HomeMy WebLinkAbout11-3494UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
HEATHER RILOFF, ESQUIRE - ID #309906
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadin2s6d?udren.com
PNC Bank, National Association
CARE OF 3232 Newmark Drive
Miamisburg, OH 45342
Plaintiff
V.
LISA GOODRICH
PO BOX 747
MECHANICSBURG, PA 17055
ROBERT S. GOODRICH
PO BOX 747
MECHANICSBURG, PA 17055
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
NO. 11 .?1111(!? 4 Cl \A 1
COMPLAINT IN MORTGAGE FORECLOSURE
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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.
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ATTORNEY FOR PLAINTIFF
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
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 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 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 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 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 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 Mortgage, 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:
Assignee:
Date of Assignment:
Recorded Date:
Book/Instrument #:
Page:
2. Upon information and belief Defendant(s):
Robert S. Goodrich and Lisa Goodrich
(hereinafter "Defendants"), are the owners of property located at 1595 West Lisburn
Road, (Monroe Township), Mechanicsburg, PA 17055, by virtue of Deed dated
12/14/2007 and recorded 12/14/2007 in Official Records Book Instrument #200746369
at Page n/a of the Public Records of Cumberland County, Pennsylvania (hereinafter
the "Property").
3. On 12/14/2007, Defendant(s):
ROBERT S. GOODRICH AND LISA GOODRICH
promised to pay to the order of National City Mortgage a Division of National
City Bank, the principal sum of $335,000.00 payable with interest thereon
provided in the Note.
4. By Mortgage dated 12/14/2007, Defendant(s):
ROBERT S. GOODRICH AND LISA GOODRICH
to secure the Note, mortgaged to National City Mortgage a Division of National
City Bank, the Property which is the subject of this action. The Mortgage was
recorded on 12/14/2007 in Official Records Book Instrument #200746370 at Page
N/A. Said Mortgage is incorporated herein by referenced in accordance with
Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto
and made a part hereof.
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6.
Said mortgage is in default in that the payment due 08/01/2010, 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 other charges
authorized by said Mortgage and itemized below, shall be immediately due.
After demand, the Defendant(s) continues to fail or refused 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.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $324,707.49
Accumulated interest $14,919.46
Accumulated Late Charges $928,17
Escrow Deficit/(Reserve) $3,787.78
Title Report $325.00
Court Costs- Estimated $300.00
Attorney Fees- Estimated $1,300.00
Pro Rata MIP/PMI $145.17
Grand Total
$346,413.07
The above figures are calculated as of 03/26/2011:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 6.25000 %. The per diem interest accruing
on this debt is $55.60 and that sum should be added each day after the above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $103.13.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the
subject mortgage, The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and
the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983.
Copies of the breach letters are attached hereto as Exhibit "A".
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $346,413.07 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, C.
BY:
Daniel S. Siedman, Esquire
PA ID 306534
ALL THAT CERTAIN TRACT OR PARCEL OF LAND WITH THE IMPROVEMENTS
THEREON ERECTED, SITUATE IN MONROE TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN IRON PIN ON THE SOUTHERN LINE OF LISBURN ROAD AT
THE CORNER OF PROPERTY NOW OR FORMERLY OF GEORGE EBENER, AS
SHOWN ON THE PLAN OF ALLEN PARK, WHICH PLAN IS RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY IN PLAN
BOOK 22, PAGE 83; THENCE ALONG THE SOUTHERN LINE OF LISBURN ROAD,
SOUTH 65 DEGREES 31 MINUTES 15 SECONDS EAST TWO HUNDRED FIVE AND
TWENTY-SIX ONE-HUNDREDTHS (205.26) FEET TO A POINT; THENCE ALONG
LAND NOW OR LATE OF SKIRO, INC. (LOT 8 ON SAID PLAN), SOUTH 24
DEGREES 28 MINUTES 45 SECONDS WEST, ONE HUNDRED FIFTY AND ELEVEN
ONE-HUNDREDTHS (150.11) FEET TO A POINT; THENCE ALONG THE SAME,
SOUTH 65 DEGREES 31 MINUTES 15 SECONDS EAST, THIRTY AND EIGHT ONE-
HUNDREDTHS (30.08) FEET TO A POINT; THENCE CONTINUING ALONG LANDS
NOW OR LATE OF SKIRO, INC., SOUTH 26 DEGREES 35 MINUTES WEST, FIVE
HUNDRED AND ZERO ONE-HUNDREDTHS (500.00) FEET TO A POINT AT LINE
NOW OR FORMERLY OF WILLIAM E. LEIB; THENCE ALONG THE LATTER,
NORTH 63 DEGREES 25 MINUTES WEST, THREE HUNDRED TWENTY-NINE AND
THIRTY-EIGHT ONE-HUNDREDTHS (329.38) FEET TO A PONT AT LINE OF
LANDS, NOW OR LATE OF GEORGE EBENER; THENCE ALONG THE LATTER,
NORTH 34 DEGREES 27 MINUTES 20 SECONDS EAST, SIX HUNDRED FORTY-
SEVEN AND FORTY-EIGHT ONE-HUNDREDTHS (647.48) FEET TO AN IRON PIN,
THE PLACE OF BEGINNING.
CONTAINING 4.108 ACRES.
BEING IMPROVED BY A TWO AND ONE-HALF STORY BRICK DWELLING AND A
WAGON SHED CURRENTLY USED AS A FOUR CAR GARAGE KNOWN AND
NUMBERED AS 1595 WEST LISBURN ROAD, MECHANICSBURG, PENNSYLVANIA
17055.
BEING THE NORTHEASTERN AND GREATER PORTION OF LOT NO. 9 AS
SHOWN ON THE PLAN OF LOTS OF ALLEN PARK, WHICH PLAN IS RECORDED
IN CUMBERLAND COUNTY PLAN BOOK 22, PAGE 83.
UNDER AND SUBJECT, NEVERTHELESS, TO EASEMENTS, RESTRICTIONS,
RESERVATIONS, CONDITIONS AND RIGHTS OF WAY OF RECORD.
AS DESCRIBED IN MORTGAGE INSTRUMENT NO. 200746370
7107 8381 6540 2115 6292
PNC Mamie
3232 Ntewmwk Orbm
MWmlobwg, OW45342
Tskiphco 4W7`9 9 ter-12DO
Mow* Addeu":
Roson ISM
Do"o n. Ohio 46401-1
EXHIBIT A
DATE: October 15, -V 10
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an eflicIal node that the mortimee on your home is In debulht.. and tie lender intends to
t
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EMAP
AGENCY VMMIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with u
when you meet with the ouuseli
The name- add=s and nhnne n •m .r of Werner Czedit CounMling, ge?i? ser?,:nff yn Yr grnt?r
arr fisted at he end of hip Notice- lfy you have n; gWsfiQrrc j= U Call flee Pemajvnnia Hougin
Finance A tall free at 1-SW342- 397. errm with im ired hearing can call 71?` 780-1869 .
This Notice contains Important legal information. If you have soy 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 aide to help you find a lawyer.
LA NOTIFICACION EN A.DJUNTO EE*, DE SUM IMPORTANCIA, PLIES AFWT'A SU IDERECBO
A CONTINUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CONTENIDO DE EST'A?
NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAIr+IANDO ESTA
AGENCIA (PENNSYLVANIA HOUSLNG FINANCE AGENCY) SEN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELi G'IBLE PARA UN PRkSTAMO POR EL PROGRAMA
LL.AMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL
PUEDE SALVBAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMIR SU MFOTECA.
HOMEOWNER'S NAME(S)GOOOItICI-I ROBERT 5
GOODIR:IC KLISA
PROPERTY ADDRESS. 1595 W LISBURN RD
LOAN ACCT. NO.: 00059913"
ORIGINAL LENDER: &,A
C't MRENT LENDERSERVICER., PNC
HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
E&W r
IF YOU COMPLY WITH TINE PRONIMONS OF THE HOME OWNER'S EMERGENO' MORTGAGE ASSISTANU
ACT OF 1983 (I'HE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASKANCE:
• IF YOUR DEFAULT WAS BEEN CAUSED BY CIRCUf4LSTANCES BEYOND YOUR CONTROL.
If YOU HAVE A REASONABLE: PROSPECT OF RE LNG ABLE TO PAY YOUR MORTGAGE FA'la' NIE: AND
IF YOU MEET OTHER ELIGIBILITY REQtIIR.EME ESTABLISHED BY THE PENNSYL ANtA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF F[1lRECLOSUM y- Linder the Art, you are entidod to a ternpaatary stay of fc redos
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing).
arrange and attend a "farce-to-face'iueting with one of the c r credit m wlin agencies- listed at the end of this
Notice TTI S MEET1NG_MUST OCCUR WITHIN M*41 DAY!. OF THEIR t1ATF OF TMt WnTlt''i' 11; Will tvi
CONSUMER, CR1ED?T COI?NSELItVG AGGNCIES - if you mith we of the a`a?nauruczt arauingaatgeaes
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days alter the date of this
meeting.
It is only a>ecessaryto schedule one Ito-face meetiing.
Advisr your lendrdMM=djAW&ofynur intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your xnartgage as in derault filar tine reasons set forth later in this
Notice (see fallowing pages for ific information about the nature of your default.) You have the right to apply for
financial assistance frran the 11-canto wner'$E c cno-yMo tpSe Assistance T erm. To do sir, youinust fill Out, giSn and
file a completed Homemmer'sEnwrgency AssiL a Program Application with one of the designated consumer credit
counseling agencies listx at the said of this Notice. Only oonsur r credit cotrnselin agencies I se applications for the
program and they will mist you in submitting a complete application to the Pennsylvania housing Finan a Agency. To
tempuraxily stop the lender from filing as f)wclol a action. your application MUST be forwarded to P11FA and received
within thirty (30) days of your face-to-fiuae meeting with the counseling agency.
YOU SHOULD FILE A HEMAP .APPLICANON AS SWA' AS I SIRLIE IF YOU HAVE A M EIING 0179 A
COUNSF.LfAV AGENCY 977WAI 33 DAYS OF ME PfJS'f M.A U DA- TE OF IMS NOTICE a FILE AN APPLIC.AT IO
I41111II PffFA Il'I1"Jl N 0 DAYS OF T>FLaIT MiEEFINa THEN THE LENDER WILL BE TEMP0A4&rUY PIfEDEA'I
FROM STAJt7lfMrGA FDRECL W"AGAJA T YOURPWOPERIT, AS DINED AROVI '7 IV THE SEC7WNCALLED
"Tl±'MI'fJW YSTAYOFFOlR CUISVRE'P
MLI ffA!z THE Affaz Z2 FILE A A M E AP1°Lu U E't*TA 8L YM eF` mar ffduaU ,A LATE
APP0CATYht N WXL JVOr "BVENT ME LENDER P STAR17NG A FCiIt;WL URE ACTION. BUT IF YOUR
.AJ'PUCA7701 `IS Et'L'.VnIALLYAPPROVED T AArV 171'M BEFORE A SHERIFFISSALE, 7WE FO R'ECLf,EY,G'RE NUL
BE'S'9rOP ED.
AGENCY ACTION -- Available funds fvr emergency ni ge assistance are very limited... They Mll be
disbursed by the Agency under the eligibility criteria established by the Act+ The Fc ylvania Housing
.
Finance Agency has sixty (60) days to make a decision after it receives your application. Charing that time. no
c=losure ptooeadi s will be pumW against you if you have met the time regukanem ; set forth eve.
You will be nofifwd directly by the 1' cisylvania Housing Finance Agency of its decision on your ?+ appliicati+caa>
N : IF YOU ARE CUM ENTLY PROTECTED BY THE FILING Of A PETMON IN BANKRUPTCY.
THE FOLLOWING PART OF THi;I NOTICE IS FOR INFORMATION PVRPOSES ONLY AND SiHpMI)
NOT BE CONSIDERED AS AN ATTI:l4PT "I COLLECT THE DEBT.
