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HomeMy WebLinkAbout11-6897MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff a N TAr ", I! c r} ?3 p 1 L zJ ' RLA11t7 COUNTY trli 3SYL\IAWA SUSQUEHANNA BANK 13511 Label Lane Hagerstown, MD 21740 PLAINTIFF V. ERNEST E. BOLTON AND LAURIE A. BOLTON 40 North Enola Drive Enola, PA 17025 DEFENDANTS 28596CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 1 I -Vq ?'V4 CIVIL ACTION - MORTGAGE FORECLOSURE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le ban 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 a sentar 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 a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 O 0'M q'9 -to ?d a44 ctj 9 7 93A aAa ?yqq? THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff SUSQUEHANNA BANK 13511 Label Lane Hagerstown, MD 21740 PLAINTIFF V. ERNEST E. BOLTON AND LAURIE A. BOLTON 40 North Enola Drive Enola, PA 17025 DEFENDANTS 28596CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Susquehanna Bank, successor by merger to Community Banks, corporation organized and existing under state law, with offices for the conduct of business at 13511 Label Lane, Hagerstown, MD 21740. 2. Defendants, Ernest E. Bolton and Laurie A. Bolton are the mortgagors and real owners of premises 40 North Enola Drive, Enola, PA 17025, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Blue Ball National Bank on August 3, 1993, which mortgage is recorded on August 10, 1993 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1156, Page: 436, secured on premises 40 North Enola Drive, Enola, PA 17025 a true and correct description of which is attached hereto as Exhibit I. 4. On July 1, 2005 Blue Ball National Bank Aquired Community Banks as evidenced by Articles of Merger attached hereto as Exhibit Il. 5. On November 17, 2007 Susquehanna Bank acquired Community Banks as evidenced by Agreement and Plan of Merger attached hereto as Exhibit III. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from December 2009 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible. forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 11 / 1 /2009 to 9/1/2011 at $2.37 per diem Accrued late charges to 9/1/2011 Accrued Escrow deficit to 9/1/2011 Corporate Advances Attorney's Fee Total $ 12,371.29 $ 1,587.74 $ 2,958.43 $ 903.09 $ 1,300.00 $ 19,120.55 10. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated prior to the Sheriffs sale, reasonable- attorney's fees will be charged based on work actually performed. 11. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit IV). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $19,120.55, plus per diem interest at $2.37 from September 2, 201,1 to the date of judgment plus costs thereon. Respectfully Su MARTHA E. VON ROSENSTIEL, P.C. B 'Martha E. Von Rosenstiel, Esquire 1 Jacqueline F. McNally, Esquire Attorneys for Plaintiff i VERIFICATION a&4 K ' hereby states that he/she is the AyP LO cr?o,?s MA,V,459E-of Susquehanna Bank, plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Susquehanna Bank and verifies that the statements made in the foregoing Complaint in Susquehanna Bank v. Ernest E. Bolton and Laurie A. Bolton relating to the property located at 40 North Enola Drive, Enola, PA 17025 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. &&VIAU21 BY- Title:AVP- L0? /ONS 14A'VA&E& Susquehanna Bank Dated: LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of land, situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on in the Easterly line of Brick Church Road at the distance of one hundred five (105) feet measured Southwardly along said line of road from its intersection with the Southwesterly extremity of the arc or curve connecting the Southerly line of Perry Street with the Easterly line of Brick Church Road and extending thence North seventy-nine (79) degrees forty (40) minutes East one hundred fifteen (115) feet; thence South ten (10) degrees twenty (20) minutes East twenty five (25) feet; thence South seventy nine (79) degrees forty (40) minutes West one hundred fifteen (115) feet to the Easterly line of Brick Church Road aforesaid; and thence along said road North ten (10) degrees twenty (20) minutes West twenty five (25) feet to the place of beginning. HAVING THEREON ERECTED the Northern half of a double two and one-half story frame, dwelling house known as No. 40 North Enola Drive TAX MAP NUMBER: 09-14-0832-321 / CONTROL #009-002239 200506 7- W ARTICLES OF MERGER MERGER OF BLUE BALL NATIONAL BANK WITH AND INTO COMMUNITY BANKS In compliance with the provisions of Chapter 16 of the Banking Code of 1965, as amended (Title 7, Chapter 16 of Purdon's Statutes), COMMUNITY BANKS, a Pennsylvania banking institution and wholly-owned subsidiary of COMMUNITY BANKS, INC., a Pennsylvania corporation and bank holding company ("CMTY"), and BLUE BALL NATIONAL BANK, a national banking association and wholly owned subsidiary of PennRock Financial Services Corp. ("PRFS"), desiring to effect a merger, hereby state that: 1. The resulting institution will be COMMUNITY BANKS. 2. The registered office of the resulting institution and its principal place of business in the Commonwealth of Pennsylvania is 150 Market Square, Millersburg, Dauphin County, Pennsylvania 17061, 3. The name and the address of the registered office in the Commonwealth of Pennsylvania and the county of venue of each other institution which is a party to the plan of merger is as follows: Blue Ball National Bank, State Route 23 And Township Road 896, Blue Ball, Pennsylvania 17506. 4. The plan of merger shall be effective at 12:02 a.m, on July 1, 2005. 5. The manner in which the plan of merger was adopted by each institution is as follows: Community Banks - At the Board of Directors meeting for Community Banks on November 15, 2004, the directors of Community Banks voted unanimously in favor of the merger. The merger was approved by CMTY as the sole shareholder of Community Banks by execution of a unanimous consent in lieu of meeting effective on November 15, 2004. Blue Ball National Bank - At the Board of Directors meeting for Blue Ball National Bank on November 16, 2004, the directors of Blue Ball. National Bank voted unanimously in favor of the merger. The merger was approved by PRFS as the sole shareholder of Blue Ball National 'Bank by execution of a unanimous consent in lieu of meeting on November 16, 2004. 6. The names and addresses of the first directors of the resulting institution are as follows: 1. Ronald E. Boyer, Alvord Polk Tool Company, P. O. Box 97, Millersburg, PA 17061 2. Thomas M. Bross, 111, Winter Garden Foods, P.O. Box 339, New Oxford, PA 17350 3, Eddie L. Dunklebarger, 750 East Park Drive, Harrisburg, PA 17111 4. Harry E. Filbert, Jr., 77 Airport Road, Hazleton, PA 18202 5. Lewis M. Good, 433 Orchard Road, Mohnton, PA 19540 6. Wayne D. Hill, Gettysburg Construction, P. O.. Box 3036, Gettysburg, PA 17325 1 imro AGREEMENT AND PLAN OF MERGER This AGREEMENT AND PLAN OF MERGER, dated as of July 25, 2007 (this " Meraer Asmcrntenf% pursuant to the Pennsylvania Banking Code of 1965, as amended (the "PA BL Code" 3, is entered into by and between Susquehanna 13an1t PA, a bank and trust. company organized under the PA Banking Code, having its principal office at 9 East Main Street, Lititz, PA 17543 and baarrch offices at the locations specified in Schedule hereto Clyauehanm Bank PAD, and CommunityBoks, a bank organized under the PA Banking Code having its principal office at 150 Market Square, Millersburg, Pennsylvania i 7061 and branch offices at the locations specified its h e 2 hereto (" -QmmunitvR1WU'7. WHEREAS, Susquehanna Bancshares, inc., a Pennsylvania corporation and the parent company of Susquehanna Bank PA ("Parent"), and Community Banks, Inc., a Pennsylvania corporation and the parent company of CommuniiyBanks (the "Companv'?, have entered into an Agrc MI :t and Plan of Merger, dated as of April 30, 2007 (the "Iso dirg_Cgmnan=• Mcrster A LMmeat"), providing Far the merger of the Company with and into Parent (tha ter er'"); and WHEREAS, the Holding Company Merger Agreement requires Parent and the Company to execute :his Bwik Merger Agreement which provides for the merger (the "Bar l )Ier; er"} of Communir,,Banks with and into Susquehannna Bank PA in accordance with the PA Banking Code, and to cor.vuntmate the trans=ticrs contemplated hereby immediately ii7lluwing the consummation of the Parent :Merger. NOW, THEREFORE, in