HomeMy WebLinkAbout11-7442' PHELAN HALLINAN & SCHMIEG, LLP
Allison F. Wells, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
280158
LOANCARE, A DIVISION OF FNF SERVICING,
INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff ll ff
V. NO.
DEAN P. HOFFMAN AXIA DEAN PAUL HOFFMAN CUMBERLAND COUNTY
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
Defendant
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 280158
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NOTICE
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, (JO 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 ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File #: 280158
Plaintiff is
LOANCARE, A DIVISION OF FNF SERVICING, INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
2. The name(s) and last known address(es) of the Defendant(s) are:
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 06/12/2009 DEAN P. HOFFMAN made, executed and delivered a mortgage upon the
premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INCORPORATED AS A NOMINEE FOR LEND AMERICA which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Instrument No. 200922950. The PLAINTIFF is now the mortgagee and is in
the process of formalizing an assignment of same. The mortgage and assignment(s), if
any, are matters of public record and are incorporated herein by reference in accordance
with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach
documents to pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 03/01/2011 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 280158
6. The following amounts are due on the mortgage as of 10/01/2011:
Principal Balance $259,312.30
Interest $9,467.12
02/01/2011 through 10/01/2011
Late Charges $393.45
Escrow Deficit $670.99
TOTAL $269,843.86
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$269,843.86, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLIN
fills, Es wire
Attorney for Plain i
File #: 280158
LEGAL DESCRIPTION
ALL THOSE CERTAIN tract or parcel of land premises, situate, lying and being in the township
of Hampden in the county oil Cumberland and commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the north side of Golfriew drive at the dividing line between lots nos.
376 and 377 of the hereinafter mentioned plan, said point being 125.04 feet west of the
intersection of Golfview drive and Kent drive; thence along the north side of Golfview drive
north 79 degrees 33 minutes 40 seconds west a distance of 65.05 feet to a point; thence along the
same by a curve to the left having a radius of 590.00 feet, an arc length of 33.95 feet to a point at
lot no. 378; thence along lot no. 378 north 07 degrees 08 minutes 31 seconds east a distance of
162.67 feet to a point at :lands now or formerly of Hampden square Ltd.; thence along said laud
now or formerly of Hampden Square Ltd. north 75 degrees 21 minutes 49 seconds east a distance
of 37.57 feet to a point; thence along the same south 37 degrees 33 minutes 40 seconds east a
distance of 100.00 feet to a point at lot no. 376; thence along lot no. 376 south 10 degrees 26
minutes 20 seconds west a distance of 110.44 feet to a point, the place of beginning.
CONTAINING 15,717 square feet.
PROPERTY ADDRESS: 3602 GOLFVIEW DRIVE, MECHANICSBURG, PA 17050-2216
PARCEL # 10-17-1037-099-
File #: 280158
VERIFICATION
The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that
Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the
time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to
Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure
are based upon information supplied by.Plaintiff and are true and correct to the best of my knowledge,
information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon
receipt.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S.
Sec. 4904 relating to unsworn falsifications to authorities.
DATE: 7 r
'.'Uf'13ERL ND Coli1j l
F'EN SYLVANI:
PHELAN HALLINAN & SCHMIEG, LLP
BY: Joseph P. Schalk, Esquire
Identification No.: 91656
Mario J. Hanyon, Esquire
Identification No.: 203993
126 Locust Street
Harrisburg, PA 17101
(215) 563-7000
Loan Care, a Division of FNF Servicing, Inc
Plaintiff
vs.
Dean P. Hoffman a/k/a Dean Paul Hoffman
Defendant
Attorneys for Plaintiff
COURT OF COMMON PLEAS
Cumberland County
CIVIL DIVISION
No. 11-7442-CIVIL
PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER
Plaintiff, Loan Care, a Division of FNF Servicing, Inc., by its attorney, Mario J. Hanyon, Esquire,
hereby files the within Reply to New Matter of Defendant Dean P. Hoffman alk/a Dean Paul Hoffman
and states as follows:
Plaintiff incorporates herein by reference the averments of paragraphs one (1) through eight (8)
of its Complaint as if set forth herein at length.
9. The averments of Defendant's affirmative defense in paragraph one (1) is denied. By way
of further answer, the allegations set forth in paragraph one (1) does not serve as a defense to the
foreclosure action. By way of further answer, Plaintiff's Complaint complies with the applicable Rules
280158
of Civil Procedure governing actions in mortgage foreclosure.
10. The averments of paragraph two (2) of Defendant's affirmative defense are denied. By
way of further answer, the Plaintiff is in the process of formalizing an Assignment and is now the
Mortgagee and under the law of Assignments, the Assignee stands in the same shoes as the Assignor.
The Assignment does not confer the Assignee any greater rights than those possessed by the Assignor.