(Ifykm have filed bankruptcy you caws still apply for rnerpncy MWrt a Assistance.)
SOW To = 2 YOUR MORTG"19 DEFAULT grin it a to date).
MATUIM O THE DEPiDLT -- The MORTGAGE debt held by the above lender on
your property located at:
:55f9+?W L1?URN RD
.
1S SERIOUSLY 1h ' BFAULI" because:
YOU HA?'E NOT KADE MONTHLY MORTGAUR PAYMENTS for the fol lowing month I s)
August 01. 2010 t8 October G1. oiu and the fallowing
am unt 1 s) are now past due
Monthly Paymente 8,015-25
Corpora-,c Fees 0.30
Late charges 309.39
Nom-Sufficient Funds ,00
Fax Fees .00
Property Inspection Fees 9.00
5redpay Fees 24.70
Less Suspense Balance .00
Tot.&I Amouet Past Due $8,357.64
NOW TO CURE THE DEFAULT - You may cure the default within thirty 0) days
of the date of this notice BY PATIM TSR TOTAL A3KRWT :PAST To THR
LMUM, WHICH IS $8,357_64, PLUS ANY MaRMAGE PAYt r.-, AND LATE CHMGF-S
WHICH BECOME DUE DURING THE THIRTY t301 DAY PERIOD*
Pavmant a must he made i th?p by raehi gar l a check i f i Rd rhec a gh
or "Onev order ma amble, and gent to:
PNC Mortgage
Collections Center
3232 Newmark Dr
MiAMi9burg{, ON 45432
Thivt ?fz an at-ttmpi? -n r:al sect a debt., Any information obtained will be
used for that purpose
Enclosure
DR6x2
IF YOU_DU_NOT CURE TBE DEFAM - If you do not cure the default within 714IR'T'Y (30) DAYS of the
date of this Notice, *e leader loweds to exerelse its riehts to accelerate the mortsraeae debt This moans that the
entire outstanding balance of this debt will be considered due im7mediatelyand you may loos the chwxx to the
mortgage in monthly installments, If full payment of the total amount past due is not mauls within THIR'l?(30)
[SAYS, the lender also intends to i stn ct its aftom s to start legal action to faredose
? rot.
OTHER LlEl"DE 1l=RW - The kmdcr may also sua you personally f0r the unpaid Oneipal balance d all
other sums due under the mortgage.
the
If you have not cured the default within
msiore your moripp to the same position as ifyow had never defaulted
manner soul forth In
EAMLIEST POSSIBLE SHERIFF'S SALE IRATE _- It is estimated than the earliest date that such a Sheriff's
Sad of the ortp?1 p k, cuu.ld be held voould be roximaaely muntlut from the dater of thlis
Notice. A notice orthe actual date of the Sheriff's Sale ff ?c sent to you before the sane, Of course, the aunt
needed to cure the default will inctease the longer you wait may find out ad any tip city uthat the required
payment or action will he by contacting the lcodcr,
HOW TO CONTACT THE LEIM DER a
EFFECT OF SE FF'S SALE - You should realize that a Sheriffs Sale will cW }our ownership of the
mortgaged Oo mty your _n Wt to occupy it. If you continue to live in the property after the Sheritrs Sale. a
lawsuit to rcr ovc you and your firrn shun arid other belongings could be sawtc4 by the lender at am, time,
ASSUMPTION OF MORTGAGE -You nary or su ay not X (CHECK CANE) sell or tra for your hornc to a
er or tram M11 assume the mortgage debt, provides that all the outstanding payments, charges and
attorney's fees and cosec rare paid prior to or at the sale and that the other ncqui cawnts of the mortgage aye satisfied.
YOU MAY ALSO RANT 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 TI11S DEBT,
• TO HAVE THIS DEFAULT CURED BY ANY TURD PARTY ACTING O 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
CLARE 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 1STITt M. UNDER TIIE MORTGA (jF L)OCTJX ENTS.
TO ASSERT ANY OTHER DEFENSE YOU I$ELJEVL YOU MAY HAVE TO SUCH A(--rl0N BY THE
LENDER.
+ TO SEEK PROTEC71ON UNDER THE. FEDERAL BANKRUPTCY LAW.
QN 14 T, N N S Y
ties
MEN
111111111111111
7107 8381 6540 2115 6315
PMUC lioAgals
3232 pmt Drivm
mie6Lwp, OW 4,%34
Te phoarn P37 4 V)-12DD
P.O. Box ISM
Dww, Ohio 454 I-1 Wit}
DATE October 15, yV 1 0
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the martin on your home is in default and the lender intends to
s
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP
mere bC;able to help to Un Unr home, This l' s ice, "p aina how The =_kj.
To see if HEMAP can helm you most MEET WITH A CONSUMER CREI)lT COUNSEU NAG
AGENCY'MYITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you MM with the connsellul acv.
The name- addMs anti phone number of QMU=er CMdit Cmm=fing A ing youc Caunly
arr kted at h d of h Notice If 3= him g= ara stiny call the P nUlvania Hmiri„R
Finance A tall free at 1- 342-2397. erstms with impaired hearin can call 717 780-1864),
This Notice contains Important legal information. K 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 NOTWICAC16N EN ADJUNTO ES DE SUMA. 1MPORTA NCIA PVES A FECTA SU VERECHO
A +CONTINUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CO VTENIDO DE ESTA
NOTIFICAC16N OBTE'r GA UNA TRADUCC16.N 1NMEDLATAMENTE LLA.MANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AOENCV) SIN CARGOS ALA NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PR TAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR S'U HIPOTECA..
Ht}ME[) R'S bNANIEW. GTE ?RICH ROBERT S
GOODRICH,L1SiA.
PROPERTY ADDRESS: 1595 W LISBURN RD
LOAN ACCT. NO.: 00058913"
ORIGINAL LENDER.. W"
CUR-RENT LENDERISERVIC;"ER.: PNC Hank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
IFYOU COMPLY 1 TrH THE PRMISIONS OF THE HOME0'N NER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 MM '"ACT'-)''YOU MAY' BE ELIGHILE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF FOUR DEFAULT HAS BEEN CAUSED BY CIRCU44ISTANCES BEYOND YOUR CONTROL.
IF YOU HAVE A REASQWABLE PRGISM-T OF BERING MILE PAY YOUR MORTGAGE PAYMEXTS? AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
T>@I4tPORAR4r STAY Q F FORECLOWK - Under the Act, you are ent-ded to a tet voraer}° htay of fcarravlosutra on
your mortgage for thirty (30) days from the darn of this Notice (plus three (3) ' for mailing), flaring that time you mint
wiw4e and atbe d a -f -to-fkw'irr tiny with one of the consumer cre& cuunseling, es listed at the end of this
Notice. THIS MEETING MUST OCCUR WITiHM (311 DA OF THE I)ATIR OF TNI.S NtIT1t"i IF VntI M
CONSUMER CREDIT COUNSELING AGENCIES If you inect with one of the ar umer er- dit a}oaaaa eliatg a?easc
listed) at the end of this notice, the lender may N(YT take action against you far thirty (30) days after the data of this
It is only Yto
Adviw yoL r lendexir?,rn, r-d?, lj&&of+, your intentions_
APPLICATION FOR MORTGAGE ASSISTANCE - Your max age is in cl-Faith for the rcawns se farlth later in this
Notice (see fallowing paw for specific infinnnation about the nature of your dcfarult.) You have the right to apply for
finma.:idl aansaaistanae fim the ll+ raeoa?iia 'sEnner vie}` Aasiataanuc Program To do spa, you mwa fill ow, sipand
file a complied Homeowner`sErner cy Assistance Program Application with o of the designated consumer credit
counseling; agencies li at the acid of this Notice- Only oxisunu!r a t& coaling agencies Iw- ve appd tic'ae€ for the
program and they will assist you to submitting a complete application to the Pcnnsyh-nnia I lour- ing Finance Agency. To
t poratrily stw the lender filing; a fbreclosure action, your afpficaation MUST be Ecarwaartlod to P1IFA and received,
within thirty (IEt) days of your face-to-farce meting with the counseling agency.
YOU SHaII.LD FIB A H ASP APPLI+CArION AS SW A' AS POWKE IF YOU HAVE A MEETING WIN A
CrClGrA' ELr A GENCY FITYtt AI 33 jDAYS OF THE POSTMARK DATE OF TI5T1''.ii NOTICE FILE A APPLIC':I TTi m
WTH PHFA wT7WN 0 DA YS OF 1TIAT E'LT1, THEA?' THE LENDER Of "ILL RE 7EW*M4=Y )PRE I E.VIED
FROMSTA&TINGA FORE1C'.LOSUXE AGAINST YOUR P*OPERTY, AS EXPLAINED ABOVF, IN THE SEC'TIONCALLED
"TE%"RARYST'AYOFFORaEC1.!'7 URE':
Y- 1 Ifs LE THE BMW M FILL A ff SAP Aff MUON EIL4f NEI't'!ND ZM SE TIME l?RNI e A LATE
AP LJC lT7ON I ,L WT 1`RL"4T.N'r THE LENDER fROM STA R17NG A POMC",t.OSUR'E ACTIO , SlIT IF YOUR
APPLICATION IS E1', Vn!ALL3'.APPRIOOED AT ANY TIME aR'EFGR;E A S1? ERIFF SSALA TTIE Ff1REaCTLaSUR,E' WILL
1RES110PPaa ?
AGENCY AMON -- Available funds fvr emergency merge assistance are very litni d. They will be
disbunkA by the Agceecy raider the eligibility pia establis)wd by the Am The P ;ylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application, luring that tine, no
foreclosure pro din will be pursued against you if you have met the tint req rments ScY Beth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NCVM: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUP'TC'Y.
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION P'LIRPOSE 074LY AND SHOULD
NOT BE CUNSIDERED Ali AN ATTEMPT TO COLLECT THE DEBT.
(lfyow We fled bankruptcy you can still fly for E:tn+ Wncy Mort W A.ssi ,)
now C'M YOUR ll ORTWWR DEFAULT (Erin it !i to date) .
JUTURE OF T= DRYA13LT -- The NORTY E debt held by _:he above lender an
your property 1004tes+d a :
159S R LI BURN RD
KE IG`fJ3T)R13, PA 1705.5
lS SERIOUS=,Y IN EFAULT because:
YOU HAVE NOT MAD) t JTHLY MORTGACE PAYMENTS for the following rrc-n:h Ia;b
August G1, 2010 to October al, 2010 and the following
mount. ! s i are now mast -dues :
Monthly Payments 0,D15_25
Corporate F".a 010a
Late Charges 30S_34
Non-Sufficient Funds .00
Fax Fees OQ
Property Insr, :ion Fees S, Q
Speedpay Fees 24_n0
Less Suspense Balance .00
Total lknount Past >u $8,357. e54
R€W TO CORE THE DEFAULT - You may cure the default within thirty 30) days
of the date of t,hi s notice BY PAT IM T= '1 AUDWT PAST DUE TO THR
I.' &, IMICH 19 j8,357_64, PLUS ANY KWTGAGE PAYMENTS AND LATE ROES
WHICH aECOME DUE DURING THE THIRTY (301 DAY PERIOD.
