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Home My WebLink About11-4734i GQLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET Ci r r f iLLCIJ!?-LFFIIu±? _ PHILADELPHIA, PA 19106 OF' THE P JR O T E { 01`s !0-',r(866) + 5 f 413-2311 PNMAC MORTGAGE CO., LLC 27001 Agoura Road Suite 350 Calabasas, CA 91301 CUMBERLAND COUN - PENNSYLVANIA Plaintiff AMY B. GILMORE KEVIN R. GILMORE vs. Mortgagor(s) and Record Owner(s) 449 North 2nd Street Enola, PA 17025 Defendant(s) NOTICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE I) - Y-/* 0/V0 FORpr! f-" ® A?ft)RTCqrE 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 the 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 claim in the Complaint of 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 OR CANNOT AFFORD ONE, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en ]as 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 defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades It 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 SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Pd. #&a h* 10 slJ3?s? SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.i)hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www. hip 'ladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 107701FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNMAC MORTGAGE CO., LLC, 27001 Agoura Road, Suite 350 Calabasas, CA 91301. 2. The name(s) and address(es) of the Defendant(s) is/are AMY B. GILMORE, 449 2nd Street, Enola, PA 17025 and KEVIN R. GILMORE, 449 2nd Street, Enola, PA 17025, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. On April 20, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR WILMINGTON FINANCE, INC., ITS SUCCESSORS AND ASSIGNS, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on April 27, 2006 as Book 1948 Page 1434. The mortgage has been assigned to: PNMAC MORTGAGE CO., LLC by assignment of Mortgage. The assignment of mortgage was recorded on May 9, 2011 as Instrument # 201113363. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 01, 2010 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$84,736.72 Interest from 03/01/2010 through 03/22/2011 at 8.3750% .......................$7,635.51 Per Diem interest rate at $19.73 Late Charges from 04/01/2010 to 03/22/2011 .............................................$458.71 Monthly Escrow amount $107.07 Escrow Balance Deficit .............................................................................$3,634.26 Reasonable Attorney's Fee .......................................................................$1.300.00 $97,765.20 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail on April 26, 2011, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $97,765.20, together with interest at the rate of $19.73, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBLCI-)&CCLAFFEBTA/ & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff VERIFICATION I, -rod ?1 GYGty? as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. Date: 1A #107701FC - AMY B. GILMORE and KEVIN R. GILMORE 449 North 2nd Street Enola, PA 17025 E.rs, hibit A Sdudmk C Legal Description ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and as described as follows, to wit: BEGINNING at a point on the Eastern line of North Second Street, at the Southern line of laud now or late of Thomas McKinsey; thence along said land, North 54 degrees 26 minutes East two hundred ten and thirty-three one-hundredths (210.33) feet to a point on the Western side of Hill Street; thence along said Street, South 29 degrees 34 minutes East forty-two and sixty one-hundredths (42.60) feet to .a point; thence South 54 degrees 26 minutes West two hundred five and four one-hundredths (205.04) feat to the Eastem line of North Second Street; thence along North Second Street North 36 degrees East forty-two and twenty one-hundredths (42.20) feet to a point the place of BEGINNING. HAVING thereon erected a two story frame dwelling house, known and numbered as No. 449 North Second Street, Enola (erroneously stated as West Fairview in prior deed), Pennsylvania. BEING Parcel No. 45-16-1049-039 i Certify this to be recorded in Cumberland County PA Recorder of Deeds i E.r,Fii6it ?B QnyMij P.O. Box 60 11 Agoura Hills, CA 91376-6011 April 26, 2011 KEVIN R GILMORE AMY B GILMORE 449N2NDST ENOLA PA 17025 Re: Loan Numbe 449N2NDST ENOLA PA 17025 Dear KEVIN R GILMORE & AMY B GILMORE: ACT 91NOTICE DATE OF NOTICE: April 26, 2011 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP)may be able to help to save your home This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. This is an The name, address and phone number of Consumer Credit Counseling Aizencies serving your County are listed at the end of this Notice If you have any questionsyou may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869 ) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su casa. Si no comprende el contenido' de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania, Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cuai