jared A. Pyke 101 C Portland Street Mechanicsburg, PA 17055-3333 BY: Paige PA #: 1 . i i MJU#10070759-6 Lit/pam Trisha A. Pyke 101 C Portland Street Mechanicsburg, PA 17055-3333 A IIDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE 111 WOODCREST ROAD NJ MANAGINGATTORNEY SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH FAX: 856. 669. 5399 OFF/C6dDMlNlSTRATOR FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL November , 2012 3ared A. Pyke 101 C Portland Street Mechanicsurg, PA 17055-3333 Re: PNC Bank, National Association vs. Trisha A. Pyke Jared A. Pyke Cumberland County No. 201.0-7269 Civil Dear Defendant: Please find enclosed a true and correct copy of the Rule to Show Cause with a Rule Returnable Date of NOVEMBER 26.2012 with regard to Plaintiff's Motion For Leave to Amend Complaint in regard to the above captioned matter. The Motion had been served upon you on November 5, 2012. Please refer to the Rule and to the Cumberland County Local. Rules of Court which set forth your rights and responsibilities herein. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Sincerely, UDREN~AW OFFICES, P ~~ By:J~~ ~~, Atto y for ainti Paige M, ellino, Esqui~e'~ PA #3091 PMB/pam Enclosure ~. -~~ `ti i ~ /~ n /f{/yf~ ~ ,~,~; ~ - MJU#10070759-6 Litlpam UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARK J. UDREN, EsQUIRE 111 WOODCREST ROAD NJ MANAGINGATTORNEY SUITE 200 CHERRY HILL, NEW .TERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH FAX: 856. 669. 5399 OFFICE ADMINISTRATOR FREDDIE MAC PENNSYLVANL4 DESIGNATED COUNSEL November ~ , 2012 Trisha A. Pyke 101 C Portland Street Mechanicsurg, PA 17055-3333 Re: PNC Bank, National Association vs. Trisha A. Pyke Jared A. Pyke Cumberland County No. 2010-7269 Civil Dear Defendant: Please find enclosed a true and correct copy of the Rule to Show Cause with a Rule Returnable Date of NOVEMBER 26, 2012 with regard to Pla_intiff's Motion For Leave to Amend Complaint in regard to the above captioned matter. The Motion had been served upon you on November 5, 2012. Please refer to the Rule and to the Cumberland County Local Rules of Court which set forth your rights and responsibilities herein. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Sincerely, ~ ~ -. UDREI?i~LAtW OFFICES, P.C. ; ~ / ;/ ,~~! \ ~..~~: Attorney for'Plaintif --- Paige M. Belling, Esquire PA #, 3p'9091 PMB/pam Enclosure MJU#10070759-6 Lit/pam UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 - pleadin ss @udren.com C- PNC Bank National Association COURT OF COMMON PLEAS mCO - 3232 Newmark Drive CIVIL DIVISIONr`l Miamisburg, OH 45342 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE zo � JARED A PYKE 1349 W.TRINDLE ROAD —i Ln D CARLISLE, PA 17013 NO. 107269 ° THRISA A PYKE 1211 N 16TH STREET HARRISBURG, PA 17103 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), JARED A PYKE; THRISA A PYKE; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $120,082.46 Interest Per Complaint $16,017.11 Additional Interest 04/21/2012 04/25/2013 $7,910.60 Late Charges Per Complaint $251.28 Additional Late Charges 04/21/2012 04/25/2013 $502.56 Escrow Per Complaint $7,606.92 Pro Rata MIP/PMI $156.10 Property Inspections $199.50 Grand Total $152,726.53 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. UD GPIain P.C. BY- DAMAGES DAMAGES EREBY ASSESSED AS INDICATED DATE: PRO Y �i�.500 a MJU#: 10070759 CASE#: 10070759-2 CSCt 4 7 qa ��-a 9oaY3 1►ofic:e V�tcu'��l UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER ill WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Jared A Pyke,Thrisa A Pyke I MORTGAGE FORECLOSURE D efendant(s) ! NO. 107269 TO: Thrisa A Pyke 1211 N 16th Street Harrisburg,PA 171,03 Date of Notice: February 26,2013 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 (800) 990-9108 NOTIFICACION IMPORTATNTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA FOR 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 O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO LMMEDIA.TAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (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. UI R�-N JAW OFFI S, BY: A orney frP nti f RAIGE M. BELLINO, ESQUIRE PA Its 309091 Wooderest Corporate Center 111 Wooderest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 10070759 CASE#: 10070759-2 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County Jared A Pyke,Thrisa A Peke MORTGAGE FORECLOSURE Defendant(s) NO. 107269 TO: Jared A Pyke 1349 W.Trindle Road Carlisle,PA 17013 Date of Notice: February 26, 2013 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 (800) 990-91.08 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 ACCIONT DEBIDA DENTRO DE UN TERMING DE DIEZ(10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O 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, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA ENT PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (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. UDt N LAW OFFICES Ai+ 1 �IIaIRE iPA ID 309091 Wooderest Corporate Center 111 Wooderest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 10070759 CASE#: 10070759-2 UDREN LA W OFFICES, A C. WOODCREST CORPORATE CENTER MARK J. UDREN,ESQUIRE 111 WOODCREST ROAD SUITE 200 CHERRY HILL,NEW JERSEY 08003-3620 ARIE RICH TINA M OFFICE ADMINISTRATOR 856. 669.5400 FAX.856. 669.5399 FREDDIE MAC PENNSYL VA NIA DESIGNATED COUNSEL Prothonotary of Cumberland County One Courthouse Square Carlisle,PA 17013 Re: PNC Bank,National Association VS. JARED A PYKE,THRISA A PYKE, Cumberland County C.C.P.No. 107269 MJU#: 10070759 CASE#: 10070759-2 Dear Sir or Madam: Enclosed please find Affidavit of Non-Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non-Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Alexandria Carr Foreclosure Specialist MJU/ Enclosures MJU#: 10070759 CASE#: 10070759-2 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 COURT OF COMMON PLEAS PNC Bank,National Association CIVIL DIVISION Plaintiff Cumberland County V. JARED A PYKE,THRISA A PYKE, MORTGAGE FORECLOSURE Defendant(s) NO. 107269 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s),that the Defendant(s),JARED A PYKE,THRISA A PYKE,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. e a worn falsification to authorities. Dated: April;2013 Attorn for Plaintiff David Neeren, Esquire PA ID 204252 MJU#: 10070759 CASE#: 10070759-2 Department of Defense Manpower Data Center Results as of:Apr-16-2013 12:17:26 SCRA 3.0 t Status Report Pursuant to Sery cememben Civil Relief Act Last Name: PYKE First Name: JARED Middle Name: A Active Duty Status As Of: AR06-_2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Dale Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. iA Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers 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 only 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 was on active duty for the active duty status date,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:tlwww.detenselink.mil/faq/pis/PCOgSLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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(NOAH Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: F229B389WOFFIFO Department of Defense Manpower Data Center Results as of:Apr-16-2013 12:18:37 SCRA 3.0 Status Rc.port �m Pursuant to Sew remembers Civil Relief Act Last Name: PYKE First Name: THRISA Middle Name: A Active Duty Status As Of: Apr-16-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA I NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. iA AaAy- I -I. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers 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 only 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 was on active duty for the active duty status date,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/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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(NOAH Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 028BI3296OFFGBO 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 a,udren com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County cy Jared A Pyke ``' --:j Thrisa A Pyke MORTGAGE FORECLOSUREm -=-' Defendant(s) co ° NO. 107269 =n CD ; .