consideration of the mutual covenants, representations, warranties and agreements contained herein, and intending to be legally bound hereby, the parties agree as follows: ARTICLE 1 THE BANK MERGER E 1.1 The 80k. Me1go . The constituent entities to the Bank Merger (the "Constituent BatdCS"} shall be Susquehanna Bank PA and CommunityBanks. Subject to the terms and conditions of this Bank Merger Agreement and the Holding Company Merger Agr•ment, in accordance with Chapter 16 of the PA Banking Code, at the Effective Time (as defined in Section 1.2 hereof), CommunityBanks shall merge with and into Susquehanna Bank PA. Susquehanna Bank PA shall be the surviving entity (sometimes referred to herein as the "ggt eNiag Bank"} of the Bank Merger and shall continue its vistence as a Pennsylvania state chartered bank and trust company following consummation of the Batik Merger. Upon consummation of the Bank :Merger, the separate existence of CommunityBanks shall cease. 1.2 Ef#'ecrixe Time. Subject to the provisions of this Bank Merger Agreement and the Holding Company Merger Agreement, following the execution of this Bank Merger Agreement, the parties shall duly prepare, execute and submirto the Department of Banking (the I wnV-633323 S EXHIBIT ,-ZT d ? VA t, Susquehanna Bank CERTIFIED MAIL 74101870 00021489 6905 Date: January 6, 2011 TO: Ernest E Bolton h 7" ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in tl:e attached pages. The HOMEOWNER'S EMERGENCYMORTGAGE 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 WITHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. Ifyou have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342.2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fli nd a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SCANNED 2459591-1 JUL 13 201 EXH181j HOMEOWNER'S NAME(S) PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: Ernest E Bolton and Laurie A Bolton 40 N Enola Drive, Enola, PA 17025 XX038139 Blue Ball National Bank CURRENT LENDERISERVICER: Susquehanna Batik CONTACT PERSON: Debra -- --__._.......... _ .. . ..._._................ _ PHONE NUMBER: 888-722-7270 Ext 1552 E-MAIL ADDRESS: Debra Carbau h(c sus uehai na net HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH C:4N SA VE YOUR HOME FROM FORECLOSURE AND HELP YOU MADE 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. TEMPOR4RYSTAYOF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During; that time you must arrange and attend a "face-to-face" meeting with one ofthe consumer credit counseling agencies listed at the end of this Notice, THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS' OF THE DATE OF THIS NOTICE. fF )OU DO NOT APPLY FOR EMERGE NGY MORTG.-IGE AS.S1,57ANC"E, YOU 11'iT BRIi1 G YOUR MORTGAGE UP TO DATE. TIIF. P,,IRT OF THI.5,VOTICE C„4LLED "IJOW TO CURE YC)UR ,AORTGAGE DEF,.4ULT"; E.VPLAI,VS IIOW TO BRI,'VCi YOUR i4ORTC%4GE UP TO D,4 TE. CONSUMER CREDIT COUNSELING AGENCIES--If?you meet with one oj`the c°onsunier credit counseling agencies listed at the end of this notice, the lender naayt NOT take action agrainst you for thirty= (10) dgvs after the date of this meeting. The names, addresses and telcyhone nunibe s of designatecd consumer credit counseling agencies for the county in which 245`rSl) f -1 the property is located fire set forth at the end of this Alotice. It is only necessar v to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in def cult frnr the reasons set forth later in this Notice (see following pages ft)r spedfie iii formation about the nature of Your default). You have the right to apply=forfincanciul assistance from the Homeowner's Emergency Aforigage .