puede salvar su casa de la perdida' del derecho a redimir su hipoteca. Date: April 26, 2011 Homeowners Name: KEVIN R GILMORE & AMY B GILMORE EN OLA PA 17025 Property Address: 46WW Loan Account No.: Original Lender: WILMINGTON FINANCE INC. Current Lender/Servicer: Penny Mac Loan Services HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (33) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania forecl xty osure ) days to make a decision after it Duringtbat time, no Agency your application.o g proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CUR tEMPLY PROTECTED BY THE FILING` OF A PETITION IN BANKftUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR. INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fded bankruptcy you can still apply for Emergency Mortgage Assistance.) This is an HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 449 N 2ND ST ENOLA PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 04/01/2010 thru 04/01/2011 (9mos. At $775.93/month) $ 6,983.37 (4mos. At $981.87/month) $3,927.48 (b) Accrued late charges $492.10 (c) Other charges; Bad Check Fees $00.00 (d) Other provisions of the mortgage obligation, if any $461.50 (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $11,864.50 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $11,864.50 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-THREE (33) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: PennyMac Loan Services 27001 Agoura Road Suite #350 Calabasas, CA 91301 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY- THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY -THREE (33) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY-THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at an time up to one hour before the Sheriffs Sale. You may do so by pang the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four 4 to six 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PENNYMAC LOAN SERVICES LLC Address: 27001 Agoura Rd Suite 350, Calabasas, CA 91301 Phone Number: (866) 545-9070 Fax Number: (818)224-7410 or (866)545-9070 Contact Person: Todd Graves EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVICNG YOUR COUNTY Germantown Settlement Acorn Housing Corporation 218 W. Chelten Avenue Philadelphia, PA 19144 Acorn Housing Corporation 846 North Broad Street Philadelphia PA 19130 Phone: (215) 765-1221 (215) 849-3104 HACE American Credit Counseling Institute 167 W Allegheny Avenue Coatsville, PA 19320 American Credit Counseling Institute 845 Coates Street 2"d Floor Philadelphia PA 19140 Phone: (888)212-6741 This is an (215)426-8025 CONSUMER CREDIT COUNSELING AGENCIES SERVICNG YOUR COUNTY American Credit Counseling Institute Housing Association of Delaware Valley 530 West Street Road Suite 201 Warminster, PA 18974 American Credit Counseling Institute Housing Association of Delaware Valley 1500 Walnut Street suite 601 Philadelphia 19102 Phone: (215) 444-9429 (215) 545-6010 American Financial Counseling Services, Inc. Housing Association of Delaware Valley 175 Stafford Avenue, Suite One Wayne, PA 19087 American Financial Counseling Services, Inc. Housing Association of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 Phone: (800) 490-3039 (215) 978-0224 APM Northwest Counseling Service 2147 North Sixth Street Philadelphia, PA 19122 Northwest Counseling Service 5001 North Broad Street Philadelphia PA 19141 Phone: (215)235-6788 (215)324-7500 This is an Carroll Park Community Council, Inc., Phila Council for Community Advancement 5218 Master Street Philadelphia, PA 19131 Phone: (215)878-2722 (215)877-1157 CONSUMER CREDIT COUNSELING AGENCIES SERVICNG YOUR COUNTY CCCS of Delaware Valley Phone: (215)567-7803 Catholic Social Services Building Southwest Community Development Corporation 7340 Jackson Street Philadelphia, PA 19136 Catholic Social Services Building Southwest Community Development Corporation 6328 Paschall Avenue Philadelphia, PA 19142 Phone: (215) 563-5665 (215) 729-0800 CCCS of Delaware Valley Urban League of Philadelphia 1801 Market Street Suite 250 Philadelphia, PA 19103 Phone: (215)561-6070 (215)563-5665 CCCS of Delaware Valley 1515 Market Street Suite 1325 Philadelphia, PA 19107 Phone: (215) 563-5665 Chester Community Improvement Project 412 Avenue of the States P.O. Box 541 Chester, PA 19016 Phone: (610) 876-3449 This is an atteir Diversified Community Services Dixon House 1920 South 20th Street Philadelphia, PA 19145 Phone: (215) 336-3511 We attempted to contact you on numerous occasions via phone and mail, but have not heard from you. You have not paid your loan under the terms of the promissory note and mortgage instrument for the real estate loan identified above. If we do not receive full reinstatement within 30 days from the date of this letter, we will proceed with foreclosure and will accelerate the loan balance without further notices to you. You will be required to pay all reasonable costs incurred by