� Z: — C) PRAECIPE TO ISSUE WRIT OF EXECUTION �� + TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $_152,726.53 Interest From 4/26/2013 $ 2,822.16 to Date of Sale September 4,2013 Ongoing Per Diem of$21.38 - to actual date of sale including if sale is held at a later date (Costs to be added) $ l=/ UDREN LA 16 'Lib F BY: _ q a.(� Atto or Plaintiff �`� a David Neeren E 1Q I � e MJU#: 10070759 CASE#: 10070759-2 PA I D 204fJ"'Z. Cu Q 9C 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 Jared A Pyke FORECLOSUREr Thrisa A Pyke MORTGAGE� Defendant(s) .�3>-> CO (-) NO. 107269 r--2'- --q c.:. .�o =-n �c7 ',, CERTIFICATE OF ACT 91 —i Cn :71 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: Act 91 procedures have been fulfilled El Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage . This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. N A P S, C. Attorney for Plai ff David Neeren. Esquire a ; } 2,0425. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com , PNC Bank,National Association COURT OF COMMON PLEAS z, -- Plaintiff CIVIL DIVISION MM � , V. Cumberland County -< -V rrq Jared A Pyke Nr R ;U Thrisa A Pyke MORTGAGE FORECLOSURE Defendant(s) y C:) �o mac-; M. c NO. 107269 X Cn 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: 1349W Trindle Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 2. Name and address of Defendant(s) in the judgment: Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders -None Mortgage Electronic Registration Systems, Inc. PO Box 2026 Flint, MI 48501-2026 5..Name and address of every other person who has any record lien on the property: Sr lien Holders -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: Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 1349W Trindle Road Carlisle, PA 17013 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: Federal Tax Lien Holders -None Condo/Homeowners Association-None 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: I�I 13 ;B . ES, P.C. orney for Plain MJU#: 10070759 CASE#: 10070759-2 Neeren, Esquire David PA (D 20!4252 V UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadingsa,udren.com n ' c cm PNC Bank,National Association COURT OF COMMON PLEAS , Plaintiff CIVIL DIVISION �" -•e -o r V• Cumberland County coo �- --+c, JARED A PYKE, THRISA A PYKE MORTGAGE FORECLOSURE Defendant(s) cc� C � ve NO. 107269 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 Your house (real estate) at 1349W Trindle Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on September 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$152,726.53, 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 Sheriffs 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (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 c _ pleadings audren.com MOD PNC Bank,National Association COURT OF COMMON PLEAS vir Plaintiff CIVIL DIVISION V. Cumberland County . JARED A PYKE,THRISA A PYKE MORTGAGE FORECLOSURE :r,-= Defendant(s) un NO. 107269 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 Your house(real estate) at 1349W Trindle Road,Carlisle,PA 17013 is scheduled to be sold at. the Sheriffs Sale on September 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013,to enforce the court judgment of$152,726.53, 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:(8.56)..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 Sheriffs 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. 1 1 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-7269 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 JARED A.DYKE,THRISA A.DYKE (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: $152,726.53 L.L.:$.50 Interest FROM 4/26/13 TO DATE OF SALE SEPTEMBER 4,2013-ONGOING PER DIEM OF (0 $21.38 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm: Due Prothy: $2.25 Arty Paid: $207.40 Other Costs: Plaintiff Paid: Date:5/8/13 - David 1,Prothonotary (Seal).,. By: Deputy -REQUESTING PARTY: Name:DAVID NEEREN,ESQUIRE Address:UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 204252 ! UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS CIVIL DIVISION ' Plaintiff Cumberland County a � V. JARED A PYKE; NO. 107269 THRISA A PYKE; et al C") s� Defendant(s) = rJ `_' • PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: ' 7/e3 //3 UDREN LAW OFFICES,P.C. B • �i ey for Plaice David Neeren Esquire PA ID 204252 Service of Process by , PNC Bank,lkiational Association,et.at,Plaintiff(s) APS International, Ltd. vs.Jared A.Pyke,et.al.,Defendant(s) 1-800-328-7171 APS International Plaza ,Iiild.1,1111171 7800 Glporoy Road Min Minneapolis,MN 55439-3122 APS File#: 123849-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT f - — — 1 Service of Process on: UDREN LAW OFFICES --Jared A. Pyke Ms.Henni Crommarty Court Case No.Cumberland Co 107269 I 1 1 Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 Customer File: N10070759-2 State of: Pen r\St–A ss. County of: C(..c. DE, t Name of Server: C1,r;54r a, 1'{5 e 1 , undersigned, being duly sworn,deposes and says that at all times mentioned herein, s/he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Jared A.Pyke and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: 1349 W.Trindle Road,Carlisle,PA 17013 Dates/Time/Address Attempted: / , Reason for Non-Service: - 'Fe) 11 0 e �pl ni QC � �f.. -4- t. r� rt i Dates/Time/Address Attempted: b1 Jlt-Ce to4a{� V`rd fG(4-re S Reason for Non-Service: 6216) 739"c290-C) Dates/Time/Address Attempted: Reason for Non-Service:. Based upon the above stated facts,Affiant believes the defend. • is avoi•'s service. Signature of Server: Undersigned declares under penalty of perjury Subscr/d any • s to b- ore me this that the fo egoing is tr9e 7 correct. C _,y`• / 20 --- - %//% /A' Signature of Server ' , Mr. y ublie (Commission xpires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA _ Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES Service of Process by r PNC ii:tnk,National Association,et.al.,Plaintiff(s) APS International, Ltd. Jared A.Pyke,et.al.,Defendant(s) 1-800-328-7171 APS International Plaza 7800 Glenroy Road Minneapolis,MN 55439-3122 APS File If: 123849-0002 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES --Thrisa A.Pyke Ms.Flenni Crommarty Court Case No.Cumberland Co 107269 I 1 1 Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 C istomer File: N10070759-2 j Stated: ttta�.� �. � t _ _: — _ — - — — — — - - — — — — — — — — — - County of: ;Ada„A Name of Server: r;S-I-1'01.1 'A t undersigned,being duly sworn, deposes and says that at all times mentioned herein. s/he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A.Pyke and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/Time/Address Attempted: 1211 1 N. 16th Street,Harrisburg,PA 17103 Reason for Non-Service: Chili 3 I/O.SOA M / Dates/nine/Address Attempted: 1�r0peil-y is ✓C/�LQn1 elect e. i'NiLer%Leo'l 11/aG li Reason for Non-Service: by S4 k }TQ;n Teen a n L'e. (711) ciro— D 7G 2- Dates/Time/Address Attempted•, 9e' ouh/ ei a ^6,41A-e.>! L/e w e t d(in X>/vi C� k')9) 1 3f o.2 Reason for Non-Service: I I Based upon the above stated facts,Affiant believe = de - ,:nt is avoiding service Signature of Server: Undersigned declares under penalty of perjury `.Subs -d and .worn to befog that the foregoing is true and correct. � rrsay of y • t Signature of Server taw: c o Ok onu C ;x ices C P APS International, Ltd. COMMONWEALTH OF PIVSYLVANIA Notarial Sea& I M.Michelle Guyton,Notatx"bli Carlisle Boro,Cumberland w My Commission Expires July 9,2026' MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES Service of Process by PNC Bank,National Association,et.at.,Platntlff(s) APS International, Ltd. vs. Jared A Pyke,et.al.,Defendant(s) 1-800-328-7171 ti1;'1'E117`;113.lifVAL APS International Plaza Ior 7800 Glenroy Road :y �toot Minneapolis,MN 55439-3122 APS File 0: 124100-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES —Thrisa A Pyke Nis.Henni Crommarty Court Case No.Cumberland Co 107269 1 I 1 Wooderest Rd.,Ste.200 Cherry hilt,NJ 08003-3620 Customer File: N10070759.2 State of: ss. County of: �� �� • Name of Server: irL --t .t 'g r�ci.0 I ,undersigned,being duly sworn,deposes and says that at all times mentidned herein,s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A Pyke and after due and diligent efforts,was unable to effect service. Attempts: The following is a list of the attempts made to effect service:�1 �+ !