Pennsylvania Higher Education Assistance v Debore, 67 Pa.Super 74, 416 A.2d 343, 344 (1979); U.S.
Steel Homes Credit Corporation v South Shore Development Corporation, 277 Pa.Super 3808, 419
A.2d 785 (1980). Furthermore, the Superior Court has held that a party is not required to have an
assignment recorded prior to filing a complaint in mortgage foreclosure. US Bank N.A. v. Mallory,
2009 Pa. Super. 182, 118 (2009). Therefore, the Plaintiff is the proper party and has standing to bring
this suit for Defendant's failure to tender monthly payments.
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and
against Defendant as requested in Plaintiffs Complaint.
Respectfully submitted,
PHELAN HALLINAN & SCHMIEG, LLP
Date: By;
ra chalk, Esquire
nyon, Esquire
for Plaintiff
280158
VERIFICATION
Joseph P. Schalk, Esquire, hereby states that he is the attorney for the Plaintiff in this action, that
he is authorized to make this verification, and that the statements made in the foregoing Reply to New
Matter are true and correct to the best of his information and belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsifications to authorities.
Date: 16T'lI'm gy;
PHELAN HALLINAN & SCHMIEG, LLP
P chalk, Esquire
J. 4anyon, Esquire
ey for Plaintiff
)cust Street
Harrisburg, PA 17101
(215) 563-7000
280158
PHELAN HALLINAN & SCHMIEG, LLP
BY: Mario J. Hanyon, Esquire
Identification No.: 203993
126 Locust Street
Harrisburg, PA 17101
(215) 563-7000
Loan Care, a Division of FNF Servicing, Inc
Plaintiff
vs.
Dean P. Hoffinan a/k/a Dean Paul Hoffman
Defendant
Attorneys for Plaintiff
COURT OF COMMON PLEAS
Cumberland County
CIVIL DIVISION
No. 11-7442-CIVIL
CERTIFICATION OF SERVICE
I certify that a true and correct copy of Plaintiff s Reply to Defendant's New Matter was sent via
first class mail to the person listed below on the date indicated:
Dean Paul Hoffman, Pro Se
3602 Golfview Drive
Mechanicsburg, PA 17050
Date: (61-L-1,
[anyon, Esquire
for Plaintiff
280158
PHELAN HALLINAN & SCHMIEG, LLP
BY: COURTENAY R. DUNN, ESQUIRE
Identification No. 206779
One Penn Center at Suburban Station
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
Plaintiff
V.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
Defendant
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Attorney for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 11-7442-CIVIL
CUMBERLAND COUNTY
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Please substitute the attached, original Verification of Mary Lucy, Vice President
for Loancare, a Division of FNF Servicing, Inc., servicing agent for Plaintiff for the
Verification attached to Plaintiff's Complaint filed in the above matter on or about
September 29, 2011.
Date: t
BY: c _
ourtenay R. Dunn, Esquire
Attorney for Plaintiff
PHS 280158
PHELAN HALLINAN & SCHMIEG, LLP
BY: COURTENAY R. DUNN, ESQUIRE
Identification No. 206779
One Penn Center at Suburban Station
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
Plaintiff
V.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
Defendant
Attorney for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 11-7442-CIVIL
CUMBERLAND COUNTY
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the foregoing Plaintiff's Praecipe to
Substitute Verification was served by regular mail on the following parties on the date
listed below:
Dean P. Hoffinan, Pro Se
3602 Golfview Drive
Mechanicsburg, PA 17050-2216
DATE: 7 (Yob Z."'
BY:
ourtenay R. Dunn, Esquire
Attorney for Plaintiff
PHS 280158
VERIFICATION
rfl 6(N ?V , hereby states that he/she is ( of, LOANCARE,
A DIVISION OF FNF SERVICING, INC., Plaintiff in this matter, that he/she is authorized to
make this Verification, and verify that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and
belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
DATE:
??) I L ?' t -?--
File#: 280158 LT
Name: HOFFMAN
Name: ar,
Title:
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
File #: 280158
PHELAN HALLINAN & SCHMIF4. ?I ,? l
BY: JOSEPH P. SCHALK, ESQUI ,/
Identification No. 91656 }!,` 16ERLA D COUNT Attorney for Plaintiff
126 Locust Street ;yHSYLVANIA
Harrisburg, PA 17101
(215) 563-7000
Loan Care, a Division of FNF Servicing, Inc.
3637 Sentara Way, Suite 303
Virginia Beach, VA 23452
Plaintiff
VS.
Dean P. Hoffman a/k/a Dean Paul Hoffman
3602 Golfview Drive
Mechanicsburg, PA 17050
Defendant
: Court of Common Pleas
: Civil Division
: Cumberland County
: No. 11-7442-CIVIL
MOTION FOR SUMMARY JUDGMENT
Plaintiff respectfully requests that the Court enter an Order granting summary judgment in
its favor in the above-captioned matter and in support thereof avers as follows:
There are no material issues of fact in dispute.