Faymem s must he made either by ea nhi r I $ h ck ro rt i f 1 d hank anti
ar mane order mad± paXable and whir tej:
PNC KorLgage
Collections Venter
3232 Newmark Dr
Miamisburg, OH 45432
Thjs is an attempt to rc?l i?ct a debt., o.ny in!ormation : bt.a; reed wi l l l)used for that purpose
Enclosure
DR67
t F YULI DO NUT CCU XM UEF W J - If you do not cuts the ditfault within THIRTY (30) DAYS of dw
date of this Notice, The Imder hMmds to exercise lb dEhts to atcMerats the mortsm debt This m cons that the
entire outstanding balance of this debt wi-11 be o m&idered due inmtediatelyand you may low the else to the
mortgage in moritlhly nstallmerrts, If full payment of the total amount past dune is not made within Tlllki r(30)
DAYS, the lender also intends to instruct its attotrwys to start legal act to kwedaw non
r+.
prom
OTHER LEIVTMER El!dEUtE.M - The krAlcr m al. sac you pccsottally for the unpaid pi ncipal balance aid all
tether sinus due u rxicr the mart
If you have not cured the def nk within
restore your mortgage to the same position as if you.W never defrauked
amhrmer
EARLIEST POSSIBLE SHERIFFS SALE DATE -- It is estimated that the earliest date that such a Sheritlc's
Sale of the property could he held would be approxim ly nt=,tep mondhs from the date of this
Notice, A notice-of the actual date of the SherifrsSalc wr be sent to you before the sale, Of course, the amount
needed to cum, the default t6ill " e the longer you wait. You t find out at any tune exactly what the tequirsed
payment or action will belay contacting the lender.
HOW TO CONTACT THE LENDER ;
Name of t PNUMMmy
Address: 3232 NVewmari Dr.
tta Number.
cont"t on: a ns en
E-Mail rear; n crier
EFFECT OF SHERIFFS SALE: -T You should realize that a Sherifrs Sale will end your ownership of the
mortj Mperty and your right to occupy it. If you continue to live in the property after the Sherif°s Sale, a
lawsuit to rcwvc you and your furnishings and other bclongings could be starved by the leader at xrW time,
AS?S1IMPTION OF i40RTGAGE -You mat), cr a wy not X (C"TIECK ONE) scil cartrariskr brow home t a
buyer or teat Rft_ wrt a mne the mtottgage debt, provideZ that all the oursumd ng tines, charges and
attorocy's and costs arc paid prior to or at the sale arid that the oth-_T mquircmcnts of the mortgagc arc satisfiod.
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 INST1 "'l.1T ION TO PAY OFF THIS DEBT,
TO HAW THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOURBEHALF.
IX) 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 S" EAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTMJTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUC'I- ACTION BY THE
LENDER-
* TO SEER.. PROTECTION UNDER THE FEDERAL B NICRt 'Y LAW.
NSVM
ER-CREJ -COX -G V0
T I Lr (: IF: rF
? FNS
MK. R E'
P.O. wx 1820
Dayton, Ohio A5401-1820
October lea, 010
5511 2S0.4u1s04! CMl
IIIIIIIIIIIIII
7107 8381 6540 2115 6308
PNC Marls
3232Nawmwk Drive
A%MWwg. 0&o 4ta 42
Tehiphone: (937 310120D
m0wigAddrom
P-0, ftm Ion
{ODDRICH, RDBERT S
BOX 747
MECHANICSBURG RA 1'7055-0,74Y
DATE'z (}mba 15. 24) 10
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortaaee on vour home is in debult and the leader intends to
ftrmlose. SvccMc Information about the Patere of t
The HOMEOWNER'S EMERGENCE' MORTGAGE ASSISTANCE PROGRAM HEMAP
may he Able to help to save nur l.mm, This Notice g=lsona how he III w?rk&
To see if FWWAP can help, von most MEET WITH A CONSIJMER CREDIT COUNSELING
AGENCY WITHIN 33 HAVS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Cou as+elina Aseen
The me rldJZ5 anti plume n Um_ r f Cana=r& flit Cmmse ingAgencie serving your mw
at listed at the d of h`. Noting. fyou, ?_ a ??
Finame A toll free at 1-8W342-2397. Pans with rdearir?fl the fi -.? can call (7171 7S ?
This Notice contains important legal Information. If you have spry questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain It You may also want to contact
as attorney is your area. The local bar aswistion may be able to help you Ilnd a lawyer.
LA NOTI CAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA PUSS AFF.CT A SU DERECHO
A CONTlNUAR VIVIENDO EN SU CASA.. SI NO COMPRLNDE EL CONTENIDO HE ESTA
NOT IFICAC16 OBTENGA UNA TRADUCC16N aNM:EDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSVLVANIA HOUSING FINANCE AGENCY) $IN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PA?RA L PRI STAMU POR EL PROGRAMA
LLAMAIKI "HOMEOWNEW-S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL
PUEDE SALVAR SU CASA DIE LA PERDIDA DEL DERECHO A. REDIMIR SU HIPOTECA.
HOMEOWNER'S NAAMUSY C RICH,ROBER'T S
GOODRIC KL;ISA
PROPERTY ADDRESS: 1395 W LISBURN RD
AN ACCT. NO,; 40058+90"
ORIGINAL LENDER,, Wa
CURRENT LENDERISERV'ICER-, PNC
HOMEOWNER' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
a
IF YOU COMPLY AITH THE PRO ISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
.kCT OF 1993 (ME '"ACTT, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT I LAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• If YOU HAVE A REASONABLE, PROSPECT OF BEING ABLE TO PAY YOUR 14 ORTG.-V:E PAYNIENM AND
IF YOU FEET OTHER ELIGIBIIdTY REQUIREMEN71S ESTABLISHED V THE PE.", SYLVANIA. NGUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Aft, you arc entidod to a Crary siay of forcclosureon
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arms c and attend a "fit-to-faco`hwetin with q of the consumer crediE counseling agencies liaswA at the d of tip
Nofice. THIS MEETING ST OCCUR WITHIN 1331 DAYS OF THE -DATE OF THIS NOTICE. IF YOU DO
HOW TO RPJNG YOUR MORTGADE UP TO DATE
C'QNS[.UMF.RCREDIT COUNS rG AGENCIES -If you meet utith ame of the Lonstaanr,a• dit c oun linngayLmx-ies
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 wm c aa?nd t+'la la nen of desigw "W C .nn ,.s,+ r c rl t w 1irn2 a for di +rrt
, It is only t essaryto schedule one -to-face meeting.
Advise your lend UUCdjM*of your intentions-
APPLICATION FOR MORTGAGE ASSISTANCE -- YouT moot} a is in default fur the reasons set forth later in th&
Notice ism following pages for specific irdbr nation about the nature of your &-fauult.) You have the right to apply for
financial as ibua nee tium the Ilcxs vowner'a Emergency Mortgage Assistance Progmm To do so, you must fill tout, sign and
file a completed llouneowner'spmergetncy Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this No twe_ Only c unuz credit counseling agenci a have applications for the
pvogram and they will assist you in submitting a complete application to the Pennsylvania Homing Finance Agency. To
temponaily stoop the leaner fvtn filing; a foreclosure action, your application MUST be ft varrded to PHFA and roceiw
within thirty (Tp) days of your face-to-face meeting with the counseling agency.
VOL' SHOULD FILE A HEMAP APPLICATION AS S N' AS POWNL.a1 IF YOU HAVE A MEETING PITH A
COUNSELING A GEN 147TW k 33 DA I S OF THE POSTMARK DA IT OF IRIS 1'"l?',lr FILE AA? APPLK-A Tff!'N
17TH PKFA 077MN J# DAfS OF T94T MEETINCh TMEA' THE LE',VOERR HILL BE TE.HPI#11Cr1M Y PREVEAWD
FROMS?"ARTIN A FOREC'LOSUR A AMST YOUR PWOPE`RTY, AS EXPLAI3VF..D ABOVE, IN THE SEC7W.1V CALLED
"TEMPORARY STA Y OF FORECLOSURE ':
E .4 .jKM P .4PP t F A' LATE
.oIPMCA771t, V WILL NOT 1'E.Vr THE LENDER FkW STARTING A FORECLOSURE AC'TWV,, At'r lip YOUR
APPLICATION IS EtT. VnIALL Y APaPROF'E'A 4T AW T/ONE BEFORE .4 SolfyT cRIF'F S SA LE, 11IE FORECLOSURE 1#7LL
SE STOPPED.
AGENC"Y" ACTION -- Available finKis far emergencymon gage assistance are eery limited. 'Tl y will be
disbursed by the Agency under the eligibility tviteria ekabli l by the Act. The Pennsylvania Houton;
Finance Agency has sixty (60) days to make a decision after it receives your application. Oaring that tine , no
forec xsume pmrxx ings will be mound ' -t y if you have met the titne requirennerits scat (brth ubo-c.
You will be notified directly by the Pennsylvania Housin Finance Agency of its decision on your application.
NOTE. IF YOU AM CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SWU I D
BE C ONSIU A AN ATTEMPT TO COLLECT THE I3Ellf1'.
(If ykw have tiled bankruptcy you can still ' for E ncy Mortgage A%,4 ,;l
HOW TO CURB YOM RT"GE 1DE PA>Il LT (Br ixi it-4p to date)..
MATURE OF THE DEFAULT -- The MORTGAGE debt held by he above lender an
your property located at-:
LISBURN RD
4 C +«T HITF , FA 17055
is SERIOUSLY It4l EFAi_tVf because-
YOU HAVE NOT MADE MONTMY NORTCACIE PAYMENTS for the following month ! s'
August 01, 2010 to October al. 2010 and the following
artunt{s1 are now vast due:
Monthly Payments 8,1015.25
Corpora.,*-, Fres 0.Dd
Late Charges 305.39
[ion-Suffitir;it Funds . 0
Fax Pees .0th
Property Inspection Fees 9.00
Speedpay Fees 24.00
Less Suspense Balance 110
Total Amount Past DUO $8,357.64
HOW TO CURB THE DEFAULT - You may cure the default within thirty 1301 days
of the date of this notice BY PATZW T= TOTAL i11R'rMIT PAST TO THE
LZEDER, WHICH IS $0,357.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING TIM THIRTY (301 DAY PERIOD.
Fawments_etust be made either 1hv rashier,s cher*k ca ifi r7 h k e-amh
money ordr'rt- made pa,eable and een,.- to;
P14C ML)rt_gage
Collections Center
3232 Newmark Dr
Miamisburg, CH 45432
rhis a ap at_t.ftmpt. t E°Ct debt, n 1t5'csY'R1.3t.;.t?C1 ,)h a rued will be
used for that purpose.
E,nclasure
DR670
- If you do not t rr the default within TFIIRTY (30) DAYS of the
doe its rhrhts to amlerate the mortaaee debt This mew that the
entire outstanding balance of this debt will be considered due itrmtediatelyand you way lie the e? to nav the
mortgage in monthly installment& If full payment of the total saturant past dine Ls not matte wMin THtK14Y (30)
DAYS, the lender also inter to instruct its attar ticys to Mart legal action to foredow now
It y.
O'T'HER LEMUR RMD1lE.S - The lender may also sus you personally for the to . ` principal balance and all
other sums due under the mortgage-
(30) DAY period and f xwlosur c
restore your mortpge to the same position as Nye* never defaulted
If you have not cured the default within
10"near rat
EARLIEST POSSIBLE SHERIFFIS SALE DATE _- It is estimated that the earliest date that such a Sheriff's
Sak of the ? property could be held would be ?mately ? months from the date of this
lrlotlse, non e o the actual d of the Sher fL'sSalc =1
We sent to you before the sale. Of curse,. the amount
needed to curethe default wtill increase the larger you fruit. You may find out at any time exactly what the required
payment or action will he by contacting the lender.
HOB' TO CONTACT THE LENDER.
EFFECT OF SHERIFFS SALE You should realise that a Sheriffs Sale will cad your ownership of the
mortgaged praperty afid your -n Wt to occupy it, If you oont true to live in the property aver the Sheriffs Sale, a
lawsuit try rcmm•c you and your f"uimishiing;s and other belongings could be started by the lender at any time.
??'" JMf''I'1ClN OF MORTGAGE - You may or way= not X (CH FC ONE) sell or transfer your home to a
uyeer car transibiCv Who- Wiassutme the mortgage deft, ptmvide3 that all the outstanding payments.. chargers and
attorney's f= and costs am paid prior to or at the sale and that the other re?qui?rett? ns? of the mortgage are satisfied.
