Loading...
HomeMy WebLinkAbout11-2027k ` f 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 c) PNC Bank, National Association Cn :COURT OF COMMON PLEAS - -n --? 3232 Newmark Drive :CIVIL DIVISION _ Miamisburg, OH 45342 Plaintiff € Cumberland County N? -- 70 C:) , V. tea ,. Q-" Nichole D. Simmons I 'a? ? C? YI c-? 7e,194 Z °rn 125 Herman Avenue NO. . Lemoyne, PA 17043 "" 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 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 (3> , pa a?e a? t3400. g04 120 265 9" AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace 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 demanders en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 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: 125 Herman Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Lemoyne Borough COUNTY: Cumberland DATE EXECUTED: 11/22/2004 DATE RECORDED: 11/24/2004 BOOK: 1889 PAGE: 293 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, 1 ! 6. 2/11/11: indicated below. The following amounts are due on the said Mortgage as of Principal of debt due $81,335.29 Unpaid Interest at 3.0%* from 9/1/10 to 2/11/11 (the per diem interest accruing on this debt is $6.69 and that sum should be added each day after 2/11/11) 1,185.22 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $198.99 and that sum should be added on the first of each month after 2/11/11) (81.98) Late Charges (monthly late charge of $19.70 should be added in accordance with the terms of the note after 2/11/11) 101.83 Pro Rata MIP/PMI 117.94 Attorneys Fees (anticipated and actual to 5% of principal) 4,066.76 TOTAL $87,330.06 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 L.. 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 $87,330.06 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, V.C. BY: z-- L Attorney r P n PA y,-,? 02-16-'11 15:36 FROM- SCBEDVLZ A Feb 17 2011 04:40am P009/012 T-203 P0009/0012 F-507 AM SAT CERTAIV lot of ground situate in Lamoyne Borough, Cumberland County, Pennsylvania, bounded and described aaooardinq to survey by Michael C. D'Angolo, Registered Surv*yor, by survey dated may 5F 1977, as follows: BZGXNKING at a point an the northern line of Seaman Avenue (80 feet wide) at the dividing line between proportion Was. 121 and 125 Berman Avenue which said beginning point is located 180.00 feet measured southwestwaardly along the northern line of Norman Avenue from the western line of First Street'.; thence from said beginning point by the northern lime off' Borman Avenue south 54 degrees 00 minutes West 17.50 feat to a nail; thence by the dividing liao between properties Nos. 125 and 127 Norman Avenue and through the osnter line of the partition wall between the doable dwelling houses located on the lot herein conveyed and the lot adjoining on the west, North 36 degrees 00 minutes West 150.00 feet to at pia; thence by the southern line of Peach Alley (15 feet Vida) North 54 degrees Q0 minutes East 17.50 feet to a pin; thence by tho dividing lies between proportion Mos. 121 and 125 Berman Avenue South 36 degrees 00 minutes EmAt 150.00 feet to the place of WGXHH2VG. BEING improved with the eastern one-half of a< two and ono-half story double dwelling house being knower and numbered as 125 Berman Avenue, Lemoyne, Pennsylvania. BEING Lot No. 1 acs shaven on the Final Subdivision Flan of Lot No. 39, Section R, Plan No. 1 of Riverton as recorded in Cumbearl&Z4 County Deed Book 4-J, page 40, said Subdivision Plan for Olive G. Lambert being dated May 5, 1977 and recorded in Plan' Beak 31, pugs 44 Cumberland County records. I Cer.ify this to be recorded In C. utilballand County PA v Recorder of Deeds W1094031019 PNC AtIC AGES P.O. Box 1820 Dayton, Ohio 45401-1820 December 15, 2010 57565-0000004-001-001-000-000-000 SIMMONS,NICHOLE D 125 HERMAN AVE LEMOYNE PA 17043-1936 7107 8381 6540 2117 6948 Mailing Address: P.O. Box 1820 Dayton, Ohio 45401-1820 Certified Nlail/Return Receipt Requested RE: Loan No. 0003323413 Aviso importante para personas de habla Hispana. Si no entiende esta notificacion, contacte su abogado immediatamente. PNC Mortgage acknowledges that you are discharged of your debts in a Chapter 7 Bankruptcy and have not reaffirmed your obligations to pay under the terms of the original Note you executed or assumed. Under the terms of your secured mortgage, we are required to provide the enclosed notification. Therefore, we disclaim and assume no liability under the conditions and terms of 11USC 524 concerning the discharge of your debt. If you have questions about your rights, please call the attorney who handled your case. Sincerely, Collections Center Enclosure ?,? ? 1- 7 A 746-M22-11009F PNC Mortgage 3232 Newmark Drive Miamisburg, Ohio 45342 Telephone: (937) 910-1200 DATE: December 1 5, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP} may be able to help to save your home, This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any Questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): SIMMONS,NICHOLE D PROPERTY ADDRESS: 125 HERMAN AVE LOAN ACCT. NO.: 0003323413 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 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face'meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR. MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telenhonenumbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessaryto schedule one face-to-face meeting. Advise your lenderimmgdiatelyof your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Ilomeowner'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 HAFT A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROMSTARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED "TEMPORARY, STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTIOA, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'SSALE, THE FORECLOSURE WILL BE STOPPED. J AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application.. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency ;Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 125 HERMAN AVE LEYMOYNE, PA 17043 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) October 01, 2010 to December 01, 2010 and the following amount(s) are now past due: Monthly Payments 1,842.27 Corporate Fees 0.00 Late Charges 61.37 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 19.50 Speedpay Fees .00 Less Suspense Balance .00 Total Amount Past Due $1,923.14 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 $1,923.14, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash 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 DR670 ..0 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default: within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediatelyand you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged ro e IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquencybefore the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey'sfees will be added to the amount you owe the lender, which may also include other reasonable costs. If you _ cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due. plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately nine - ten months from the date of this Notice. A notice of the actual date of the 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: 937-9104009 Contact Person: Collections Center E-Mail Address: oss. i gation a,pnemortgage.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may, not X (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. - f r • 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 - ! . r V E R I F I C A T I O N 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. falsification to authorities. Section 4904 relating to unsworn 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. BRAUNSTEIN, 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 pleadings@udren.com PNC Bank, National Association =COURT OF COMMON PLEAS 3232 Newmark Drive =CIVIL DIVISION Miamisburg, OH 45342 =Cumberland County Plaintiff 4 co Z p-yrt v. NO. fi- Nichole D. Simmons 125 Herman Avenue Lemoyne, PA 17043 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: 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 Bank, National Association in the above-captioned matter. UDR BY: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ???,?a,Sr ai Luiul,crl•r?l? PEW P §R? -- P NC Bank National Association vs. Nichole D. Simmons Case Number 2011-2027 SHERIFF'S RETURN OF SERVICE 02/22/2011 07:15 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2010 at 1915 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Nichole D. Simmons, by making known unto herself personally, at 125 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $42.40 February 23, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 PNC Bank, National Association :COURT OF COMMON PLEAS 3232 Newmark Drive :CIVIL DIVISION Miamisburg, OH 45342 :Cumberland County Plaintiff V. ::NO. 11-2027-Civil Nichole D. Simmons 125 Herman Avenue Lemoyne, PA 17043 Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: 5. C-- :..., _ r: ?u Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. r Plaintiff DATED: May 18, 2012 A{MY GLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 11020484-1