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Home My WebLink About11-0156iJDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiags~udrea.com PNC Bank, National Association :COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 c~ Plaintiff €Cumberland County G ~ ~ n Deana R. Gault 513 West Main Street ~ ~,! ~~ ~/ ~~,~ € NO ~ ( ! ~,:7 __ ~ -~~ ` - ~o ~~„>>-,,,..~ti,~,~,.~r..,, PA 17055 . ~ ~ c_:1 ~;~ ' " 0'*~ o McC,1'~icgbur Defendant (s ) ~ ~ : ~_; ~ q ~ ~'~ .. .-+1 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 SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A .LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ~~ ~~~Q~ c~~~s~~~ AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas s.iguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la cort.e 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 torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la torte 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 I1rIlrIEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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: 513 West Main Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 12/15/04 DATE RECORDED: 12/17/04 BOOK: 1891 PAGE;, 2934 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 i:n the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. E. The following amounts are due on the said Mortgage as of 1/5/11: Principal of debt due $88,114.68 Unpaid Interest at 6.125 from 8/1/10 to 1/5/11 (the per diem interest accruing on this debt is $14.79 and that sum should be added each day after :1/5/11) 2,307.90 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $29.17 and that sum should be added on the first of each month after 1/5/11) 375.01 Late Charges (monthly late charge of $302.18 should be added in accordance with the terms of the note after 1/5/11) 87.51 Attorneys Fees (anticipated and artual to 5~ of principal) 4,405.73 TOTAL $95,895.83 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 $95,895.83 plus interest, costs and attorneys fees as more fully set :forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UD BY At ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE SOUTH SIDE OF WEST MAIN STREET, IN THE BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDID AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POIlVT ON THE CURB LINE OF SAID WEST MAIN STREET AND AT CORNER OF LOT OF MYRA S. PROWELL; THENCF, ALONG THE LINE OF SAID LOT OF MYRA S. PROWELL SOUTHWARDLY 165.4 FEET, MORE OR LESS, TO A POIlVT AT CORNER OF LOT OF WALTER J. FISHER; THENCE ALONG THE LINE OF SAID LOT OF WALTER J. FISHER SOUTHWARDLY 132.6 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF 5IMPSON STREET; THENCE WESTWARDLY ALONG THE CENTER OF SAID SIMPSON STREET 40 FEET 2 INCHES, MORE OR LESS TO CORNER OF LOT FORMERLY OF HARRY B. MARKLEY, NOW OF CORA M. HIMMELRIGHT; THENCE ALONG THE LINE OF SAID LOT AND LOT OF MRS. LLOYD E. ENCK NORTHWARDLY 291.3 FEET, MORE OR LESS, TO A POINT ON THE CURB LINE OF SAID WEST MAIN STREET EASTWARDLY 41 FEET 2 INCHES, MORE OR LESS, TO A POINT ON SAID CURB LINE AND AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 513 WEST MAIN STREET, MECHANICSBURG, PENNSYLVANIA. EXCEPTING FROM THE ABOVE DESCRIBED PREMISES ALL THAT CERTAIN PARCEL OF LAND CONVEYED BY DEED RECORDED IN DEED BOOK 17-H, PAGE 412. THE ABOVE DESCRIBED PREMISES CONVEYED TOGETHER WITH AN EASEMENT FOR PURPOSES OF INGRESS, EGRESS AND REGRESS TO SAID TRACT AS MORE FULLY APPEARS AND RESERVED BY PIROR GRANTOR, HIS HEIRS AND ASSIGNS IN THE SAID DEED BOOK 17-H, PAGE 412 THE ABOVE DESCRIBED PREMISES BEING MORE PARTICULARLY DESCRIBED ON MAP OF PROPERTY OF BRUCE E. ANDERSON AND JANET A. ROSS, PREPARED BY JOHN C. BRILHART, SURVEYING AND MAPPING SERVICES DATED JUNE 29, 1983 AND RECORDED IN THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE IN DEED BOOK G-30, PAGE 633, AS FOLLOWS: ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE SOUGH SIDE OF WEST MAIN STREET, IN THE BOROUGH OF MECHANICSBURG, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE CURB LINE OF SAID WEST MAIN STREET, APPROXIMATELY 283 FEET WEST OF THE CENTERLINE OF SOUTH BROAD ~~~~ ~~ P.O. Box 1820 Dayton, Ohio 45401-1820 November 15, 2010 56626-0000094-001-001-000-000-000 GAULT,DEANA R 513 W MAIN ST MECHANICSBURG PA 17055-3244 ~iiMiii~ii~idiw~ii~iiiMiii~ PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937j 910-1200 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 EXHIBIT A DATA: November 15, 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 fHEMAP) ,may be able to held to save your home This Notice explains how the grogram wnrkc, 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 n ember of on Amer redit rnmS ~ling~,gen~iPC ~P,-v,~g y~»*- onnty are listed at the end of this Notice. 1f vouh_avP an,f uestion~ ~ may call the Pennsvly n~ unucino Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717} 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI(JN OBTENGA UNA TRADUCCION INIVIEDIATAMENTE LLAMA:~iDO ESTA AGENCIA (PENNSYLVAI~TIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA. UN PRESTAMO POR EL PROGRAM. A. 