YOU MAY ALSO RAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN I4iC1NEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY PROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT,
TO HAVE THIS DEFAULT CURED BY AT` Y TI° tRD PARIN ACTING O YOUR BEHALF,
+ TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF '40 DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT_ (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TRVIES IN ANY CALE AR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OMER LAWSUIT TNSTITUTEB UNDER THE MORTOAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO tl CE T A C'T'ION BY TI IE
LENDER-
* TO SEEK PRO] =- ON UNDER THE FEDERAL. BANKRUPTCY LAW-
N 'I' -CQAMMJN-G-AaUl4CJE5, R N YOU, N
IkU.
"'K i
bayWm OW 45401-1820 7107 6361 6540 2115 6322
October 15, 2010
sse 82.Od1-flR7 04
PwC 00
3232Hawm uk Drive
MWmisburg, Oh*A5342
'1<eMpho : 4'33T+910-1214
F10, Box ISM
Now Ohio 4 11-1 t
GJDIRICH, LISA
?3 BOX 747
DATF-. October 15, 2010
AC'"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 tateeds to
t
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM EM"
ma he able to bdp tom, o save Unr h =L this Notice eu bin: ban the am==_mffju?
To see It HEMAP can heln, von mma MEET WITH A CONSUMI R CREDIT COUNSELING
AGENCY VU rMIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou
when -you meat with the Counspll
The rkam _ ridWS am nbWC number of .nnW_rner Credit C . unselinor A le i s ing ??'n'- C.t?n_n
fisted at hr d of his Notice_ If have anN=€ uegions_ rcm may es11 the Pe L_vWvgniA HaLsilng
Finance A cv to)] free at 1-800-342-2397. (Persons with irn aired hearing call `717 780-1802).
This Notice contains important legal information. If you have asy questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain lt. You may also want to contact
am attorney in your area. The local bar association may be able to help you find a lawyer.
LA ' OTIFICAC16N EIN ADJUNTO ES DE SUMA IMPORTAJ CIA, PLIES AF C I' S DER HO
A CONTI NUAR VIV'IENDO EN SU CA.SA. Sl NO COMPRENDE EL CONTENIDO DE ESTA
N071FICAC16N OBTENGA UNA TRADUCC161N LNMEDIATAMENTE LLAMANIDO ESTA
AGENCI.A (PENNSYLVAINIA HOUSL"VG FINANCE AGENCY) SIN CARGOS AL NVMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIIILE PA:ItA UN PRtSTAM10 POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL
PUEDE SALVAR SU CASA DE LA PERDIDA DFL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'SNAME{5i; r» v??DR?ryICKR1O8ERT 5
L.1tJ'4J RICKLL??I?7?A
PROPERTY ADDRESS: 1595 W LISBURN RD
LOAN ACCT. NO.: 000991344
ORIGINAL LENDER: tar`s
CURRENT LENDEW SERV CER, E
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR. HOME
YOU MAKE r
IF YOU COMPLY WITH THE PRM'1 ONS OF THE HOMEOWNERS EMERGE ' MORTGAGE ASSIS'TAWE
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 ?M ORTGAGFE PA"Y`MEN I'S, AND
+ IF YOU MEET OTHER ELIGIBILITY REEQt1tRK MIEN ESTABLISHED BY THE PENNSYLVAJNIA HOt LNG
FINANCE AGENCY.
TE1411PORA RY STA'Y' OF FORECLOSURE -- Under the Acct, you entided to a temporary stay of f weclostare, an
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). Boring that time )vu must
a unp and attend, a "f -to-fic 'in ting with one of the c nirsemner credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN (331 DAYS OF THR DATK OF TIMS NnT1rB'_ IF VAI t rvl
CONSUMER CREDIT COUNSENG AGENCIES - If you meet with one oyf the consurner cvedit eoun tin a -ies
listed at the end of this notice, the lender may NOT take action against you for thirty (3) days after the date of this
i It ism* necessaryto schedule one trace-to-face
Advise your lend ' gWyo your intentions-
APPLICATION FOR MORTGAGE, ASSISTANCE -- Your nxatgage is in default for the reamms wet forth later in this
Notice (see "lowing paw for specific information about the rwame of your default.) You have the right to apply for
firu mial assistwrxv f vrn the Howcow ner's E cy'Mortgage Assistance Proganrn. To du gin; you -mast fall out, sign and
file a completed l• omeowrner'sEmergency Assistance Program Application with one of the designated consumer edit
counseling agencies listed at the end of this Notice. Only cor s== credit counseling agencies have apprlicatiuns for the
program and they will assist you in submitting a complete application to the Pennsy"lvartia Housing Finance .Agency. To
eemporazily stop the lender fr+xn filing a fowelosure action, your application MUST be forwin4od to P UFA and r eive d
urithin thirty (3b) days of your face-to-facie meeting with the counseling agency.
YOE. SHOULD FILE A HE AP APPLIC"ATI N AS S?` )ON AS BIBLE IF 11OLP HAVE A MEETING WnW A
C'OINSEI,'W A NC'I' 0177WIN 33 DA VS OF ? POSTMARK A TE OFTIUS NMWE '1 FILE AN APPUCATft7!N
WITU PHFA wITTt7.N .#8 DAYS OF T MEETING, THEN TT,I"E LF.Vb" WILL BE TE POINJULY PREVENTED
FROM STAR TING A FORECLOSURE AGrIIAST YOUR PROPER TY, AS EXPI AiNED ADO VF, IN THE SECTION CALLED
"TFMMJL#RYSTAYOF FORECLOSURE'.
TO Ff L '_ VE 77 MCMU A LATE
APPLICATION ilt•"IU T P*ECE:V'T THE LENDER FJN V ST"AR77 A FOAWLOSLRE ACTION. BUT IF Y R
APPLICA77t7N IS EVEA'T£IALL Y'APPROVED .SIT A?S'Y' 711ME BE'FOREA SHEi RIFFW SALE, IWE Ft7afi!ECLOS,I WE HILL
BE SIOPP"E'D.
AGENCY AM ON -- Available fimds for emcr ncym ge assistance are very limited., `ncy will be
disbursed l the A cney uxtda the eligibility criteria osta bliMiod by the Act_ The Pennsylvania Hour inl;
Finance Agency has six-q, (60) days to make a decision after it receives your application. During that tom, no
formicLaume pn edi%-s will be ptrrsvod as ainst you if you have met the t t rNui=nmrft set &rrth above.
You will be notified directly by the Pennsylvania Hougng Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTWTEb BY THE FILING; OF A PETITION IN BANKRUPTCY.
THE FOLLOWING PART OF THIS NOTICE IS F+LIIi 1NFOR, TIOrV FI.JRPO r ONLY AND SHOD
NOT BE WINSIDERED AS AN ATTEMPT TO C OLUCT THE DEBT,
(Ifym have fled b*nkruptcy you can still apply for Eraerpency Nforqpge Assistarrbcc? )
NO CMM YOUR MORTGAGE DEFAULT (R rin it 14 to date)
IMTURE OF THE DEFAULT -- The MORTGAGE debt held by the aloe lender on
your property located at,;
-595 W LISBU
t IC- 2G, PR 17055
18 SERIOUSLY IN :3YV `+U1,T becauae:
WU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following maonth i s?
August 01, 2010 to October 4i, : 310 and the following
amount f si art. now past € ;
Mon hl*yr Payments 8, D 5.25
Corporate Feet 0100
Late charges 309.39
Lion-Sufficient Fangs .00
Fax Fees .0D
Property In,src.ion Fees 9.00
Speedpay Fees 21.00
Less Suspense Balance , 00
Total Amount Past Due S 8, 3 5'?, 64
H€i'W TO CURS THE DEFAULT You may stare the default within thirty {30) days
of the date of this notice BY PAYZM T= TOM PAST =3 TO TSB
LELHER, WHICH IS $8,357.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
1WHICH BECOME DU DURING THE THIRTY (301 DAY PERIOD.
F.&Mentgmugt be made githi-r by caghier's the k. r i f- d h k gh
at monev arder made raxabl* and raertt. t .o,
PHC Mort:gage
Collections Venter
3232 Newmark Dr
Miamisburg, GBH 45432
7'h i q ,o atr Atttmpt: vo col itct A debt, any inlormaAt .oCt nY??_? rt?d x i 1 l he
used for that purpose
Enclosure
DR67_
IF YO nn NM CIURE T DEER !LT - If you do not cure the, default with TI-URTY (30) DAY of the
date of this Notice, the leader laterrds to exercise its rights to accelerate the wort a debt This metes that the
entire outstanding balance of this deft will be o ns- tiered due inunedialelyand you may low the charge to the
mortgage in monthly installments, If full payment of the total amount past due is not made within Tifli('l?(30)
DAYS, the, lender also intenids to instnxi its attorneys to start legal action to
l rh'.
Ca'I'UR LENDER RE141>laDlPS -- The lender may also ;sue you personally for the unpaid principal balance and all
other shins due under the mortgage_
the WRTY-00) -DAY
;WVI reswre y' er mortMe to the same position If yore W never defiau
-= If you have not cured the default -%ithin
¦aaunner
EARLIEST POSSIBLE SHERIFF'S SALE BATE - It is estimated that the earliest date that such a Sheriffs
Sale of the moat prope y could be held would be ro?a ma ely mine - ten moada from the date of this
Notice, A ntrt ee ?ofthe actual date of the Sheriff's Sale lbe 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 ti exadly WhK the squired
p "mcnt or action will be by contacting the Irw1cr.
"OW TO CONTACT THE LENDER
EFFECT OF SHF.ttWP9 SALIE - You should realize that a Shertfrs Sale "I end your orwnermhip of the
mort
gaged
property your to occupy it. If you continue to live its the party after the Sheri Sale a
lawsuit to rcwvc you and your furnishings and other Wongings could be saw" by the lender at any time.
ASSUMPTION OF MORTGAGE -You way or orgy not X (CHECK ONE) sell or transfer yew homc to a
bii?& or tram eras who wr assume the rtgage; debt, prowi&;U that all the owing payments, charges and
attorney's fccs MW costs ate paid prior to or at the sale and that the othocr rcquircrncnts of the mortgage am wnsf'ic4_
f
YOU MAY ALSO HA NT THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY rROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT,
* TO HAVE THIS DLFALJL ' CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF,
TO HAVE ME MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HO'WWER, 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 L DER 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.
NW 1y VQVR CO
VERIFICATION
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 unswom falsification to authorities.
UDREN LAW OFFICES, P.C. - 'S
BY: 3?? -
Day,--
pA ID 306534 ?yu;i
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
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
HEATHER RILOFF, ESQUIRE - ID # 309906
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadines(a,)udren.com
PNC Bank, National Association
3232 Newmark Drive
Miamisburg, OH 45342
Plaintiff
rr-yyt1H 1Gc TAR I
zoI I Plata -6 ? 10.06
t` MPENNSYLDVANIA TY
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
LISA GOODRICH NO.
PO BOX 747
MECHANICSBURG, PA 17055
ROBERT S. GOODRICH
PO BOX 747
MECHANICSBURG, PA 17055
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, Sherri J.
Braunstein, Esquire; Chandra M. Arkema, Esquire; Marguerite L. Thomas, Esquire;
Daniel S. Siedman, Esquire and Heather Riloff, Esquire on behalf of the Plaintiff, in the
above-captioned matter.
UDREN LAW OFFICES P.C.
BY: '-
Daniel S. Siedman, Esquire
PA ID 306534
UDREN
WOODC
111 W
CHERRY
856-66 W OFFICES, P.C.
ST CORPORATE CENTER
DCREST ROAD, SUITE 200
HILL, NJ 08003-3620
9-5400 ATTORNEY FOR PLAINTIFF
PNC B ank, National Association :COURT OF COMMON PLEAS W
Plaintiff --CIVIL DIVISION
Cumberland County Cr- ? ?CD
a
V . cn c
Lisa oodrich
Rober S. Goodrich € NO. 2011-3494 ?o c `z
?C 0)r-i
Defendant (s) :'
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
y reinstate the Complaint on the above-captioned matter.