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 (it the end of this Notice, Ott/' = consumer Credit counseling'It,'i'Mu ie•s have erpplicationsfor the program and they will assist 1,011 in .sz.zl iniaing a complete application to the Pennsylvania Ilousing Finance Agency-. To tc=inporaril'v stop the lender ftoin sting a foreclosure action, your application e' U.5T be forwurded to PII1,"a,1 aizd received within thirty- (30) clays of your face-to-fizee meeting with the counseling agency.. YOU SHOULD FILE A HEMAP A PPLICA TION 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 APPLICA TION WITH PHFf1 WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL RE TEMPORARILY PREVENTED FR 011 STARTINGA FORECL OS VRE A GAINS T YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY ST.A Y OF FORECLOSURE. " YOU HA VE THE RIGHT TO FILE A HEMAP APPLICA TION EVEN BEYOND THESE T I M E P E R I O D S : A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. ,AGEAICYACTION--Availaable funds for emergency mortgage assistance are very limited. They will he disbursed by the Ai;c rrc?y' under the eligibility criteria established bythe Act. The Pennsylvania Housing Finance Agency has sixty, (60) days to make a decision after it receives Your application, Luring that time, no,foreclosure proceedings will be pursued against 'vou if" You have met the dine requirements set forth above. You will be notified directly liv the Pennsylvania :dousing Finance Agency of its decision on your application.. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONL YAND SHOULD NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THE DEBT. (If'y'vu have filed bankruptcy you can still apply for Emergency Mortgage Assistance 2454501-1 HOW TO CURE YOUR MORTGAGE DEFAULT fflrin it u to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 40 N Enola Drive, 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: December 1, 2009 thru January 1, 2011 Principal Amount Due: Interest Amount Due: Attorney Fees: Appraisal Fees: Title Search: Force Placed Insurance: Escrow Due: Late Charges: $ 4,024.52 $ 859.94 $ 875.69 $ 20.00 $ 0.00 $ 0.00 $ 1,895.77 $ 0.00 $ 0.00 TOTAL AMOUNT PAST DUE: $ 7,675.92 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable.) HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,675.92, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be trade either by cash, cashier's check, certified check or money order made payable and sent to: Susquehanna Bank C/o Susquehanna Loan Center P.O. Box 639 Maugansville, MD 21767-0639 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 2459591-1 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 (30) 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 begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 4 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 be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Susquehanna Bank Address: CIO Susquehanna Loan Center, P.O. Box 639, Maugansville, MD 21767-0639 Phone Number: 888-722-7270 ext. 1552 Fax Number: 240-313-1563 Contact Person: Debra E-Mail Address: Debra.Carbaugh@susquebanun.net 2459591-1 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 not 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. (Rev.9/2008) CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ATTACHED 2459591-1 HEMAP Consumer Credit Counseling Agencies Report last updated: 1/312011 9:56:25 AM St. Martin Center American Credit Counseling Institute 1701 Parade Street 6800 Market Street Erie, PA 16503 1st Floor 814.452.6113 Upper Darby, PA 19082 8882112.6741 CUMBERLAND County American Credit Counseling Institute CCCS of Western PA 175 Strafford Avenue 2000 Linglestown Road Suite 1 Harrisburg, PA 17102 Wayne, PA 19087 888.511.2227 610.971.2210 Community Action Commission of Capital Region 888.212.6741 1514 Deny Street American Credit Counseling Institute Harrisburg, PA 17104 526-528 Dekalb Street 717.232.9757 Norristown, PA 19401 Maranatha 610.971.2210 43 Philadelphia Avenue 888.212.6741 Waynesboro, PA 17268 American Credit Counseling Institute 717.762.3285 6800 Market Street PA Interfaith Community Programs Inc 1st Floor 40 E High Street Upper Darby, PA 19082 Gettysburg, PA 17325 888.212.6741 717.334.1518 American Financial Counseling Services Inc. PHFA 175 Strafford Avenue 211 North Front Street Suite One Harrisburg, PA 17110 Wayne, PA 19087 717.780.3940 267.228.7903 800.342.2397 800.490.3039 DAUPHIN County American Financial Counseling Services Inc. 405 West Germantown Pike CCCS of Western PA Norristown, PA 19403 2000 Linglestown Road 267.228.7903 Harrisburg, PA 17102 800.490.3039 888.511.2227 American Financial Counseling Services Inc. Community Action Commission of Capital Region 1080 N. Delaware Avenue 1514 Derry Street Suite 200 Harrisburg, PA 17104 