� /� r YXrr-._7G3 UateslTime/AJdress Attempted: 3710 N.4th St-r7eet,Harrisburg,PA 17110 t"tt�+LY Smys r .iott c/1 eAr P 1 fp f� Q/I 3,tlyk1(s Reason for Non-Service: 7��f t�1 7� r�et'ss sr p 4 J a, 3M-c/- Dates/Time/Address Attempted: 7/i)/i 3 r 3 0 A n // Reason for Non-Service:,A10 An9 r-ne✓ ,SC4-wtts ilu e- fkri e. $kc e J - et4 DatesaimelAddress Attempted: 7/12/1 3 4"; `i 3 '+"t Reason for Non-Service: Nit) /l,s,e e -.-[_ sS4 +-+� V era.k o+ Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscri ; : • s �. . refore me this that the foregoing is true and correct. :. . ✓/ ,/l th j Signature of Server /of ty Publi (Comm 'on Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle 8oro,Cumberland County My Commission Expires July 9,2016 MEMBER,pfNNSVLVAN:A ASSOCIATION OF NOTARIES i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County .) ty c ..�. .,� V. 't3W xs. tX7 mrn JARED A PYKE; NO. 107269 G-) THRISA A PYKE; et al .< uD Q S-r- Defendant(s) y.;-,. Z� C, PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: c �� t3 UDREN LAW OFFICES,P.C. BY: ey or Plaintiff David Neeren, Esquire R ID 204202 Service of Process by PNC Bank,National Association,et.at.,Platntiff(s) ' ,. APS International,Ltd. VS. ` .tared A Dyke,et.at.,Defendant(s) N_ 1-800-328-7171 APS international Plaza 7800 Glenroy Road Minneapolis,MN 55439-3122 APS File#: 124100-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES "-Thrisa A Pyke Ms.tlenni Crommarty Court Case No.Cumberland Co 107269 11I Wooderest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 ! I Customer File: N10070759-2 I State of: _ ss. County of: T{ Name of Server: CLjR6a. undersigned,being duly sworn,deposes and says that at all times menti'dned herein,s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A Pyke and after due and diligent efforts,was unable to effect service. Attempts: The following is a list of the attempts made to effect service: ! CYXM-<--74 S) UatesMme/Address Attempted: 3710 N.4th Street,Harrisburg,PA 17110 qgj,Or Say, J` j,I all g AAj- h Reason for lion-Service: / o w 0.-1 Dates/Time/Address Attempted: 7'�1h3 9'�3 u An A Reason for Non-Service: 10 Y%3t.-ejr J4 l i- a4 Dates(rime/Address Attempted: ZZ12b 3 J,26;20 _ /l Reason for Non-Service: AIV t ..__ V.-t E:. Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscri s to efore me thi that the foregoing is true and correct. ay , Signature of Scrver of ry Publi (Co mi on Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMSER,PENNSYLVANIA ASSOCIA17ON OF NOTARIES • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. c J r-. Jared A Pyke; Thrisa A Pyke 3 NO. 107269 rn co cn z r rn :.: Defendant(s) z -a c, rx cD = D c-, o-r MOTION FOR SPECIAL SERVICE PURSUANT yc° c? TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant(s): JARED A PYKE, THRISA A PYKE, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: JARED A PYKE 1349 W. TRINDLE ROAD CARLISLE, PA 17013 THRISA A PYKE 1349 W. TRINDLE ROAD CARLISLE, PA 17013 A copy of the Return of Service is attached hereto as Exhibit"A". 2. Process was unable to be served at the then last known address of said Defendant(s) as follows: THRISA A PYKE 1211 N 16TH STREET HARRISBURG, PA 17103 A copy of the Return of Service is attached hereto as Exhibit`B". 3. Process was unable to be served at the then last known address of said Defendant(s) as follows: THRISA A PYKE 3710 N 4TH STREET HARRISBURG, PA 17110 A copy of the Return of Service is attached hereto as Exhibit"C". 4. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit"D". 5. Said investigation was unable to determine an alternate address for said Defendant(s). 6. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit"E". 7. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph 1,by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: U c1 �. Attorne ss for Plaintiff Esquire Nicole LaBle tta PA ID 202194 Service of Process by PNC Bank,National Association,et.al.,Plaintiff(s) — APS International, Ltd. vs. Jared A.Pyke,et.al.,Defendant(s) _ 1-800-328-7171 APS International Plaza 7800 Glenroy Road �• Minneapolis,MN 55439-3122 APS File i1: 123849-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: tLI)REN LAW OFFICES --Jared A. Pyke Ms. Ilenni Crommartv Court Case No.Cumberland Co 107269 1 1 I Woodcrest Rd.,Ste.200 Cherry 11i11,NJ 08003-3620 Customer File: N10070759-2 State of: Pen C\ 1■1 County of: �.- a.4111 Name of Server: C�r;S�rti, I , undersigned, being duly sworn, deposes and says that at all times mentioned herein. s/he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Jared A.Pyke and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: 1349 W.Trindle Road,Carlisle,PA 17013 I)atesuTiotc/address Attempted: Reason for Non-Service: G/1.2,?-// 3 1,'5-0 7 -1)(Ope()M ! S Vac T4' I S beTns) II:ucsr nom/Address Attempted: v a frL. {J S Reason for Non-Servic • Lail.) 739-.290'0 Dates/rime/Address Attempted: Henson for Non-Service: 1 Based upon the above stated facts,Affiant believes the defend3nt,sis avoidin service. Signature of Server: Undersigned declares under penalty of perjury Subscr, d an. w. . to be, ore me this /I;.' that the foregoing is true_at l correct. e •ay •f 20 Signature of Server j ,14'x Nubile (Commission({xptrcs) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES EXHIBIT A Service of Process by PNC Bank,National Association,et.al.,Plaintiff(s) - APS International, Ltd. vs. iira Jared A.Pyke,et.al.,Defendant(s) llik 1-800-328-7171 APS International Plaza 'Nair7800 Clenroy Road Minneapolis,MN 55439-3122 APS File#: 1243119-OUUI AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES I --Thrisa A. Pyke Ms.Henni Crounnarty Court Case No.Cumberland Co 107269 III Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 Customer File: N10070759-2 State of; !';,&1_;4,, L L1 ' SS. County of: J/ I ILa Name of Server: C.1.-1 f I-4f aet -35QRR- ( . undersigned, being duly sworn,deposes and says that at all times mentioned herein, s/he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A.Pylte and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/Time/Address Attempted: 1349 W.Trindle Road,Carlisle,PA 17013 Reason for Non-Service• 7/93 it 3 //:.Si.) Ali Tir o(4 /I ill Vex c•-vs el' Ilatesfrinte/AddressAltemptcd: rlGt�'10,, e-et 5ot.Pe- ,. (21G) 7.3 / -.2 9V0 Reason for Non-Service: Else,/•V S..:14._ ?IA J J A� c�ire- I)ates/time/Address Atlempled;, uP(¢.( (y kr !— PNC g"le //y Reason for Non-Service: L Based upon the above stated facts. Affiant believes the defendant is iding service. zmil Signature of Server: + Undersigned declares under penalty of perjury Subscr'.�,d a o sworn jo before me the 7 that the foregoing is true and correct. . I da '�of L ,!/fir �i 1 (' - j------------ l / A/re Signature of Server ` ublic _ (Commis-on Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES Service of Process by PNC Bank,National Association,et. al.,Plaintiff(s) APS International, Ltd. vs, ,tared A.Pyke,et.al.,Defendant(s) 1-800-328-7171 APS International Plaza 7800 Glenroy Road Minneapolis,MN 55439-3122 APS File If: 123849-0002 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES --Thrisa A. Pyke Ms.Henni Cromntarty Court Case No.Cumberland Co 107269 11 I Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 C tstomer File: NI0070759-2 State of: Po,41 a. — - a l I County of: _ !A $ O Name of Server: PA . undersigned, being duly sworn,deposes and says that at all times mentioned herein. s/he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A. Pykc and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: 1211 N. 16th Street,Harrisburg,PA 17103 Dates/rime/Address Altempted: Reason for Non-Service: G// ?Ji 3 /LIO.' OA f1 J I / r ` Dales/Time/Address Attempted:, PrO 111 VOL(' e? I eae•a(� f..J�hy-e(" ece( I1�24lI� Reason for Non-Scrvicc: by Si k 1-10.