DATE: April 21, 2011
UDREN LAW OFFICES, P.C.
BY.
Attorneys,for Plaintiff
Daniel S. Siedman, E=squire
PA ID 306534
L-XMk r lb .00 Pd 01F
ee&-? Ssd
e*. sSI 9q
FILEO-OFFICE
UDREN LAW OFFICES, P.C. OF THE ""T""A' KvEY FOR
W0 CREST COO RATE CENTER 2012 JUL 30 AM 9: 21
111 ODCREST ROAD, SUITE 200
CHERKY RILL, NJ 03 CUMBERLAND COUNTY
-"- PENNSYLVANIA
PNC Bank, National Association
COURT OF COMMON PLEAS
CIVIL, DIVISION
Cumberland County
Plaintiff
V.
Lisa Goodrich
Robert S. Goodrich NO. 11-3494 Civil
- Defendants
Plaintiff, PNC Bank, National Association, by its Counsel, Udren Law Offices, P.C., 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
reasons:
1. Plaintiff's original Complaint in Mortgage Foreclosure was filed on April 6, 2011
2. Plaintiff desires to amend its Complaint in Mortgage Foreclosure in order to
correct the amounts claimed due and the designation of the Plaintiff.
3. 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".
In accordance with Cumberland County Local Rule 208.3(a)(2), to date no Judge has
ruled upon any other issue related to or in this matter.
Pursuant to Local Rule 208.3(a)(9), Plaintiff sought concurrence of all opposing counsel
of record on June 4, 2012 with a deadline of June 14, 2012. As of June 15, 2012 no response
was received from any opposing counsel by the Plaintiff.
WffM FORE, Plaintiff respectfully requests that this Honorable Court grant the
Plaintiff leave to file its Amended Complaint in Mortgage Foreclosure.
Respectfully submitted,
UDREN LAW OFFICES, P.C.
I
s
t
BY
H e, sq .
PA ID # 310501
Attorney for Plaintiff
t
UDREN LAW OMCES, P.C. - ATTORNEYT`OR
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
ple?gsat?reecam
PNC Bank, National Association COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff Cumberland County
v.
s
Lisa Goodrich
Robert S. Goodrich € NO. 11-3494 Civil
Defendants
CERTIFICATE OF SERVICE
I, Harry B. Reese, Esquire, hereby certify that I have served or caused to be served true
and correct copies of the Plaintiffs Amendment to the Motion For Leave To Amend Complaint
in Mortgage Foreclosure and Brief in Support upon the following persons named herein at their
last known address or their attorney of record.
xxxxxx Regular First Class Mail
Date Served: July 7-1 , 2012
TO: Lisa Goodrich Robert S. Goodrich
218 South Pebble Beach Boulevard 218 South Pebble Beach Boulevard
Sun City Center, FL 33573 Sun City Center, FL 33573
Defendant Defendant
UDREN LAW OFFICES, P.C.
By
H R , Esq e
PA ID # 310501
Attorney for Plaintiff
PNC BANK, NATIONAL ASSOC.,
PLAINTIFF
V.
LISA GOODRICH
ROBERT S. GOODRICH
DEFENDANTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAN
NO. 11-3494 CIVIL
IN RE: MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT
ORDER OF COURT
AND NOW, this 1St day of August, 2012, upon consideration of the Plaintiff's
Motion for Leave to File an Amended Complaint,
IT IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon the Defendants to show cause why the relief requested
not be granted;
2. The Defendants will file an answer on or before August 31, 2012;
3. The Prothonotary is directed to forward said Answer to this Court.
4. Hearing/argument on the matter will be held on Thursday, October 25, 2012, at 11:1
a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
By the Court,
M. L. Ebert, Jr., J
Harry B. Reese, Esquire
Attorney for Plaintiff '
? Lisa Goodrich MW map
? Robert S. Goodrich Nr
Defendants r '-
basple.S x? a
CD
d
ter;
.-4
r7it,ED-U FiCE
UDREN LAW OFFICES, P.C. ATTORNEY FOR
WOODCREST CORPORATE CENTER AUG -g i4=C
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003 ^UMBERLAND W)"'y
856-669-5400 PENN SYLVANI A
vleadinas(a udren.com
PNC Bank, National Association
Plaintiff
v.
Lisa Goodrich
Robert S. Goodrich
Defendant
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 11-3494 Civil
CERTIFICATE OF SERVICE OF RULE TO SHOW CAUSE
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 August 31,
2012 with regard to Plaintiffs Motion For Leave To File An Amended Complaint upon
following person(s) named herein at their last known address or their attorney of record.
xxxxxxx Regular First Class Mail
Date Served: August 7 , 2012
TO: Lisa Goodrich
218 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
Robert S. Goodrich
218 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
UDREN LAW OFFICES, P.C.
B
Att e or Plaintiff
HARRY B. REESE, ESQUIRE
PA ID 310501
PNC BANK, NATIONAL ASSOC.,
PLAINTIFF
V.
LISA GOODRICH
ROBERT S. GOODRICH
DEFENDANTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11-3494 CIVIL
IN RE: MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT
ORDER OF COURT
AND NOW, this 15t day of August, 2012, upon consideration of the Plaintiffs
Motion for Leave to File an Amended Complaint,
IT IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon the Defendants to show cause why the relief requested should
not be granted;
2. The Defendants will file an answer on or before August 31, 2012;
3. The Prothonotary is directed to forward said Answer to this Court.
4. Hearing/argument on the matter will be held on Thursday, October 25, 2012, at 11:00
a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
By the Court,
Harry B. Reese, Esquire
Attorney for Plaintiff
Lisa Goodrich
Robert S. Goodrich
Defendants
.bag
M. L. Ebert, Jr.; J
.
4 C-
F -7.fi
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
_ „,._
E. l.i ° ~ i° ~" i, k.
• ~w ~ r ~ T~~~Y FOR PLAINTIFF
~~~?. SEA' -~ ~'~ f 1 ~ {
'Jt•~EF~~~'a.WD COU~dTY
~'Et~~dS~LV~NfA
pleadings ,udren.com
PNC Bank, National Association '_ COURT OF COMMON PLEAS
€ CIVIL DIVISION
Plaintiff € Cumberland County
v.
Lisa Goodrich
Robert S. Goodrich = NO. 11-3494 Civil
Defendant(s)
MOTION TO MAKE RULE ABSOLUTE
Plaintiff, PNC Bank, National Association, by its Counsel, Udren Law Offices, P.C., and
the undersigned Attorney, moves for a Rule Absolute, thereby granting Plaintiff the relief prayed
for in its Motion For Leave To Amend Civil Action Complaint In Mortgage Foreclosure and in
support thereof, avers as follows:
A Motion For Leave To file an Amended Complaint in Mortgage Foreclosure,
together with a Rule to Show Cause why said Motion should not be granted was filed by counsel
for Plaintiff on June 15, 2012.
2. The Rule to Show Cause was entered on August 1, 2012 with a Rule Returnable
date of August 31, 2012. A true and correct copy of the Rule is attached hereto as Exhibit "A".
3. On August 7, 2012, a true and correct copy of the Rule to Show Cause Order was
served upon all the Defendants, Lisa Goodrich and Robert S. Goodrich Via First Class Mail as
certified to by the Order provided by the Cumberland County Prothonotary. A true and correct
copy of the Certificate of Service is attached hereto as Exhibit "B".
4. To the best of Plaintiffs knowledge, information and belief, no response was filed
or any objections interposed by any of the served parties, attorneys ,and/or interested persons.
Therefore, no cause has been shown as to why the relief prayed for in said Motion For Leave To
file an Amended Complaint in Mortgage Foreclosure should not be granted.
5. The Rule to Show Cause should be made Absolute and the relief prayed for in the
Plaintiffs Motion For Leave To file an Amended Complaint in Mortgage Foreclosure should be
granted.
WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter
an Order making the Rule Absolute and therefore grant the relief prayed for in its Motion For
Leave To file an Amended Complaint in Mortgage Foreclosure.
Respectfully submitted,
UDRE LAW OFFICES, P.C.
BY
Att nti
HARRY B. REESE, ESQUIRE
PA ID 310501
PNC BANK, NATIONAL ASSOC.,
PLAINTIFF
V.
LISA GOODRICH
ROBERT S. GOODRICH
DEFENDANTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11-3494 CIVIL
IN RE: MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT
ORDER OF COURT
AND NOW, this 1S~day of August, 2012, upon consideration of the Plaintiff's
Motion for Leave to File an Amended Complaint,
IT IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon the Defendants to show cause why the relief requested should
not be gran#ed;
2. The Defendants will file an answer on or before August 31, 2012;
3. The Prothono#ary is directed to forward said Answer to this Court.
4. Hearing/argument on the matter will be held on Thursday, October 25, 2012, at 11:04
a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
By the Court,
M L Ebert Jr J
.,
Harry B. Reese, Esquire ~ ~ ~
Attorney for Plaintiff ,
~
~ .~,
gin;:==
Lisa Goodrich ~' '
-' `~
Robert S. Goodrich -tip
{
..~ -~s.t:
c~~
Defendants
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EXHIBIT A
UDREN LAW OFFICES, P.C. ATTORhTEY FOR PLAIN TIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 .
CHERRY HILL, NJ 08003
856-669-5400 -~' ~ °'~
pleadings a(~,udren.com ..~ s
~'~'
PNC Back, National Association rn ~
=COURT OF COMMON PLEAS ~~ s~
~ ~~+"'
Plaintiff :CIVIL DIVISION ~°°!" i ~
~
v. :Cumberland County ~~ '~ -t~
~ ~~
Lisa Goodrich ~~. _ ~~
Robert S. Goodrich NO. 11-3494 Civil 3a°~ °• ~r"'
Defendant ~ ~ : ~
.
. ~
CERTIFICATE OF SERVICE OF RULE TO SHOW CAUSE
The undersigned attorney hereby certifies that I have served or caused to be served true
and correct copies of the Ruie to Show Cause with a Rule ~Returnabi.e Date of August 31,
2012 with regard to Plaintiff's Motion For Leave To File An Amended Complaint upon the
following person{s) named herein at their last known address or their attorney of record.
xxxx3:xx Regular First Class Mail
Date Served: August 7 , 201?
TO: Lisa. Goodrich
2l 8 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
Robert S. Goodrich
218 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
UDREN LAVV OFFICES, P.C.
B
A e or Plaintiff
HARR 8. REESE, ESQUIRE
PA ID 310501
COO C='~`'r`
EXHIBIT B
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
CIVIL DIVISION
Plaintiff € Cumberland County
v.
Lisa Goodrich
Robert S. Goodrich = NO. 11-3494 Civil
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that true and correct copies of Motion to Make Rule Absolute
were sent to the following person(s) named herein at their last known address or their attorney of
record by.
XXXXXX
Regular First Class Mail
Date Served: September ~ , 2012
TO: Lisa Goodrich
218 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
Robert S. Goodrich
218 South Pebble Beach Boulevard
Sun City Center, FL 33573
Defendant
UDREN LAW OFFICES, P.C.
BY~~ ,1 ~ /1,~
Attdrrfe}Ys for Plai~£i ~-~
HARR`r B. REESE, ESQUIRE
PA ID 310501
IN THE C(JURT OF COMMOM PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PNC Bank, N.A.
Plaintiff, Case No.: 1 1-3494 ^_
v.
Lisa Goodrich and
Robert S. Goodrich
Defendants
i
SUGGESTION OF FENDING BANKRUPTCY PROCEEDINGS
A voluntary petition under Chapter 7 of the United States Bankruptcy Code was filed in the
Bankruptcy Court for the Middle District of Florida, Tampa Division, on ~='c:Z~,~-.;c" -, _._~~ ~ __, 2012,
which case is captioned:
In re:
Robert Goodrich and
Lisa Goodrich
Chapter 7
Case No.: ~ ~ i~ ~~K ~ ~ t.~ ~~ C,• 1
The tiling of this Suggestion does not constitute a Notice of Appearance in these proceedings.