us in pursuing our foreclosure rights, including trustee's fees, cost of title evidence, attorney fees and other applicable costs. In addition, please be advised: • Your loan with Penny Mac Loan Services is in Default due to non-payment of the installment due on April 1, 2010 and all subsequent installments. • As of the date of this letter, your delinquency is $11,864.50, which includes any accrued fees. If any other installments or fees are due at the time you cure this Default, they will be added to the total delinquency amount stated above. • To cure this Default, you must pay with check, money order or by Western Union Quick Collect funds, the full amount stated above. We can help, but you MUST call us: Our Loan Specialists stand ready to help you resolve this issue. We have numerous programs to help you with your payment and/or past due amount. We urge you to contact our Loan Specialists toll free at (866) 545-9070 for assistance immediately. Sincerely, Additional Notes: • Any partial payments you have made have been taken into account when calculating the total delinquency. Acceptance of these payments by us does not constitute a cure of the Default. • Regardless of our rights to take action, you have the right to reinstate the loan at any point after acceleration as set forth in the mortgage instrument. • In addition, you may wish to consult a credit counseling agency to assist you. For more resources, please go to the "Helpful Websites" section of our website (www. PennyMacUSA.com) or you can access a local HUD-approved counseling agency by calling their toll free hotline at (800) 569-4287. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 4?tititt;, of 't':arru(,?r.?r r+d ;-1 LU-iJl IL, ?i _ ..rt?.1 s 2,311 JUN 14 AM 10- PENNSYLV it""I PNMAC Mortgage Co., LLC vs. Kevin R Gilmore (et al) Case Number 2011-4734 SHERIFF'S RETURN OF SERVICE 06/07/2011 07:02 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2011 at 1902 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kevin R. Gilmore, by making known unto himself personally, at 1449 N. Second Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. MI AEL BARRICK, DEPUTY 06/07/2011 07:02 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2011 at 1902 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Amy B. Gilmore, by making known unto Kevin R. Gilmore, Husband of Defendant at 1449 N. Second Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. r ? HA L BARRICK, D U SHERIFF COST: $59.00 June 08, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ?ci u7 ?JUdn ? P•'f. iFl ,6•I f ??,. GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF PNMAC MORTGAGE CO., LLC 27001 Agoura Road Suite 350 Calabasas, CA 91301 Plaintiff vs. AMY B. GILMORE KEVIN R. GILMORE 449 North 2nd Street Enola, PA 17025 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY MCD C -t ca' o z 0 v o mac' s? ?C) Zp C = ? > = Q By: GOLDBE AFFER Y & MCKEEVER Michael McKeever a. 129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 4/d,60!'t t 93 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2011-04734 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?gtti?'lit, ?t ?[UpG,?r/,rrb FILED-OFFICE 4r.IF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 JUL I I AM 11: 21 CUMBERLAND COUNTY PENNSYLVANIA PNMAC Mortgage Co., LLC Case Number vs. Kevin R Gilmore (et al.) 2011-4734 SHERIFF'S RETURN OF SERVICE 07/05/2011 06:19 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2011 at 1819 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Amy B. Gilmore, by making known unto herself personally, at 551 Valley Street, Summerdale, Cumberland County, Pennsylvania 17093 its contents and at the same time handing to her personally the said true and correct copy of the same. ,-&a I -r'ub? AMANDA COBAUGH, DEP SHERIFF COST: $44.00 July 06, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF fc1 Coun'ySuite She-llf rebo'o`t In:: KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 PNMAC MORTGAGE CO., LLC 27001 Agoura Road Suite 350 Calabasas, CA 91301 Plaintiff vs. AMY B GILMORE KEVIN R. GILMORE (Mortgagor(s) and Record owner(s)) 449 North 2nd Street Enola, PA 17025 Defendant(s) i-70-OF iC?: , L f 0TH0NQTAR'f' N12 in 25 AM I1: 00 PEN Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 2011-04734 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff PNMAC MORTGAGE CO., LLC 27001 Agoura Road Suite 350 Calabasas, CA 91301 Plaintiff vs. AMY B GILMORE KEVIN R. GILMORE (Mortgagor(s) and Record Owner(s)) 449 North 2nd Street Enola, PA 17025 Defendant(s) CERTIFICATE OF SERVICE No. 2011-04734 Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on ' ?..7'1 AMY B GILMORE 551 Valley Street Summerdale, PA 17093 KEVIN R. GILMORE 449 2nd Street Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AMY B. GILMORE 449 2nd Street Enola, PA 17025 KML LAW GROUP, P.C. F/K/A GOLD PECK McCAFFERTY & McKEEVER n, By: ? Z Angela M. Smith, Legal Assistant asmith@kmllawgroup. com 215-825-6325 (Direct Phone)