%n 4ei10.n ce.. (719) t/VU O 7G Dates/ imetAddress Attempted: e2vrak7 11 V e w e., C j ( 27 ) q a - U Reason for lion-Service: I I Based upon the above stated facts,Affiant believe- - de :• .•tat is avoiding service,, Signature of Server: Undersigned declares under penalty of perjury Subs i•-d and .worn to befo • Ill that the foregoing is true and correct. aay of �� t r !Jra/J rA Signature of Server — _ (Cuin nttu -,xpires AI'S International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seat— M.Michelle Guyton,Notary Public Carlisle Bor),Cumberland Caun y My Commission Expires July 9,2016 MEMBER,BENNSYLVANtA ASSOCIATION OF NOTARIES EXHIBIT B Service of Process by PNC Bank,National Association,et.al.,Plaintiff{s) APS International, Ltd. vs. / 1''. Jared A Pyke,et.ai.,Defendant(s) / ``' 1-800-328-7171 INTER`PLTIONA APS International Plaza 7800 Glenroy Road L7nn:� Atinncapolis,MN 55439-3122 APS File#: 124100-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES Thrisa A Pyke Ms.Itenni Crommarty Court Case No.Cumberland Co 107269 1 I 1 Woodcrest Rd.,Ste.200 Cherry Bill,NJ 08003-3620 Customer File: N10070759-2 State of: ILA a ..i ss. County of: �..► AMM Name of Server: CLNN--- Nr 4 1 , undersigned,being duly sworn,deposes and says that at all times menttined herein, s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriffs Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Thrisa A Pyke and after due and diligent efforts,was unable to effect service. Attempts: The following is a list of the attempts made to effect service: / �l '+ C VX M-`.7143) DateslTimelAddressAticmpicd: 3 710 N.4th Street,Harrisburg,PA 17110 114;1 ''i' & i c'L7 P 1p i, o1: S.( a// 3 ,tk arts Reason for Non-Service: 7/4/13 / .t/L)pp1 N 0 Ae e/, 4 4- 1-t y rr)- o-- i�L la...rS,�I t r1n. s pi)ra., S e Mies/Time/Address Attempted: 7/lit/t 3 S^S 3 0 A n l Reason for Non-Service• A✓t) AriS fA-rke 1 441. S,}1^ce - kar- l Ott 1)ates/rime7Address Attempted: 7J)2J,3 Cyr; c C[p i Reason for Non-Service: AA) Igrv.e c.._ (4 Lee1.- t/".t Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscri ;ant s '--i to efore me thi` that the foregoing is true and correct. /7 •ayli.ay /j 2; Signature of Servo / of ry Publi (Comm s on Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMBER PENNc"l VAN'A As5OC1AT ON OF NOTARIES EXHIBIT C Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiffs) PNC Bank,National Association vs Defendant(s) Jared Pyke AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I,Abigail Sessions, do hereby swear and affirm that I made the following diligent search and inquiry on defendant,Jared Pyke: 1. On July 8,2013, I conducted a Skip Trace, the results of which indicated the defendant's current residence is 1349 W.Trindle Road, Carlisle, PA, 17013. 2. On July 8,2013,I conducted an Internet search for the Death Records of the Defendant,the results of which indicated that the defendant is not deceased. 3. On July 8,2013, I conducted an Internet search for the Voter Registration Records of the Defendant,the results of which indicated that the defendant is a registered voter at the address of 1349 W. Trindle Road, Carlisle, PA, 17013. 4. On July 8,2013, I conducted an Internet search for the Motor Vehicle Records of the Defendant,with no results obtained from the search. 5. On July 8,2013, I conducted an Internet search of Facebook,Twitter, Yahoo!, Google and Bing with intellius.com indicating the defendant is currently living in Carlisle, PA. 6. On July 8,2013 at 6:24pm I placed a phone call to defendant's neighbor, Robert Koser(717-697-4417), of 1347 W. Trindle Road, Carlisle, PA,17013 to inquire about defendant's last known address.There was no answer. 7. There were no other potential neighbors available to confirm the defendant's last known address. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unworn falsification to authorities. 07/08/2013 Date Abigail Sessions Investigative Processor De Novo Attorney Services, Inc. P.O.Box 20215 Baltimore,MD 21284 Our Job Serial Number: NOV-2013004528 Ref 10070759-2 EXHIBIT D Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiff(s) PNC National Bank, National Association vs Defendant(s) Trisha Pyke AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I,Abigail Sessions,do hereby swear and affirm that I made the following diligent search and inquiry on defendant,Trisha Pyke: 1. On July 2, 2013, I conducted a Skip Trace,the results of which indicated the defendant's current residence is 3710 N. 4th Street, Harrisonburg,PA,17110 2. On July 2, 2013, I conducted an Internet search for the Death Records of the Defendant,the results of which indicated that the defendant is not deceased. 3. On July 2, 2013, I conducted an Internet search for the Voter Registration Records of the Defendant,the results of which indicated that the defendant is a registered voter at the address of 1349 W.Trindle Road,Carlisle, PA, 17013. 4. On July 2, 2013, I conducted an Internet search for the Motor Vehicle Records of the Defendant,with no results obtained from the search. 5. On July 2, 2013, I conducted an Internet search of Facebook,Twitter,Yahoo!, Google and Bing with intellius.com indicating the defendant is currently residing in Harrisonburg, PA. 6. On July 2, 2013 at 6:o9pm I placed a phone call to defendant's neighbor, D. Mumma(717-238-3602) of 3712 N.4th Street, Harrisonburg, PA, 17110 to inquire about defendant's last known address.The person who answered the phone was able to verify the defendant's last known address. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge,information, and belief. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsification to authorities. 07/02/2013 /L..L.fi AL:6,k .t Date A.igail Sessions Investigative Processor De Novo Attorney Services, Inc. P.O. Box 20215 Baltimore, MD 21284 Our Job Serial Number: NOV-2013004404 Ref: 10070759-2 Udren Law Offices, PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill, New Jersey 08003 TO:POSTMASTER DATE: July 17,2013 Harrisburg,PA,17110 CASE No.: 10070759-2 Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special note that this request deals with a matter pending in Court and,therefore,any information available would be greatly appreciated,even if any existing forwarding order has expired. NAME:Thrisa A Pyke LAST KNOWN ADDRESS:3710 N.4m Street,Harrisburg,PA 17110 NOTE: The name and last known address are required for change of address information. The name, if known,and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1) and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester. Attorney at Law 2. Statute/regulation that empowers me to serve process(not required if requester is an attorney) 3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Thrisa A Pvke 4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania 5. The docket or other identifying number if one has been issued: 2010-07269 6. The capacity in which this individual is to be served(defendant,witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices,PC. Woodcrest Corporate Center ll1" ••: Road Cherry``�.y. Jersey 08003 B Y: A...1 JJ1/ j ,, '/ . . pecialst -r **************************************** ********************************************* POST OFFICE USE ONLY NEW ADDRESSBOXHOLDER'S NAME AND STREET ADD l Tot known at address given _No such number AFFD STMA X4IERE Left no forwarding _No change of address on file it a' _No such street `GOOD AS ADDRESSED , a illA . c6 .1 , ( . i)c4fiiiiiivil-- - EXHIBIT E Udren Law Offices, PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill, New Jersey 08003 TO:POSTMASTER DATE: August 22,2013 Harrisburg,PA,17103 CASE No.:10070759-2 Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special note that this request deals with a matter pending in Court and,therefore,any information available would be greatly appreciated,even if any existing forwarding order has expired. NAME:Thrisa A Pyke LAST KNOWN ADDRESS: 1211 North 16T'Street,Harrisburg,PA 17103 NOTE: The name and last known address are required for change of address information. The