The undersigned represents the Defendant in connection with a federal bankruptcy case, as referenced
above, and is providing this Suggestion for informational purposes only.
Respectfully
G. Donal e a. Bar No.: (1137080
don@br nd la er.com
Joseph B. Battaglia, Fla. Bar iJo.: 0058199
joe@.brandonlawyer.com
THE GOLDEN LAW GROUP
808 Oakfield Drive, Suite A
Brandon, Florida 33511
Telephone: (813) 413-8700
Facsimile: (813) 413-8701
Bankruptcy Counsel for Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY 'THAT, on this _3 ~ day of ~~C~r.~r`-,- _ 2012, a true and correct copy of the
foregoing has been provided via mail to; Attorney for Plaintiff; Udren Law Offices, P.C'., Woodcrest
Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hil , J 8 03.
G. Do d lden, Fla. Bar No.: 0l 37080
Jose B. B ttaglia, Fla. Bar No..: 0058199
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 c �_
CIVIL DIVISION -°a
Plaintiff Cumberland County z� „� M
V _ C3
LISA GOODRICH NO. 11-3494 C:) .
ROBERT S. GOODRICH; et al CZ)
aM>X M
Defendant(s) ---q o
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date:4-" �i
UDREN LAW OFFICES, P.C.
BY:
Att'oA4je Aj P f
HAR B. REESE, ESQUIRE
PA ID 310501
y Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s) APS International, Ltd.
VS.
Lisa Goodrich,et.al„Defendant(s) 1-800-328-7171 .
^ItN4-IrERNATIONA1, APS International Plaza
7800 Glenroy Rd.
Minneapolis.MN 55439-3122
APS File€i: 122012-0002
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES --Lisa Goodrich
Ms.Henni Crommarty Court Case No.Cumberland Co 11-3494
111 Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
State of: )ss.
County of. 1-N
Name of Server: h�N NOcv �c�Art�S ,undersigned, being duly sworn,deposes and says
that at the time of service, s/he was of legal age and was not a party to this action;
Date/Time of Service: that on the -�2 0 day of �`t1P�Q c� ,20 13 ,at 1\ !90 o'clock _t:Z_4M
Place of Service: at 1713 Atrium Drive in Sun City Center,FL 33573
Documents Served: the undersigned served the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Lisa Goodrich
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 , a person
of suitable age,who verified,or who upon questioning stated,that he/she resides with
Lisa Goodrich
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 ColorCcr-Nc_, Hair Color Q\or%& ; +eeia}"I-lail' taLA5SE5
Approx.Age S4\q,& ; Approx. Height s /S1I ; Approx.Weight k"0 \bs
"*�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 Subscribed and sw to before me thi
that the foregoing is true and correct. 7S'day o 20 13
Signature of Server Notary Pubfi (Commissi Expires)
APS International, Ltd.
SEAN SIM
NoWV Pd at;-IM d Fk ma.
my Comet.bom i"S,5017
��� Cannft"I EE 894170
F, 0
•
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCRF.ST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
PLeWinn@udren.com
PNC Bank,National Association 1 COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. , Cumberland County
LISA GOODRICH MORTGAGE FORECLOSURE
ROBERT S.GOODRICH
Defendant(s)
NO.11-3494
OF SHERIFF'S SALE OF REAL PROPE 3 (3 S 1-1 V E D
TO: Lisa Goodrich .20 1713 Atrium Drive ;
Sun City Center,FL 33573
Your house(real estate)at 1595 West Lisburn Road,Mechanicsburg,PA 17055 is scheduled
to be sold at the Sheriffs Sale on June 5,2013 at 10:00am at the Cumberland County
Courthouse,Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce they
court judgment of$3 S1.02,obtained by Plaintiff above(the mortgagee)against you. If NES
sale is postponed,the property will be relisted for the Next Available Sale.
NOTICE OF QMMR'S RIGHTS
YOU MAY BE ABLE TO PREYEM THIS SHERIFFS SALE
To prevent this Sheriffs Sale,you must take Immediate action: sm
1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable
attorney's fees. To find out how much you must pay,you may call:(go 669-5400. A62 C
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if The
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. !JGT
3. You may also be able to stop the sale through other legal proceedings-
You j
You may need an attorney to assert your rights. The sooner you contact one,the more chance you wili'�GT # / qZ�'
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
oTx�xt �
PNC Bank,National Association,et.al.,Plaintiff(s) Service of Process by
VS. APS International, Ltd.
Lisa Goodrich,et.al.,Defendant(s) 1-800-32$-7171
APS INTERNATIONAL APS International Plaza
.7800 Glenroy Rd.
Minneapolis,MN 55439-3122
APS File#: 122012-0002
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES --Robert S.Goodrich
Ms.Henni Crommarty Court Case No.Cumberland Co 11-3494
111 Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
State of. -t L,O P— ss.
County of:
Name of Server: c� , undersigned,being duly sworn, deposes and says
that at the time of service,s/he was of legal age and was not a party to this action;
Date/Time of Service: that on the -20 day of M P-2c,y ,20 � ,at
1\<ES)
o'clock (-� M
Place of Service: at 1713 Atrium Drive , in Sun City Center,FL 33573
Documents Served: the undersigned served the documents described as:
Notice of Sheriffs Sale of Real Property
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Robert S.Goodrich
Person Served,and
Method of Service: ❑ By personally delivering them into the hands of the person to be served.
G� By delivering them into the hands of Li s r�,, C y,KE , a person
of suitable age,who verified,or who upon questioning stated,that he/she resides with
Robert S.Goodrich
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 U o rut LASS S
Approx. Age 5 s ; Approx.Height 5 / S`) ; Approx.Weight 161
VTo 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 Subscribed and sw n to before me thi
that the foregoing is true and correct. S- day o M�( _ . 0 \3
Signature of Server Notary Pub' (Comm issi Expires).
APS International,Ltd.
N�u�q SEAN SESK
• Nfty Pdft•SrN1a st Rammma
My Comm.
''�% i�► 17
COOlMISIN 0 EE SS41?0
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
Ill WOODCREST ROAD,SUITE 200
CHERRY MLL,NJ 08003-3620
856-669-5400
lead' @udren.co
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v Cumberland County
LISA GOODRICH MORTGAGE.FORECLOSURE
ROBERT S.GOODRICH
Defendants)
N0.11-3494
NOTICE OE SKERIFF'S SALE OE REAL PROPERTY / S F R
TO: Robert S.Goodrich 1 a}ATE.. - �-
1713 Atrium Drive ��;_ 11 --
Sun City Center,FL 33573 1 ll{}: �� t
C3 'e ed-rte
Your house(real estate)at 1595 West Lisburn Road,Mechaniicsburg,PA 17055 is scheduled
to be sold at the Sheriffs Sale on June 5,2013 at 10:00am at the Cumberland County
Courthouse,Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce the
count judgment of$392.3S1.02,obtained by Plaintiff above(the mortgagee)against you. If then s
sale is postponed,the property will be relisted for the Next Available Sale.
NQ.=OF OWNER'S WGHTS
YQU MAY BE ABLE TO PREVENT IM SHERII•FS SALE RAM -A AIN
To prevent this Sheriff's Sale,you must take 1mrnedlate a on:
I. The sale will be cancelled if you pay to the mortgagee the back payment,late cbmv,%casts and reasonaffe
attorney's fees. To find out how much you must pay,you may call:(856)X5400.
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. er UIGT
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 WGT «-
have of stopping the sate. (See notice on page two on how to obtain an attorney.)
1WR
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF-
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 fr,
CHERRY HILL,NJ 08003-3620 cW
856-669-5400
pleadings@udren.com rri Xr-
PNC Bank,National Association COURT OF COMMON PLEAS cn
Plaintiff CIVIL DIVISION
v Cumberland County A o-n
LISA GOODRICH, 2 D G
MORTGAGE FORECLOSURE _
ROBERT S. GOODRICH,
Defendant(s)
NO. 11-3494
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
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.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification
to authorities.
Dated: r' UDR N LAW OFFICES,P.C. .
BY: ,
Atto y or a' f
HARRY REESE, ESQUIRE:
A ID 310501
MJU#: 11030678 CASE#: 11030678-1
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
Lisa Goodrich MORTGAGE FORECLOSURE
Robert S. Goodrich
Defendant(s) NO. 11-3494
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:
1595 West Lisburn Road,Mechanicsburg,PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Lisa Goodrich
1713 Atrium Drive
Sun City Center, FL 33573
Robert S. Goodrich
1713 Atrium Drive.
Sun City Center, FL 33573
2. Name and address of Defendant(s) in the judgment:
Lisa Goodrich
1713 Atrium Drive
Sun City Center, FL 33573
Robert S. Goodrich
1713 Atrium Drive
Sun City Center, FL 33573
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
American Express Bank,FSB
200 Vessey Street
New York,NY 10285-1000
Citibank (South Dakota),NA
701 E. 60th Street
Sioux Falls, SD 57117
Capital One Bank
4851 Cox Road
Glen Allen, VA 23060
Citizens Bank of Pennsylvania
443 Jefferson Boulevard
Warwick,RI 02886
Prode Acquisitions,LLC
100 Herricks Road, Suite 200
Mineola,NY 11501
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
Susquehanna Bank
1570 Manheim Pike
PO Box 3300
Lancaster, PA 17604-3300
Susquehanna Bank
c/o Brubaker Connaughton Goss & Lucarelli LLC
480 New Holland Avenue, Suite 6205
Lancaster, PA 17602
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
Monroe Township Municipal Authority
1220 Boiling Springs Road
Mechanicsburg, PA 17055
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:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle,PA 17013
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
1595 West Lisburn Road
Mechanicsburg, PA 17055
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: UDREN LAW OFFICES, P.C.
BY:
Attol d r 1 intiff
HARRY B. ESE, ESQUIRE
MJU#: 11030678 CASE#: 11030678-1 P ID 310501
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
LISA GOODRICH
ROBERT S. GOODRICH; MORTGAGE FORECLOSURE.
Defendant(s)
NO. 11-3494
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
OWNER(S): LISA GOODRICH AND ROBERT S. GOODRICH;
PROPERTY: 1595 West Lisburn Road, Mechanicsburg, PA 17055
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale
on 06/05/2013 at 10:00 AM, 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#: 11030678 CASE#: 11030678-1
Name and
Address ► HENNI CROMMARTY Affix stamp here if issued as
of Sender UDREN LAW OFFICES,P.C. ❑Registered ❑Return Receipt for Check appropriate block for certificate of mailing or for
111 Woodcrest Road,Suite 200 ❑Insured Merchandise Registered Mail: additional copies of this bill.
Cherry Hill,NJ 08003 ❑COD ❑Int'I Recorded Del. ❑With Postal Insurance
❑Certified ❑Express Mail ❑Without postal Insurance Postmark and Date of Recei t
Due Rst.Del.Fee
Line Article Name of Addressee,Street,and Post Office Address Postage Fee Handling Act.Value Insured Sender R.R. S.D. S.H.
Number Charge (If Regis.) Value Fee Fee Fee Remarks
If COD
1 Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle,PA 17013
2 Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle,PA 17013
3 Commonwealth of PA,Department of Revenue
Bureau of Compliance,PO Box 281230
Harrisburg,PA 17128-1230 U1
4 11-3494 Tenants/Occupants
OI M C7
1595 West Lisburn Road 0 p '�
Mechanicsburg,PA 17055 U11 'q Ir
5 American Express Bank,FSB N p 0
200 Vessey Street U. (-
New York,NY 10285-1000 C�,O O ��
C.