Philadelphia, PA 19125 717.232.9757 267.228.7903 800.490.3039 PHFA 211 North Front Street American Red Cross of Chester Harrisburg, PA 17110 1729 Edgemort Avenue 717.780.3940 Chester, PA 19013 800.342.2397 610.874.1484 DELAWARE County APM 600 W Diamond Street Advocates for Financial Independence Philadelphia, PA 19122 1503 Wadsworth Ave 215.235.6070 Philadelphia, PA 19150 (267) 9534615 267-323-2698 Carroll Park Community Council, Inc. 5218 Master Street Philadelphla, PA 19131 215.877.1157 Page 8 of 21 Susquehanna Bank CERTIFIED MAIL 70101870 0002 1489 6912 Date: January 6, 2011 TO: Laurie A Bolton t )jeo 116 L ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCYMORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see ifHEMAP can help, you must MEET WITHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with tire Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, yore may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO`N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SCANNED 2459591-I JUL 13 2011 HOMEO IER'S NAME(S): Ernest E Bolton and Laurie .A Bolton PROPERTY ADDRESS: 40 N Enola Drive, Enola, PA 17025 LOAN ACCT. NO.: XX038139 ORIGINAL LENDER: Blue Ball National Bark ,._..._ CURRENT LENDER/SERVICER: Sussueh.anna Bank (.ONTACT PERSON: Debra _ PHONE NUMBER: 888-722-7270 Ext 1552 E-MAIL ADDRESS: Debra Carbaugh(a,sus tichanna net HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VE 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. TE.ffP0R.9RYST4 YOF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for nailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. 7111S AfEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF r'O(I l)O.1VOT APPLY FOR .F..YIFRGFNCY XfORTGAGE : tSSISTANC'F, YOU MUST BRING YOUR !1rfORTG,1GC: UI" TO DATE. THE PART OF THIS NOTICE C11ILLED "HOW TO CURE, YOUR _AORTGAGE DEF:4 ULT", EXPLAINS HOW TO BRING YOUR AtORT6AGI UP TO D.4 TE. CONStfAtER 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 rag ainst you for thiq (30) stays aver- the date of this meeting, The names, acldre:sses and telephone numbers cif designatcd consumer credit counseling; cal;encie for the counth in which the property, is located acre set forth at the end of this Notice, It is onfy necessary to schedule one fcace-to-f cc e meeting. Advise your lender immediately gfyour- intentions. APPLICA TION FOR MORTGAGE ASSISTANCE-Your mortgage is in defeauIt, fin- the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to taPply for financial assistance from the Homeowner's Ernergencv Mortgage Assistance Program. To do so, you must fill out, sign and files ca completed Homeowner's Emergency Assistance Program Application kvith 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 thcv will assist You rra submitting a complete application to the Pennsylvania Housing Finance, Agency. To temporarily stop the lender from filing a foreclosure action, your application tlfU T be forty+-,arded to PH -",.4 and received within thirty (30) dU, of your4fiace-to-face meeting with the counseling agc?racI YOU SHOULD FILE A HEMAP APPLIC9 T ION AS SOON AS POSSIBLE. IF YOU 11A VE A 41EETING WITHA COUNSELING A GENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF T11A TMEETING, 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 H.A VE THE RIGHT TO FILE A HEM.AP APPLICATION EDEN BEYOND THESE TLYIE 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 HE STOPPED. AGENCYACTION=-Available finds for emergency mortgage assistance care very, limited. They will be disbursed b1 the Agenev under- the eligibility criteria established 1y the Act. The Pennsylvania Housing Finance Agency has sixty (6v) days to make a decision a4ter it receives your application. During that time, no foreclosure proceedings will he pursued against you if You have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finances Agency cif its decision on.vour application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THE DEBT. (If you Rave filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 40 N Enola Drive, Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following arnounts are now past due: December 1, 2009 thru January 1, 2011 Principal Amount Due: Interest Amount Due: Attorney Fees: Appraisal Fees: Title Search: Force Placed Insurance: Escrow Due: $ 4,024.52 $ 859.94 $ 875.69 $ 20.00 $ 0.00 $ 0.00 $ 1,895.77 $ 0.00 Late Charges: $ 0.00 TOTAL AMOUNT PAST DUE: $ 7,675.92 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable.) HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,675.92, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Susquehanna Bank C/o Susquehanna Loan Center P.O. Box 639 Maugansville, MD 21767-0639 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 2459591-1 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 lase the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within TIl IRTY (30) 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-=I"he mortgaged property will be sold by the Sheriff to pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cur.. the delinquency before the lender begins legal proceedings against you, you will still be regUired to pay the reasonable attorney's fees that were actually incurred, tip to 550.00. However, i f 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 niay also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REINIEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums clue under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheri ffs Sale. You may do so by paying 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 4 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 be by contacting; the lender. HOW TO CONTACT THE LENDER: Name of Lender: Susquehanna Rank Address: C/O Susquehanna Loan Center, P.O. Box 639, Maugansville, NID 21767-0639 Phone dumber: 888-722-7270 ext. 1552 Fax Number: 240-313-1563 ............ _. ..... _ . Contact Person: Debra E-;Mail Address: Debra.Carbaugh sasguehanna.net 2 45059 1, 1 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 Iender at any time. ASSUMPTION OF MORTGAGE--You may not 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. (Rev.9/2008) CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ATTACHED 2459591-1 HEMAP Consumer Credit Counseling Agencies l Report last updated: 113/2011 9:56:25 AM St. Martin Center American Credit Counseling Institute 1701 Parade Street 6800 Market Street Erie, PA 16503 1st Floor 814.452.6113 Upper Darby, PA 19082 888.212.6741 CUMBERLAND County American Credit Counseling Institute CCCS of Western PA 175 Strafford Avenue 2000 Linglestown Road Suite 1 Harrisburg, PA 17102 Wayne, PA 19087 888.511.2227 610.971.2210 Community Action Commission of Capital Region 888.212.6741 1514 Deny Street American Credit Counseling Institute Harrisburg, PA 17104 526-528 Dekalb Street 717.232.9757 Norristown, PA 19401 610.971,2210 Maranatha 888.212.6741 43 Philadelphia Avenue Waynesboro, PA 17268 American Credit Counseling Institute 717.762.3285 6800 Market Street PA Interfaith Community Programs Inc 1st Floor Upper Darby, PA 19082 40 E High Street 888.212.6741 Gettysburg, PA 17325 717.334.1518 American Financial Counseling Services Inc. 175 Strafford Avenue PHFA Suite One 211 North Front Street Wayne, PA 19087 Harrisburg, PA 17110 267.228.7903 717.780.3940 800.490.3039 800.342.2397 American Financial Counseling Services Inc. DAUPHIN County 405 West Germantown Pike CCCS of Western PA Norristown, PA 19403 2000 tinglestown Road 267.228.7903 Harrisburg, PA 17102 800.490.3039 888'511'2227 American Financial Counseling Services Inc. Community Action Commission of Capital Region 1080 N. Delaware Avenue 1514 Deny Street Suite 200 Harrisburg, PA 17104 Philadelphia, PA 19125 717.232.9757 267.228,7903 800.490.3039 PHFA 211 North Front Street American Red Cross of Chester Harrisburg, PA 17110 1729 Edgemonl Avenue 717.780.3940 Chester, PA 19013 800.342.2397 610.874.1484 DELAWARE County APM 600 W Diamond Street Advocates for Financial Independence Philadelphia, PA 19122 1503 Wadsworth Ave 215235.6070 Philadelphia, PA 19150 (267) 9534615 267-323-2696 Carroll Paris Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 215.877.1157 Page 8 of 21 Bmff Prothonotary Office offh^-^nth~y(h-y^ /`�y�6 County, _ /' - —'/''_'-- '~rk,—.--'-o`—~Q Solicitor �� �oR��«��� CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28r* DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite 0D e TA 0 (Phone D7240'6195 0 Toc7272406573