name, if known,and post o ffice box address are required for boxholder information. The following information is provided in accordance with 39Crit 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1) and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney at Law 2. Statute/regulation that empowers me to serve process(not required if requester is an attorney) 3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Thrisa A Pvke 4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania 5. The docket or other identifying number if one has been issued: 2010-07269 6. The capacity in which this individual is to be served(defendant,witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH (TITLE 18 US.C.SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices,PC. Woodcrest Corporate Center 111 Woodcrest • C ery Hill, ew J `-4 t 003 I r /./BY: t A._,i i ia.wt 1 1 r f,SY's._''t1 ii t ************************************************************************************** POST OFFICE USE ONLY NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS _Not known at address given _No such number AFFIX POSTMARK HERE _Left no forwarding _No change of address on file No such street GOOD AS ADDRESSED Udren Law Offices, PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill, New Jersey 08003 TO:POSTMASTER DATE: July 17,2013 Carlisle,PA,17013 CASE No.:10070759-2 Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special note that this request deals with a matter pending in Court and,therefore,any information available would be greatly appreciated,even if any existing forwarding order has expired. NAME: Thrisa A Pyke LAST KNOWN ADDRESS: 1349W Trindle Road,Carlisle,PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known,and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1) and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney at Law 2. Statute/regulation that empowers me to serve process(not required if requester is an attorney) 3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME:Thrisa A Pvke 4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania 5. The docket or other identifying number if one has been issued: 2010-07269 6. The capacity in which this individual is to be served(defendant,witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANYOTHIER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION ION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE TITAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices,PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill,N w Jersey 08003 BY: 41%• orec,.: S.•:"1 POST OFFICE USE ONLY NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS of known at address given —No such number AFFIX POSTMARK HERE ft no forwarding No change of address on file No such street GOOD AS ADDRESSED / C'r Udren Law Offices, PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill, New Jersey 08003 TO:POSTMASTER DATE: July 17,2013 Carlisle,PA, 17013 CASE No.:10070759-2 Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special note that this request deals with a matter pending in Court and,therefore,any information available would be greatly appreciated,even if any existing forwarding order has expired. NAME:Jared A Pyke LAST KNOWN ADDRESS: 1349W Trindle Road,Carlisle,PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known,and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1) and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Attorney at Law 2. Statute/regulation that empowers me to serve process(not required if requester is an attorney) 3. The names of known parties to the litigation:(PNC Bank,N.A.) vs.NAME;Jared A Pvke 4. The Court in which the case has been or will be heard: Cumberland County Pennvslvania 5. The docket or other identifying number if one has been issued: 2010-07269 6. The capacity in which this individual is to be served(defendant,witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WIT HACT UAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH (17TLE 18 US.C.SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices,PC. Woodcrest Corporate Center 111 Woodcrest Road if J Cherry Hill,N- Jersey 08003 JA .i.r . Foreclosure pee :i"' V *************************************** *********************************************' POST OFFICE USE ONLY NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS %*. Not known at address given No such number AFFIX POSTMARK HERE �ft no forwarding _No change of address on file No such street ,^GOOD AS ADDRESSED UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Jared A Pyke; Thrisa A Pyke NO. 107269 Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Returns of Service marked Exhibits "A", "B" and "C" the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses: A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "D". Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit"E". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: V A _C Attorneys for Plaintiff Nicole LaBlefta, Esquire PA ID 202194 VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C. S . Sec 4904 relating to unsworn falsification to authorities . Date: UDREN LAW OFFICES, P .C. . Attorneys for Plaintiff Nicole LaBIea, Esquire PA ID 202194 • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Jared A Pyke; Thrisa A Pyke NO. 107269 Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 13TH day of September, 2013. Udren Law Offices, P.C. Attorney for Plaintiff By: 11" 4 e �.gi � l Nicole aAead, ; PA ID 202194 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP.No. Docket Number: 107269 NAME: JARED A PYKE MAILING ADDRESS: 1349 W. TRINDLE ROAD CARLISLE, PA 17013 NAME: THRISA A PYKE MAILING ADDRESS: 3710 N 4TH STREET HARRISBURG, PA 17110 i L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION 4, c PNC Bank,National Association ;M a =rn r s I rl Plaintiff V. cn N) . = Jared A Pyke; NO. 107269 t-- _.I�, Thrisa A Pyke x CD ° Defendant(s) ORDER _ AND NOW, this o� day of Ato4LtV, 2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Jared A Pyke, Thrisa A Pyke, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 1349W TRINDLE ROAD CARLISLE,PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: JARED A PYKE 1349 W. TRINDLE ROAD CARLISLE,PA 17013 THRISA A PYKE 3710 N 4TH STREET HARRISBURG, PA 17110 BY THE COURT: J • I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 .leadin i s • udren.com PNC Bank,National Association COURT OF COMMON PLEAS cr'° Plaintiff CIVIL DIVISION V. Cumberland County _ rr CA) JARED A PYKE, MORTGAGE FORECLOSURE -<> THRISA A PYKE, Defendant(s) NO. 107269 K?-tf > urn AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 —s Plaintiff,by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs 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 Sheriffs 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. 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: ` o•-2_9-13 UDREN LA a FICES,P.C. BY A orneys for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 MJU#: 10070759 CASE#: 10070759-2 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 •leadin l s ' udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County Jared A Pyke MORTGAGE FORECLOSURE Thrisa A Pyke Defendant(s) NO. 107269 AMENDED 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: 1349W Trindle Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jared A Pyke 1349 W. Trindle Road Carlisle,PA 17013 Thrisa A Pyke 3710 N.4th Street Harrisburg, PA 17110 Thrisa A Pyke 1349 W. Trindle Road Carlisle, PA 17013 2.Name and address of Defendant(s) in the judgment: Jared A Pyke 1349 W. Trindle Road Carlisle,PA 17013 Thrisa A Pyke 3710 N. 4th Street Harrisburg, PA 17110 Thrisa A Pyke 1349 W. Trindle Road Carlisle, PA 17013 3.Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders -None Mortgage Electronic Registration Systems,Inc. PO Box 2026 Flint, MI 48501-2026 US Bank NA, as Trustee do GMAC Mortgage, LLC 1100 Virginia Drive Fort Washington, PA 19034 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -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: Commonwealth of PA, Department of Revenue Bureau of Compliance-PO Box 281230 Harrisburg, PA 17128-1230 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 1349W Trindle Road Carlisle, PA 17013 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: Federal Tax Lien Holders -None Condo/Homeowners Association-None 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: �,0 _13 UDREN LAW ICES, P.C. BY: Attorney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 MJU#: 10070759 CASE#: 10070759-2 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 an , ,ahona ssociahon COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County JARED A THRISA A PYKE; MORTGAGE FORECLOSURE Defendants) NO. 107269 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): JARED A PYKE AND THRISA A PYKE; PROPERTY: 1349W Trindle Road, Carlisle,PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 09/04/2013 at 01:00 PM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013. 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. The Sheriff will file a Schedule of Distribution 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. MJU#: 10070759 CASE#: 10070759-2 WilhE 011110 III laills 411511 1111111111 r4 O C cra N ao C7 inn G ono �� �w"-1mO� ° G '2d ° d '''-:t i r. tp dKn°co C"3O cones 9w a 'm rlErf *'rjt .p 00'19 0 .b Np w CO nacJ�p LTC '�, r• P '�� W N �G wo ?.p.4 z O.�� 5 o. Cu to cc el, c—� O 0.w. 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It* 001: o. %IOW o n o i te A . co "70 L. lisc.: , riot% IA ON 11, Ili 5.°,-t I o 01 cc '".� { ,.•�` N �G u•O F , F� r, g So a ;* - } 2013 5 �; o cgs o,; a-.fir,,,• v► 07113•J app3 illtA K °°r s i•� j jt Z })laiteefrO S�P+GE O .• r.,- n00-,. . ... ,:,....0,, crp w,c� t0 �b.5�E+0 f d r , n^ r A����s,Mo N „ oo-0 � el o g n s y ,,e,,. . 0 ^ Yn OnG m GG q 0 %.?;,0111011111TaiiiikililiW s r' X3 8� Oil. VA ? ' m y o 0 Vm 0 i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CUMBERLAND County JARED A PYKE, MORTGAGE FORECLOSURE THRISA A PYKE, Defendant(s) NO. 107269 VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: JARED A PYKE 1349 W. TRINDLE ROAD, CARLISLE,PA 17013 THRISA A PYKE 3710 N.4TH STREET,HARRISBURG, PA 17110 DATE MAILED: September 24,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Dated: 04•Zq ,2013 UDREN L A"'OFFICES,P.C. BY: A orney for Plaintiff MJU#: 10070759 CASE#: 10070759-2 SALVATORE CAROLLO, ESQUIRE PA ID 311050 Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION ...... .... PNC Bank,National Association -v3 w rico Plaintiff zrn rn rn-.. z= -0 v. (AL"' 1•44 oc: Jared A Pyke; NO.107269 r-z —? Thrisa A Pyke d<° 3'' _�; Defendant(s) ` [ ORDER - AND NOW,this J'L y of ` b$EJ 2_13,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Jared A Pyke,Thrisa A Pyke,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 1349W TRINDLE ROAD CARLISLE,PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: JARED A PYKE 1349 W.TRINDLE ROAD CARLISLE,PA 17013 THRISA A PYKE 3710 N 4TH STREET HARRISBURG,PA 17110 BY THE COURT: ,spegetff.d).2A1LAL_,) J. © 0 IP Y 1CW ■ • AA . rn� g ` I is • • I;" O J. l V V y'; _, a . .a . ; v.0" - Q+- < *A Nimumil••••• I'll i o a .1 w w .rr..1,�., ,,may M w .rte : • 1 N "oneramerma U- -.I �o tL .`r. , 'VIZ;.".7 * kfl) . ...11...,0 l.) :p., 0tX%‘ o CO N y IllirC014‘11b ' °o 14%1 � N b3 Gj o a. w 0 0 mss° i �Q c� ga 3 0 E m m . <Z a k m: o ?o ao ..-11 . ?. a allii .,„2 Cr 9 $ "[ 12 9 gN N W g m 0. 4w &' �" m W C: W 20 0 � a-. 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(7., • \.--- (..., , \\,•:).• ,.--,,\-::„,,,N\v• ,,,,,,--„,‘„,„\,'•„,,), r' N N LIa 0i r►,A�, tD w M iG O iRtItllIL r . e G� t G S o o a O il G O: o w o y J PI O b• v:>\ 9 S n v\ `� y % n000 1110i 3 S 1 Cho ¢ �� � M R O a i Q R t „„4,1i sillpsistio -, -, , , ...;VIA 1.0 lel ill I I 1 I:t 1g 1 1.*'6.: r b ei e F f � GE» z�E it ill. P � A vxk't$$73 zz ;: /w a$aa3 002.-T 24 2013- . . ' ?if,EA \-- ',Wit■er a t mt *a,i.,1,,:,,,,,,,.,,,,%- - �;l qg r4 r itreamil'a'isigailifIWAIII16,v' ?�'� . ■Va ■�� b.l itAlt Itti, UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. JARED A PYKE; NO. 107269 THRISA A PYKE; et al Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: I c, _c•1) UDREN LAW OFFICES,P.C. BY: A orney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 Sir o •‘I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION `c o PNC Bank,National Association X v a-o Plaintiff =rn �. m rn V. -�A� Jared A Pyke; NO. 107269 r–x -46 Thrisa A 'ke <C3 3 ='32.>p - Defendant(s) -< tt ORDER AND NOW,this y of `errt tt 1 22013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Jared A Pyke,Thrisa A Pyke,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 1349W TRINDLE ROAD CARLISLE,PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: JARED A PYKE 1349 W.TRINDLE ROAD CARLISLE,PA 17013 THRISA A PYKE 3710 N 4TH STREET HARRISBURG,PA 17110 BY THE COURT: J. © PDY as S•W"� • • Service of Process by PNC Bank,National Association,at.aL,Plaintiff(s) `.. APS International, Ltd. 's' �� 1-800-328-7171 Jared A.Pyke.et.al„Defendant(s) �_,^-- -- 'APS 1141 Tt4NAL APS International Plaza 4,\SJ, Min Glenroy Rd. -/ Minneapolis.MN 55439-3122 APS File M: 125501-0001 _ AFFIDAVIT OF SERVICE--Individual Service of Process on: UOREN LAW OFFICES —Jared A.Pyke,by posting Court Case No.Cumberland Co 107269 Ms.Henn!Crommarty 1 II Woodcresl Rd..Ste.200 Cherry hill.NJ 08003-3620 sk County of: A/AT/LTSIt.•_A.II Name of Server: ‹\ c DAHLA ( .undersigned.being duly sworn,deposes and says that at the timed pf service.s/he w f legal age and was not a party to this action: Date/Time of Service: that on the /\,I A.day of t`� . .20 .at 4.O'clock _ M Place of Service: at 1349 W.Trindle Road • ill Carlisle,PA 17013 -•, Documents Served: the undersigned.served the documents described as: Notice of Sheriff's Sale of Real Property w/Order Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Jared A.Pyke,by posting Person Served,and -- B personally delivering them into the hands of the person to be served. Method of Service: By y g `A By delivering them into the hands of Son a person of suitable age,who verified,or who upon questiol'stated,that he/she resides with Jared A.Pyke,by posting at the place of service.and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ; Skin Color : Hair Color • Facial Hair Approx.Age : Approx.Height : Approx.Weight To the best of my knowledge and belief.said person was not gaged in the US Military at the time of service. Signature of Server: Unrc+gpe declares under penalty of perjury ;ub cr . and s n to before that the forego' g is.irue r '}y of * SL,. . e of - ib� t • .d ' . pines) S International,Ltd. QOMMONWSAI.TH OF PENNSYLVANIA Notarial Seal M.Michelle Guybon,Notary Public WI*Dom O and County Ny COrnmlalen 6pttes kV 9,2016 MOM PONNSO919UA AsSDt7A17on OF NOTARIES oo� a. el/I°1\\WI MIMIMMINNIMMINIMMINI 0.. Service of Process by PNC Bank.National Association,et.al..Plaintiff(s) t, ,u c;›, APS International, Ltd. vs. Jared A.Pyke.et.aL,Defendant(s) `i_= '`1 \ I-800-328-7171 ,try itiTeRSATIMUL-°,APS International Plaza 7800 Gloomy Rd. Minneapolis.MN 55439-3122 APS File N: 125501.0001 _ AFFIDAVIT OF SERVICE--Individual I Service of Process on: UDREN LAW OFFICES -Thrise A.Pyke,by posting Ms.Henna Crommarty Court Case No.Cumberland Co 107269 111 Wooderest Rd„Ste.200 Cherry HIB.NJ 08003.3620 • State of. .1Io. e- as. - - - _ ... - - - - - nCountyof: 0.. ,t- •.tlR Name of Server: V(1• �. 2C Y1t n�c .undersigned,being duly sworn,deposes and says that at the time of services of legal age and was not a to this action: L t WAY rr--�� Date/Time of Service: that on the day of .20 ,at •C.clock ..M Place of Service: at 13491x.Trindle Road , in Carlisle.PA 17013 Documents Served: the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property w/Order Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Tbrisa A.Pyke,by posting Person Served,and Method of Service: .— By personally delivering them into th ands of the person to be served. By delivering them into the hands of a person of suitable age,who verified,or who upon ue i % g po q st �g stated,that he/she resides with Tbrisa A.Pyke,by posting at the place of service.and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex : Skin Color_ : Hair Color ; Facial Hair Approx.Age : Approx.Height ; Approx.Weight To the best of my knowledge and belief,said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury and s to b fore 7 it • tha goin: is rrect. 