6 06/05/2013 Citibank(South Dakota),NA
701 E.60th Street vs
Sioux Falls,SD 57117
125 @H
7 Capital One Bank
4851 Cox Road /\
Glen Allen,VA 23060
8 Citizens Bank of Pennsylvania
443 Jefferson Boulevard
Warwick,RI 02886
9 Susquehanna Bank
1570 Manheim Pike,PO Box 3300
Lancaster,PA 17604-3300
1
10 n ��
ro_
13
14
15
Total number of Pieces Total Number of Pieces Postmaster,Per(Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail.The maximum indemnity payable for the
Listed by Sender Received at St Office reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is$50,000 per piece subject to a limit of
$500,000 per occurrence.The maximum indemnity payable on Express Mail merchandise is$500.The maximum indemnity payable is
$25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,S913,and S921 for limitations of
9 coverage on insured and COD mail.See International Mail Manual for limitations of coverage on international mail.Special handling
charges apply only to third and forth class parcels.
PS Form 3877,February 1994 Form Must be Completed by Typewriter,Ink or Ball Point Pen
Lisa Goodrich- MJU#11030678-1 (Cumberland County)and Robert S.Goodrich—MJU#11030678-1 (Cumberland County)
Name and EI Registered
Address Henrietta Crommarty E]Retum Receipt for Check appropri ate block for Affix stamp here if issued as
of Sender UDREN LAW OFFICES,P.C. ❑Insured Merchandise Registered Mail: certificate of mailing or for
111 Woodcrest Road,Suite 200 COD Intl Recorded Del With Postal Insurance additional copies of this bill.
Cherry Hill;NJ 08003
Certified �Express Mail �Without postal Insurance Postmark and Date of Receipt
Article Handling Act.Value Insured Due R.R. S.D. S.H. Rst.Del.Fee
Line Name of Addressee,Street,and Post Office Address Postage Fee Charge if Regis.) Value Sender Fee Fee Fee Remarks
Number g g If COD
1 11-3494 Prode Acquisitions,LLC
100 Herricks Road,Suite 200
Mineola,NY 11501
2 Monroe Township Municipal Authority
1220 Boiling Springs Road
Mechanicsburg,PA 17055 S° p 1 o W
3 66/05/2013 Susquehanna Bank rn
c/o Brubaker Connaughton Goss&Lucarelli LLC 0 r'° N
480 New Holland Avenue,Suite 6205 z � N
4 Lancaster,PA 17602 0
5 Yw
6
7 F
u
8
+w.
9
10
11
12
13
14
15
Total number of Pieces Total Number of-Pieces Postmaster,Per(Nance of Receiving Employee) The full declaration of value is required on all domestic and international registered mail.The maximum indemnity payable for the
Listed by Sender Received at O Office reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is$50,000 per piece subject to a limit of
$500,000 per occurrence.The maximum indemnity payable on Express Mail merchandise is$500.The maximum indemnity payable is
$25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,S913,and S921 for limitations of
3 coverage on insured and COD mail.See International Mail Manual for limitations of coverage on international mail.Special handling
charges a ly onl to third and forth class parcels.
PS Form 3877,February 1994 Form Must be Completed b Typewriter,Ink or Ball Point Pen
Lisa Goodrich -MJU# 11030678-1 (Cumberland County) and Robert S. Goodrich- MJU# 11030678-1 (Cumberland County)
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.
LISA GOODRICH NO. 11-3494
ROBERT S. GOODRICH; 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:+"
UDREN LAW OFFICES, P.C.
BY:
Atto e P f
HAR B. REESE, ESQUIRE
PA ID`310501
Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s) APS International, Ltd.
VS.
Lisa Goodrich,et.al.,Defendant(s) .1-800-328-7171
APS InggRNATION4L i APS International Plaza
7800 Glenroy Rd.
Minneapolis..MN 55439-3122
APS File#: 122012-0002
AFFIDAVIT OF SERVICE -- Individual
i Service of Process on:
UDREN LAW OFFICES --Lisa Goodrich
' Ms.Henni Crommarty I Court Case No.Cumberland Co 11-3494
1I l Woodcrest Rd.,Ste.200
ICherry Hill,NJ 08003-3620
State of: !—L,o IZ \n A )ss.
County of: 1A
Name of Server: 1��N cvc��� �d Ass ,undersigned, being duly sworn,deposes and says
that at the time of service, s/he was of legal age and was not a party to this action;
Date/Time of Service: that on the -'2o day of Masz.c - ,20 LS.-, at W !�_O o'clock 9M
Place of Service: at 1713 Atrium Drive , in Sun City Center,FL 33573
Documents Served: the undersigned served the documents described as:
Notice of Sheriffs Sale of Real Property
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Lisa Goodrich
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 ,a person
of suitable age,who verified,or who upon questioning stated,that he/she resides with
Lisa Goodrich
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-E_; Skin ColorC . : Hair Color '6\ore ; -iteial-ciai; G- (_ASSEs
Approx. Age S ; Approx. Height S /S!1 ; Approx.Weight i 1"t4D \6s
"")�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 Subscribed and sw to before me thi
that the foregoing is true and correct. %S'—day o 4 .20 (3
Signature of Server Notary Publi (Commissi Expires)
APS International, Ltd.
SEAN SM
NoWy.Pd*-111111116 d ft
my can.Eta�ks S:2017
?,'m- Con mwim#EE lM170
�of� Q
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
III WOODCREST ROAD,SUITE 200
CI KRRY HILL,NJ 08003-3620
856-669-3400
nleadines@udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff I.CIVIL DIVISION
V. { Cumberland County
LISA GOODRICH f MORTGAGE FORECLOSURE
ROBERT S.GOODRICH
Defendant(s)
NO.11-3494 p��
NOTICE OF SHERIFF'S SALE OF REAL PROPE 3 ""ti f 3
SERVED
TO: Lisa Goodrich
1713 Atrium Drive i.AI :F a2C�
Sun City Center,FL 33573 i i�,i
Your house(real estate)at 1595 West Lisburn Road,Mechanicsburg,PA 17055 is scheduled
to be sold at the Sheriffs Sale on June 5,2013 at 10:00am at the Cumberland County
Courthouse,Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce they
court judgment of$22W51.02,obtained by Plaintiff above(the mortgagee)against you. If NES sale is postponed,the property will be relisted for the Next Available Sale. CW
NOTICE OF QWNSR:g RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE RAM
To prevent this Sheriffs Sale,you must take Immediate action: 3=
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)66 -5400. AQs
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. MGT 5 ,s
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 wil�VGT # 1 LIZ"
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
HAm 61 -h
4Tl�
� D
Service of Process by
PNC Bank,National Association,et.al.,Plaintiff(s) APS International, Ltd.
vs.
Lisa Goodrich,et.al.,Defendant(s) 1-800-328-7171
APS I2ITERNATIONAL APS International Plaza
.7800 Glenroy Rd.
Minneapolis,MN 55439-3122
APS File t1: 122012-0002
AFFIDAVIT OF SERVICE -- Individual
A I Service of Process on:
UDREN LAW OFFICES --Robert S. Goodrich
Ms.Henni Crommarty I Court Case No.Cumberland Co 11-3494
1 1 1 Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
State of: rt LC,I?-ti's ` )ss.
County of•
Name of Server: c� , undersigned,being duly sworn,deposes and says
that at the time of service,s/he was of legal age and was not a party to this action;
Date/Time of Service: that on the -:?0 day of 20 �3,at o'clock C�_M
Place of Service: at 1713 Atrium Drive , In Sun City Center,FL 33573
Documents Served: the undersigned served the documents described as:
Notice of Sheriff s Sale of Real Property
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Robert S.Goodrich
Person Served,and
Method of Service•• E-1 By personally delivering them into the hands of the person to be served.
G� By delivering them into the hands of L s P, Gt oeAa-k\Q "Z� ,a person
of suitable age,who verified,or who upon questioning stated,that he/she resides with
Robert S.Goodrich
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-I—: ; Skin Color C ct_ ; Hair Color �\onc� 1?acta� l-t_941S
Approx. Age S s ; Approx.Height 5 �`1 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 Subscribed and sw n to before me thi
that the foregoing is true and correct. 5 day o �, �� 20 \3
Signature of Server Notary Pub'e' (Commissi Expires)
APS International,Ltd.
SEAM SEGM
my COMM.Elt m Jos 8.2017
COnllnitslhm*EE 864170
.00
c n
��oa�
UDREN LAW OMCES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCRE,ST ROAD,SUITE 200
CHERRY BILL,NJ 08003-3620
856-669-5400
ieadin @udren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL.DIVISION
Y. Cumberland County
LISA GOODRICH MORTGAGE FORECLOSURE
ROBERT S.GOODRICH
Defendant(s)
N0. 11-349+1 .,�.,�-� —7—1 1 C1
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ' J E R
TO: Robert S.Goodrich '7:�'f' ' � _ _
1713 Atrium Drive 'I1.1i L \l C{.J��,
Sun City Center,PL 33573
c c 1,Ei'
Your house(real estate)at 1595 West Lisburn Road,Mechanicsburg,PA 17OSS is scheduled
to be sold at the Sheriffs Sale on June 5,2013 at 10:00am at the Cumberland County
Courthouse,Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce the
court judgment of$392.351.02,obtained by Plaintiff above(the mortgagee)against you. If thelfc
sale is postponed,the property will be relisted for the Next Available Sale.
NOVICE OF OWNER'S RIGHTS )) �
)W MAY BE ABLE TO PREVENT THIS SHERIFFS SALE RA," :..a*.-
To prevent this Sheriffs Sale,you must take IMMV ate action;
1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasons 6Ie
attorney's fees. To find out how much you must pay,you may call:(856)669-5440. z .I
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. rr
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 morn chance you will WGT
have of of stopping the sale. (See notice on page two on how to obtain an attorney.)
- eta �-.--�----
:D
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson r r "j-LL'j-
r� i
T' >6�C Sheriff Jar i
Jody S Smith OF U'.6
ri g^t 7
?013 JUL 23 AM
Chief Deputy .
Richard W Stewart CUMBERLAND CUU}�.J_y
Solicitor CGFMEOFTPESKERIFF FENNSYLVIANIA
PNC Bank National Association
Case Number
vs.
Robert Goodrich (et al.) 2011-3494
SHERIFF'S RETURN OF SERVICE
04/01/2013 02:56 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 1595 W. Lisburn Road, Monroe Township,
Mechanicsburg, PA 17055, Cumberland County.
06/05/2013 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, PA on June 5, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Federal National Mortgage
Association, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $1,539.50 SO ANSWERS,
July 02, 2013 RON R ANDERSON, SHERIFF
';z
ic;Coun.ySuite Sheriff,Teleosoft,Inc.
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
Ple dingsAmdren.com
PNC Bank,National Association COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
Lisa Goodrich
Robert S. Goodrich MORTGAGE FORECLOSURE
Defendant(s)
NO. 11-3494
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
PNC Bank,National Associationi 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:
1595 West Lisburn Road,Mechanicsburg,PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Lisa Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, FL 33573
Robert S. Goodrich
218 S.Pebble Beach Boulevard
Sun City Center, FL 33573
2. Name and address of Defendant(s)in the judgment:
Lisa Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, FL 33573
Robert S. Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, FL 33573
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
American Express Bank, FSB
200 Vessey Street
New York, NY 10285-1000
Citibank(South Dakota),NA
701 E. 60th Street
Sioux Falls,SD 57117
Capital One Bank
4851 Cox Road
Glen Allen,VA 23060
Citizens Bank of-Pennsylvania
443 Jefferson Boulevard
Warwick,1102886
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
Susquehanna Bank
1570 Manheim Pike
PO Box 3300
Lancaster,PA 17604-3300
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:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Cumberland County Real Estate Tax Department
I Courthouse Square
Carlisle, PA 17013
Commonwealth of PA,Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg,PA 17128-1230
Tenants/Occupants
1595 West Lisburn Road
Mechanicsburg,.PA 17055
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. see. 4904
relating to unsworn falsification to authorities.