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): GAtTLT,DEANA R PROPERTY ADDRESS: X13 W MAIN ST LOAN ACCT. NO.: 0003350112 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 FBOM FORF_.CL.OS TRF. ND H .P YO AKF FTTTTTRF MfIRTC:AC`T: T~evn~r~.TTc 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 YUUR CONTROL, • IF YUU HAVE A REASONABLE PROSPECT OF BEING ABLE TU PAY' YUUR MURTGA(:E PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from. the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'lneeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING 1VIU T O IR WITHIN ('i ).DAYS OF F RAT OF THI NOT C'F 1F Y DO NOT APPLY FOR FMF.RGF.N(' MORT ; A IST N YO 1 T B iNC' YO JR MnRTC'TAGF PTO DATE. THE .PART OF THIS NOTI i i .D "HOW TO C R YO R MORT A D FA T"_ F_.~pLA.IN HOW TO BRiNCT YOiTR MnRTrar,F Tm Tfl neT~ 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 addre e ~ and telenhonenumbers of designated consumer c,Tedit c un eling,~g „~;P~ fnr rhP county in which the gropertv is locatedare set forth at the end ofth~s Notice, It is only necessaryto schedule on. eface-to-face meeting. Advise your lenderimmediatelvofyouc intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner'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 he 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 YOL' HA6~' A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHl~' 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOT'E, IN THE SECTIONCALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVE1V BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTIOA; BUT IF YOUR APPLICATION IS EVE.~VTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, .THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act.. The Pennsylvania Housing Finance Agencyhas sixty (60) days to make a decisionafter itreceives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date. NATURB OF THS DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 513 W MAIN ST MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) September O1, 2010 to November O1, 2010 and the following amount(s) are now past due: Monthly Payments 2,656.47 Corporate Fees 0.00 Late Charges 58.34 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 10.50 Speedpay Fees .00 Less Suspense Balance .00 Total Amount Past Due $2,725.31 HOW TO CURS THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THS TOTAL AMOUNT PAST DUS TO THE LENDER, PIFi2CIi IS $2,725.31, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments m~ b mad ei her by ca h~er's ch k ce i 'ed check ca h 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 tr Yuu llL) NUT CURT THE DEFAiiL 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 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 attomeys to start legal action to foreclose unon your mort,~aQpd ro e IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriffto pay off the mortgage debt. If the ].ender 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 $SU.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you. personally for the unpaid. principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the_ THIRTY (30) DAY period and foreclosure proceedings have begun, you _still have the right to cure the tiefa„it ~nmmg any or_ner requirements under the mortgaee. Curing your default in the manner set forth in 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 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. Miamisburg, OH 45432 Phone Number: 1-800-523-8654 Fax Number: 937-910-4009 on ac erson: o ec ons en r - a~ ress: oss. ga ion a pncmo gage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your ng t to occupy it If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not X (CHECK ONE) sell or transfer your home to a buyer or trans eree who wi 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 requirement`s of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF 'CHE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TU HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO TH.E SAME POSITION A.S 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 CALE'sNDAR 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 LA'W. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY V E R I F I CAT I 0 ITT I, the undersigned, am attorney for the Plaintiff and am 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. UDR BY: Att UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BR.AUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - 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 pleadingsCDudren.com PNC Bank, National Association 'COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 :Cumberland County Plaintiff n c N o ° . ~"~' ~ ~~ ~ -~ ~ °® ~ ~ -vr 'cam r- _ ____ A~ ~? rn 'i ~ c o D ~ ~ v . NO . ~O t ~ -' ~ lY ~l ~ I ~f ~' Deana R. Gault 513 West Main Street PA 17055 Mocha»icsb~rq Defendant (s ) ENTRY OF APPEARANCE TO THE PROTHONOTARY: 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. Kayos, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire and Jerome B. Blank, Esquire on behalf of the Plaintiff, PNC Bank, National Association in the above-captioned matter. UDREN LAW OFFICE~,~ BY: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriffs .7j T` Jody S Smith j o.sJ; ?} 4 Chief Deputy t'. 19 Richard W Stewart Solicitor R.tie ,.xa. PNC Bank National Association Case Number vs. Deana R. Gault 2011-156 SHERIFF'S RETURN OF SERVICE 01/12/2011 01:33 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2011 at 1333 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Deana R. Gault, by making known unto herself personally, at 513 W. Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. HA SHALL, D SHERIFF COST: $37.00 January 13, 2011 SO ANSWERS, 4" RON R ANDERSON, SHERIFF