'r .'ypf iii► _ ..14a• .. I .t • At111iI ail Signs Sc., (Commission • pins) -1 International,Ltd. COMMONWEAL • PEN VA NIA Notate seal N.ale GWton,Notary Public Carlisiewomeien- Canty MEMBER,PEN PENNSYLVANIA 11O CR 16 %Ct%54 1E11%% UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CUMBERLAND County JARED A PYKE, MORTGAGE FORECLOSURE THRISA A PYKE, Defendant(s) NO. 107269 VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: JARED A PYKE 1349 W. TRINDLE ROAD, CARLISLE,PA 17013 THRISA A PYKE 3710 N. 4TH STREET,HARRISBURG, PA 17110 DATE MAILED: September 24,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: Oci.ZcA ,2013 UDREN L• •FFICES,P.C. BY: At omey for Plaintiff MJU#: 10070759 CASE#: 10070759-2 SALVATORE CAROLLO, ESQUIRE C PA ID 311050 rn rn C"? [ r- Cam ' — -rr _pt's IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank,National Association rri_ Plaintiff zm n"+ S V. U)L- Jared A Pyke; NO. 107269 ° c)r. Thrisa A Pyke v a _-= 2rq Defendant(s) z .. _{ ..r -: -''LL ORDER AND NOW,this ab'�day of 2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Jared A Pyke,Thrisa A Pyke,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 1349W TRINDLE ROAD CARLISLE,PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: JARED A PYKE 1349 W.TRINDLE ROAD CARLISLE,PA 17013 THRISA A PYKE 3710 N 4TH STREET HARRISBURG,PA 17110 BY THE COURT: J. C 0 EP Y i i ... - w i t' .xi =88* F 33 311 • • . 1-i 1 i m , . . 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ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. JARED A PYKE; NO. 107269 THRISA A PYKE; et al Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: 0. L.-1•13 UDREN LAW OFFICES,P.C. BY: A orney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 J i cn .�2 C) N) N { ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION N PNC Bank,National Association 13= Z.74 rrt CD V) ,.. Plaintiff z= - -a ter:-. Jared A Pyke; NO. 107269 r—= --!c Thrisa A Pyke vc; c, fir, Defendant(s) 3"3": ORDER AND NOW,this 20411tay of91•4€0161ETZ.2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Jared A Pyke,Thrisa A Pyke,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 1349W TRINDLE ROAD CARLISLE,PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: JARED A PYKE 1349 W.TRINDLE ROAD CARLISLE,PA 17013 THRISA A PYKE 3710 N 4TH STREET HARRISBURG,PA 17110 BY THE COURT: jeat? L' _ J. c ® pv . Service of Process by PNC Dank,National Association.et.al..Plaintiff(s) v��ner; APS International, Ltd. vs. Jared A.Pyke.et.al.,Defendants) 0 1-800-328-7171 nr5 tNTEAaTtoNnL APS International Plaza 7800 Glenroy Rd. Minneapolis,NIX 55439-3122 APS File l: 125501-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: UDREN LAW OFFICES --Thrisa A.Pyke,by posting Court Case No.Cumberland Co 107269 Ms.Henni Crommarty I 1 1 Woodcrest Rd.,Ste.200 Cherry Hill.NJ 08003-3620 State of: tl<Cll*e, ss. County of: - La, rt�� ._. C�� Name of Server: � C (\• <. RCN Y-11 . undersigned, being duly sworn,deposes and says that at the time of service. s/I Was of legal age and was not a party to this action: Date/Time of Service: that on the day of 20 at 4 'clock M Place of Service: at 1349 W.Trindte Road . in Carlisle.PA 17013 Documents Served: the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property WI Order Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Thrisa A.Pyke,by posting Person Served,and Method of Service: By personally delivering them into th ands of the person to be served. By delivering them into the hands of , , a person of suitable age, who verified,or who upon questi.4 g stated. that he/she resides with Thrisa A. Pyke,by posting at the place of service. and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex : Skin Color : Hair Color ; Facial Hair Approx. Age ; Approx. Height Approx. Weight To the best of my knowledge and belief. said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury . . •e'� and sN'•., to b-fore m= th ilia •regoin is t orrect. of ( 0 k (AV iy I ..�.+i��y •. Signa Se .\ tbli l (Commission�:xpires) S International,Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary public Carlisle Boro,Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES All r r • Service of Process by , PNC flank,National Association,et.al.,Plaintiff(s) N APS International, Ltd. vs. /,`41ACi1j0 Jared A.Pyke,et.al..Defendant(s) 1 " .T _\__ 1-800-328-7171 ,' APS 1NTRRMhb0NAL APS International Plaza 7800 Gtenroy Rd. T/ Minneapolis,MN 55439-3122 APS File#: 125501-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: IJDREN LAW OFFICES --Jared A.Pyke, by posting Ms.Henni Crommarty Court Case No.Cumberland Co 107269 111 Woodcrest Rd.,Ste.200 Cherry Hill.NJ 08003-3620 State of: - - ra ` �. 1 _ S. - - - - - - - _ County of: , . ,ate /fa• ._m• Name of Server: VTha< l Z . t_ 11 Acre ( . undersigned. being duly sworn,deposes and says that at the time o service. s/he wtf legal age and was not a party to this action: (r > A_ , a "k. . ' `.. Date/Time of Service: that on the � day of 20 , . at clock M Place of Service: at 1349 W.Trindle Road • 111 Carlisle,PA 17013 Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property w/Order Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Jared A. Pyke, by posting Person Served,and Method of Service: — By personally delivering them into the hands of the person to be served. By delivering them into the hands of MFs,-?A , a person of suitable age, who verified,or who upon question stated,that he/she resides with Jared A. Pyke,by posting at the place of service.and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex : Skin Color : Hair Color : Facial Hair Approx. Age : Approx. Height : Approx. Weight _ To the best of my knowledge and belief. said person was not __,gaged in the US Military at the time of service. Signature of Server: Una- 'I -. declares under penalty of perjury iub cr r . and s rn to before 14- that the forego', g is,true an et. ,, of gp, ;,,a_ 0 y ll1i..:um...4.i Si! --- eofS•. ,..iiio b . t��� (Co ssi4, Expires) • 'S International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Bon),Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ! oi 11 in tyre Jody S Smith t Chief Deputy , ti ,' 2 Richard W Stewart - , °�� Solicitor OFFICE OF THE SHERIFF E c+1 L.14{^) PNC Bank National Association vs. Case Number Jared A. Pyke (et al.) 2010-7269 SHERIFF'S RETURN OF SERVICE 06/28/2013 03:07 PM - Deputy Jason Kinsler, 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 1349 W. Trindle Road, Monroe Township, Carlisle, PA 17013, Cumberland County. 08/28/2013 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013 11/06/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, PA on November 06, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Federal Home Loan Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,020.66 SO ANSWERS, December 10, 2013 RONNY R ANDERSON, SHERIFF • LLf,ol- 306ys'S !c;Coun!ySuite Sheriff:Telecwft,Inc. UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin!s(a)udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County Jared A Pyke Thrisa A Pyke MORTGAGE FORECLOSURE Defendant(s) NO. 107269 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: 1349W Trindle Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 • Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 2. Name and address of Defendant(s) in the judgment: Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders -None Mortgage Electronic Registration Systems, Inc. PO Box 2026 Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -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: Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 171284230 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 1349W Trindle Road Carlisle, PA 17013 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: Federal Tax Lien Holders -None Condo/Homeowners Association-None 