DATED: UDREN LAW OFFICES, P.C.
BY: ELIZABETH L WASSALL, E5�-
Attorn6yYbrPra—intiff PA ID 77788
MJU#: 11030678 CASE#: 11030678-1
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
12leadin,-s c(�udren.com
PNC Bank,National Association I COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
LISA GOODRICH,ROBERT S. MORTGAGE FORECLOSURE
GOODRICH
Defendant(s)
NO. 11-3494
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Lisa Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, FL 33573
Your house(real estate) at 1595 West Lisburn Road,Mechanicsburg,PA 17055 is scheduled
to be sold at the Sheriffs-Sale on June 5,2013 at 10:00am at the Cumberland County
Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013,to enforce the
court judgment of$392.351.02, 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
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
III WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Rleadingsgudrenxom
PNC Bank,National Association COURT OF COMMON PLEAS
I Plaintiff CIVIL DIVISION
V. Cumberland County
LISA GOODRICH,ROBERT S. MORTGAGE FORECLOSURE
GOODRICH
Defendant(s)
NO. 11-3494
NOTICE OF SHERIFFS SALE OF REAL PROPERTY
TO: Lisa Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, FL 33573.
Yourlouse(real estate) at 1595 West Lisburn Road,Mechanicsburg, PA 17055 is scheduled
to be sold at the Sheriffs Sale on June 5, 2013 at 10:00am at the Cumberland County
Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the
court judgment of$392,351.02, 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 SHERIFFS SALE
To prevent this Sheriffs Sale,you must take immediate action:
I. 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 OR PARCEL OF LAND WITH THE IMPROVEMENTS
THEREON ERECTED, SITUATE. IN - MONROE TOWNSHIP, CUMBERLAND
-
COUNTY,PENNSYLVANIA,BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT AN IRON PIN ON THE SOUTHERN LINE OF LISBURN ROAD AT
THE.'CORNER OF PROPERTY NOW OR FORMERLY OF- GEORGE EBENER,• AS
SHOWN ON THE PLAN OF ALLEN PARK,.WHICH PLAN IS RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY IN PLAN
BOOK 22, PAGE 83; THENCE ALONG THE SOUTHERN LINE OF LISBURN ROAD,
SOUTH 65 DEGREES 31 MINUTES 15 SECONDS EAST TWO HUNDRED FIVE AND
TWENTY-SIX ONE-HUNDREDTHS (205.26) FEET TO A POINT; THENCE ALONG
LAND NOW OR LATE OF SKIRO, INC. (LOT 8 ON SAID PLAN), SOUTH 24
DEGREES 28 MINUTES-45 SECONDS WEST, ONE HUNDRED FIFTY AND ELEVEN
ONE-HUNDREDTHS (150.'11) FEET TO A POINT; THENCE ALONG THE SAME)
SOUTH 65 DEGREES 31 MINUTES 15 SECONDS EAST, THIRTY AND EIGHT ONE-
14UNDREDTHS (30.08) FEET TO A POINT; THENCE CONTINUING ALONG:LANDS
NOW OR LATE OF SKIRO, INC., SOUTH 26 DEGREES 35 MINUTES WEST, FIVE
HUNDRED AND ZERO ONE-HUNDREDTHS'(500.00) FEET TO A POINT AT LINE
NOW OR FORMERLY OF WILLIAM E. LEIB; THENCE ALONG THE LATTER,
NORTH 63 DEGREES 25 MINUTES WEST, THREE HUNDRED TWENTY-NINE AND
THIRTY-EIGHT ONE-HUNDREDTHS (329.38) FEET TO A POINT AT LINE OF
LANDS, NOW OR LATE OF GEORGE-EBENER; THENCE ALONG THE LATTER,
NORTH 34 DEGREES 27 MINUTES 20 SECONDS EAST, SIX. HUNDRED FORTY-
SEVEN AND FORTY-EIGHT ONE-HUNDREDTHS (647.48) FEET TO AN IRON PIN,
THE PLACE OF BEGINNING.
CONTAINING 4.108 ACRES.
BEING IMPROVED BY A TWO AND ONE-HALF STORY BRICK DWELLING AND A
WAGON SHED CURRENTLY USED AS A FOUR CAR GARAGE KNOWN AND
NUMBERED AS 1595 WEST LISBURN ROAD, MECHANICSBURG, PENNSYLVANIA
17055.
BEING THE NORTHEASTERN AND GREATER PORTION OF LOT NO. 9 AS
SHOWN ON THE PLAN OF LOTS OF ALLEN PARK, WHICH PLAN IS RECORDED
IN CUMBERLAND COUNTY PLAN BOOK 22,PAGE 83.
UNDER AND SUBJECT, NEVERTHELESS, TO EASEMENTS, RESTRICTIONS,
RESERVATIONS,-CONDITIONS AND RIGHTS OF WAY'OF RECORD.
AS DESCRIBED IN MORTGAGE INSTRUMENT NO. 200746370
BEING KNOWN AS: 1595 WEST LISBURN ROAD,MECHANICSBURG,PA 17055
PROPERTY ID NO.: 22-10-0640-025
TITLE TO SAID PREMISES IS VESTED IN ROBERT S. GOODRICH AND LISA GOODRICH,
HUSBAND AND WIFE BY DEED FROM J.MARSHALL BACHMAN AND PAMELA J. BACHMAN,
HUSBAND AND WIFE DATED 12/14/2007 RECORDED 12/14/2007 IN DEED BOOK INSTRUMENT
#200746369.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWBA*LTH OF PENNSYLVANIA) NO. 11-3494 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 LISA GOODRICH and ROBERTS. GOODRICH
(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,
ZD
(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: $392,351.02 L.L.:
Interest from 3/1/13 to DAte of Sale 615113 Ongoing Per Diem of$55.60 to actual date of sale
including if sale is held at a later date -- $5,393.20
Atty's Comm: Due Prothy: $2.25
Atty Paid: $211.00 Other Costs:
Plaintiff Paid:
Date: 3/1/13
David D.Buell,Prothonotary
(Seat)
Deputy
REQUESTING PARTY:
Name: ELIZABETH L.WASSALL,ESQUIRE
Address: UDREN LAW OFFICES,PC
WOODCREST CORPORATE CENTER
TRUE'COPY FROM RECORD
111 WOODCREST ROAD,SUITE 200 In Testimony whereof,i here unto set my hand
andthe seal ofsaic[C rt at Carlisle,Pa.
and 9u, ,
CHERRY HILL,NJ 08003-3620 This Leff day'of MarCh -201--21—
Attorney for: PLAINTIFF Prothonotary
Telephone: 856-669-5400
Supreme Court ID No. 77788
On March 11, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland,County, PA,
Known and numbered as 1.595 West Lisburn Road,
Mechanisburg, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: March 11, 2013
--
By:
Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2011-3494 Civil CONTAINING 4.108 acres.
BEING IMPROVED by a two and
PNC BANK NATIONAL one-half story brick dwelling and a
ASSOCIATION wagon shed currently used as a four
vs. car garage known and numbered as
ROBERT GOODRICH, 1595 West Lisburn Road,Mechanics-
Lisa Goodrich burg, Pennsylvania 17055.
BEING the northeastern and
Atty.: Mark Udren greater portion of Lot No.9 as shown
ALL THAT CERTAIN tract or par- on the Plan of Lots of Allen Park,
cel of land with the improvements which plan is recorded in Cumber-
thereon erected, situate in Monroe land County Plan Book 22,Page 83.
Township, Cumberland County, UNDER AND SUBJECT, never-
Pennsylvania, bounded and de- theless, to easements, restrictions,
scribed as follows: reservations, conditions and rights
BEGINNING at an iron pin on the of way of record.
southern line of Lisburn Road at the AS DESCRIBED IN MORTGAGE
corner of property now or formerly Instrument No. 200746370.
of George Ebener, as shown on the BEING KNOWN AS: 1595 West
plan of Allen Park,which plan is re- Lisburn Road, Mechanicsburg, PA
corded in the Office of the Recorder 17055.
of Deeds of Cumberland County in PROPERTY ID NO.: 22-10-0640-
Plan Book 22,Page 83;thence along 025.
the southern line of Lisburn Road, TITLE TO SAID PREMISES IS
South 65 degrees 31 minutes 15 VESTED IN Robert S. Goodrich and
seconds East two hundred five and Lisa Goodrich,husband and wife by
twenty-six one-hundredths(205.26) deed from J.Marshall Bachman and
feet to a point;thence along land now Pamela J. Bachman, husband and
or late of Skiro, Inc. (Lot 8 on said wife dated 12/14/2007 recorded
plan), South 24 degrees 28 minutes 12/14/2007 in Deed Book Instru-
45 seconds West, one hundred fifty ment#200746369.
and eleven one-hundredths(150.11)
feet to a point;thence along the same,
South 65 degrees 31 minutes 15
seconds East, thirty and eight one-
hundredths (30.08) feet to a point;
thence continuing along lands now or
late of Skiro,Inc., South 26 degrees
35 minutes West, five hundred and
zero one-hundredths (500.00) feet
to a point at line now or formerly
of William E. Leib;thence along the
latter, North 63 degrees 25 minutes
West,three hundred twenty-nine and
thirty-eight one-hundredths(329.38)
feet to a point at line of lands, now
or late of George Ebener; thence
along the latter, North 34 degrees
27 minutes 20 seconds East, six
hundred fortyseven and forty-eight
one-hundredths (647.48) feet to an
iron pin,the place of BEGINNING.
36
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:
April 12, April 19 and April 26, 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.
_ y
L'Lli-slMarie Coyne, Ed' or
SWORN TO AND SUBSCRIBED before me this
=dav A ril, 2013
otary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.
12020 Technology Pkwy the atr1*otwXews
Suite 300 , - P
Mechanicsburd, PA 17050 Now you know
Inquiries - 717-255-8213
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
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
2011-3494 Ch►u gyp; This ad ran on the date(s)shown below:
P BANK NATIONAL 04/16/13
ASSOCIATION
vs. 0- 04/23/13
R BERT GOODRICH 1 :
Lisa Goodrich y 04/30113
Atty: Mark Udren fa
is 1
ALL THAT CERTAIN TRACT OR t�
PARCEL OF LAND WITH THE'r • • • . . . . . . . . . . . . . . . . . . . .
IMPROVEMENTS THEREON
ERECTED, SITUATE IN MONROE
TOWNSHIP,CUMBERLAND COUNTY, Sworn to and subscribed before a this 13 day of May, 2013 A.D.
PENNSYLVANIA, BOUNDED AND ,
DESCRIBED AS FOLLOWS:
BEGmT Q AT AN IRON PIN ON TIE
SOUTHERN LIVE OF LISBURN ROAD
AT THE CORNER OF PROPERTY NOW a Public
OR FORMERLY OF GEORGE EBENER, i
AS SHOWN ON THE PLAN OF ALLEN .
PARK,WHICH PLAN IS RECORDED IN i
THE OFFICE OF THE RECORDER OF
DEEDS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA
IN FIAN BOOK 22,PAGE 83;THENCE Notarial Seal
ALONG THE SOUTHER LINE OF i Holly Lynn Warfel,Notary Public
LISBURN ROAD,SOUTH 65 DEGREES Washington T r e Dauphin County
31 MINUTES 15 SECONDS EAST TWO My Commission Expires Dec.12,2016
HUNDRED MEMBER,PENNSYLVANIA p55paATION OF NOTARIES
ONE- HUNDREDTHS (205.16) FEET
_'TO A POINT.THENCE ALONG LAND
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Nationial Mtg Assoc is the grantee the same having been sold to
said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 1 st
day of March, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2011
Number 3494, at the suit of PNC Bank N A against Lisa&Robert S Goodrich is duly recorded as
Instrument Number 201324173.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 3 day of
I'du , A.D.
Recorder of Deeds
Recorder of Dee#Cumbefland County,Carlisle,PA
My Commission Expires the First Monday of Jan.2014