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 unswom falsification to authorities. DATED: <11 113 U r • - ES, P.C. B . , orney for Plain*- MJU#: 10070759 CASE#: 10070759-2 David Neeren, Esquire PA ID 204252 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 JARED A PYKE, THRISA A PYKE MORTGAGE FORECLOSURE Defendant(s) NO. 107269 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jared A Pyke 1349 W. Trindle Road Carlisle, PA 17013 Your house(real estate) at 1349W Trindle Road, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on September 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$152,726.53, 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 Sheriffs 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 fmd 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 Sheriffs 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 fmd 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A NAIL IN THE CENTER OF THE TRINDLE ROAD; THENCE BY LAND NOW OR FORMERLY OF ROBERT KOSER AND LAND NOW OR FORMERLY OF RICKY HAIR, SOUTH 27 DEGREES 4 MINUTES EAST 462.57 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CLARENCE HAIR, SOUTH 82 DEGREES 52 MINUTES 10 SECONDS WEST 100 FEET TO AN IRON PIN; THENCE BY THE DIVIDING LINE BETWEEN LOTS NOS. 1 AND 2 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, NORTH 27 DEGREES 4 MINUTES WEST 462.57 FEET TO A NAIL IN THE CENTER OF THE TRINDLE ROAD; THENCE BY THE CENTER OF SAID ROAD, NORTH 82 DEGREES 52 MINUTES 10 SECONDS EAST 100 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 2 ON THE SUBDIVISION PLAN OF LOTS OF IRVIN F. HURLEY AND MILDRED B. HURLEY, HIS WIFE, AS RECORDED IN PLAN BOOK 41, PAGE 131. AS DESCRIBED IN MORTGAGE BOOK 1884 PAGE 582 BEING KNOWN AS: 1349W TRINDLE ROAD, CARLISLE, PA 17013 PROPERTY ID NO.: 22-24-0771-014A TITLE TO SAID PREMISES IS VESTED IN JARED A. PYKE AND TRISHA A. PYKE, HUSBAND AND WIFE BY DEED FROM KENNETH L. HURLEY AND DEBORAH A. HURLEY,HUSBAND AND WIFE DATED 09/30/2004 RECORDED 10/12/2004 IN DEED BOOK 265 PAGE 3481. • • UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 .leadin s(udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County JARED A PYKE, THRISA A PYKE MORTGAGE FORECLOSURE Defendant(s) NO. 107269 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Thrisa A Pyke 1211 N 16th Street Harrisburg, PA 17103 Your house(real estate) at 1349W Trindle Road, Carlisle,PA 17013 is scheduled to be sold at. the Sheriffs Sale on September 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$152,726.53, 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 Sheriffs 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 Sheriffs 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 • ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A NAIL IN THE CENTER OF THE TRINDLE ROAD; THENCE BY LAND NOW OR FORMERLY OF ROBERT KOSER AND LAND NOW OR FORMERLY OF RICKY HAIR, SOUTH 27 DEGREES 4 MINUTES EAST 462.57 FEET TO AN IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CLARENCE HAIR, SOUTH 82 DEGREES 52 MINUTES 10 SECONDS WEST 100 FEET TO AN IRON PIN; THENCE BY THE DIVIDING LINE BETWEEN LOTS NOS. 1 AND 2 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, NORTH 27 DEGREES 4 MINUTES WEST 462.57 FEET TO A NAIL IN THE CENTER OF THE TRINDLE ROAD; THENCE BY THE CENTER OF SAID ROAD, NORTH 82 DEGREES 52 MINUTES 10 SECONDS EAST 100 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 2 ON THE SUBDIVISION PLAN OF LOTS OF IRVIN F. HURLEY AND MILDRED B. HURLEY, HIS WIFE, AS RECORDED IN PLAN BOOK 41, PAGE 131. AS DESCRIBED IN MORTGAGE BOOK 1884 PAGE 582 BEING KNOWN AS: 1349W TRINDLE ROAD, CARLISLE, PA 17013 PROPERTY ID NO.: 22-24-0771-014A TITLE TO SAID PREMISES IS VESTED IN JARED A. PYKE AND TRISHA A. PYKE, HUSBAND AND WIFE BY DEED FROM KENNETH L. HURLEY AND DEBORAH A. HURLEY,HUSBAND AND WIFE DATED 09/30/2004 RECORDED 10/12/2004 IN DEED BOOK 265 PAGE 3481. • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-7269 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 JARED A.PYKE,THRISA A.PYKE (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 garnishees)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: $152,726.53 L.L.:$.50 Interest FROM 4/26/13 TO DATE OF SALE SEPTEMBER 4,2013-ONGOING PER DIEM OF $21.38 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -4Ir a, $aa• 1 4 Atty's Comm: Due Prothy:$2.25 Atty Paid:$207.40 Other Costs: Plaintiff Paid: Date:5/8/13 M •AIV David a Eg,Prothonotary (Seal). By: Deputy REQUESTING PARTY: Name:DAVID NEEREN,ESQUIRE Address:UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No.204252 4 LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2010-7269 Civil Term PNC BANK NATIONAL ASSOCIATION vs. JARED A. PYKE,Trisha A.Pyke Atty.: Mark Udren ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a nail in the center of the Trindle Road; thence by land now or formerly of Robert Koser and land now or formerly of Ricky Hair, South 27 degrees 4 minutes East 462.57 feet to an iron pin; thence by land now or formerly of Clarence Hair, South 82 degrees 52 minutes 10 seconds West 100 feet to an iron pin;thence by the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots, North 27 degrees 4 minutes West 462.57 feet to a nail in the center of the Trindle Road;thence by the cen- ter of said road,North 82 degrees 52 minutes 10 seconds East 100 feet to the place of BEGINNING. BEING Lot No.2 on the subdivi- sion plan of lots of Irvin F. Hurley and Mildred B. Hurley, his wife, as recorded in Plan Book 41,Page 131. AS described in Mortgage Book 1884 Page 582. BEING known as: 1349W Trindle Road, Carlisle,PA 17013. PROPERTY ID NO.: 22-24-0771- 014A. TITLE TO SAID PREMISES IS VESTED IN Jared A.Pyke and Trisha A. Pyke, husband and wife by deed from Kenneth L.Hurley and Deborah A. Hurley, husband and wife dated 09/30/2004 recorded 10/12/2004 in Deed Book 265 Page 3481. 84 i • PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 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. 1-- jr■r:—)(1(■ -1-- .^ sa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this day of August, 2013 C___ , 110.. ? � Notary N`TA HiAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COMFY My Commission Expires Apr 28,2014 The ESO * A'e a �10 �► � � Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller 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 1900 Patriot Drive, 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 he 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 he 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. This ad ran on the date(s)shown below: • 10-7269 CNN- IwI Tenn 07/28/13 BANK NATI ASSOCIATION 08/04/13 . JARED A.PYKE 08/11/13 Trisha A.Pyke • Atty: Mark Udren ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY,r Sworn to and ubscri led be ore me th'. 23 say of August, 2013 A.D. PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: , BEGINNING AT.A NAIL IN THE AA �. ! ' • ' • ,' , CENTER OF THE TRINDLE ROAD; i otary •ublic THENCE BY_ LAND NOW OR FORMERLY OF ROBERT KOSER AND LAND NOW OR FORMERLY OF RICKY HAIR,SOUTH 27 DEGREES 4 MINUTES EAST 462.57 FEET TO AN IRON PIN; THENCE BY LAND NOW I:i A1MONWEAt.T 1 OF Pwmi`dNSYLVANIA OR FORMERLY OF CLARENCE HAIR, Notarial Seal SOUTH 82 DEGREES 52 MINUTES Holly Lynn Warfel,Notary Public 10 SECONDS WEST 100 FEET TO AN Washington Tvup.,Dauphin County IRON PIN;THE ' DIVIDING My Commission Expires Dec.12,2016 LINE BETWEEN LOTS NOS.1 AND 2 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES „ON THE HEREINAFTER MENTIONED PLAN OF LOTS,NORTH 27 DEGREES 4 .....r v..rn..mom Ael[iCCCI•M A UATT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Home Loan Mortgage is the grantee the same having been sold to said grantee on the 6th day of November A.D., 2013, under and by virtue of a writ Execution issued on the 8th day of May, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7269, at the suit of PNC Bank,N.A. against Jared A. Pyke and Trisha A. Pyke is duly recorded as Instrument Number 201401092. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 1 day of Jan , A.D. O/ Recorder of Deed Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018