2. Plaintiff is seeking only an in rem judgment in this mortgage foreclosure action.
3. Defendant, Dean P. Hoffman a/k/a Dean Paul Hoffman, has filed an Answer to the
Complaint in which he has effectively admitted all of the allegations of the Complaint, as is further
addressed in Plaintiffs attached Brief.
4. In his Answer, Defendant failed to deny the default, mortgage and Plaintiff s
compliance with Act 6 of 1974, therefore he is deemed to have admitted these allegations of
Plaintiff s Complaint. True and correct copies of Plaintiffs Mortgage Foreclosure Complaint,
Defendant's Answer and New Matter, and Plaintiffs Reply to New Matter are attached hereto,
incorporated herein by reference, and marked as Exhibits C, D and E, respectively.
5. In his Answer, Defendant generally denies paragraph six (6) of the Complaint
Exhibit "A"
\-L
This lnstrumcnt 1'rcn:?rt?f si?:
?-WU, r Iel A( P,? /r 7 y 7
After Recording Return To;
LEND AMERICA
520 BROADI OL - 016 ROAD, SUITE 100E
MELVILLE, NEW YORK 11747
Loan Number: 20090295,40
Uniform Parcel Idenfilier Number: i Q - i 7 - ) C .? 7- 0? 7
Property Address:
3602 Gc1fv1-ew Drive
Mechan-_csbu q, Pennwy.vani-a 1'7050
[Space Abcve This sire For Recorairg Dalai
MORTGAGE
MIN: 100286220090295400^
1716 U
--+,3b rt (1 t?5 Pq
FHA CASE NO
441-9050'704-703
THIS NIORTGAG ("Security Instrument")is -ivcnon JUNE 12, 2009
The mortgagor is Dean P. Hof Oman SOLELY
360a Cvl71?t eLj ?(-,I e 1 cckQ? t r--r, bor9 t "Borrower").
This Security Instrument is viyen to.Aortgagc I'•iccuon ic Registration Systems, Inc. ("MFRS") as. Mortgagee, MERS
is the nominee for tender, as hereinafter dcimcd, and Lender',, successors and assigns. ;VEERS is organized and
existing under tLc laws of Delaware. and has a mailing addre;e off'. 0. Box 2026, Flint, MI 48501-?0_'6 and a street
address of -,100 S.W 34th Avenue. Suite [01. Ocala. Fl_ 34474, tel. (8SS) 679-MERS.
LEND AMERICA, A NEW YORK CDRP-)RATIt;N ("Lender")
is organized and, existing under the law. o NEW YORK
and has an address of 520 BROADIHOLLOW ROAD, SUITE 100E, MELVILLE, _'4EW
YORK 11747
Borrower owes Lender the principal sum of TWO -HUNDRED SIX--Y-FIVE THOUSAND
FIFTY- I HT AND 00/10C Doilors(U.S. S 265, 05fi . 00 ).
This debt is cviucn"d by B01-1`0\10r'i nine darted the 1n11W CIOU: W, this S,:;:nrity Ir.strument ("Noi,:" } -,?hich provides
for monthly paxmenis- with the full debt, it 1101 paid corder, due and p.r,able on JULY 1, 210 3 R
FHA PENNSYLVANIA MORTGAGE- MERS
PAMTGZ.FHA 11101:08 Page 1 of 10
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This Security lnstrtr:;nent ,ccnres to Lender is the rcpaynictu of the dclht evidenced by the Nulc. „ith interest, and
all renewals. extensions and n?nt'.iii aiiun nl't'nc• Noic- (b) tL, pavn,nw of all other sums, with inkiest, advanced
under paragraph % to protect the security ofdti> Sei urity Imtrumcnt: and t cI the performance of Bot i mi or' s covenants
and agrccincnts order this Security Instrument anti the Note. For this purpose, Borrower does hereby mortgage, grant
and convey to HERS (solely a, namince fin Lender and Lcndcr', Sut'ce,,atrs and assigns) and to the successors and
assigns of HERS the 1i0110wing dcsct'ibcd prol?ertti' located in C'ImberIand counly,
Pennsylvania:
SEE LEGAL ::ESGRIPTI'CN ATTACHED HERETO AND MADE A PART tIEREOF AS
EXHIBIT "A" .
which has the nddre, of 3602 Gcifview give
.r rc ct]
tf_ecttarlicsburg . Pciin,yh;tnia 17050 Prop crty Address"):
[Zip Codcl
TOGETHER WITH all the improycnerrs now of hercalier erected on the property, and Lill casements,
appurtenances. and fivures nosy or hLreatler a part of tLe propcrty All replacements and additions shall also be
covered by this Security lnstrument. All of tlic foregoing is referred to it: this Security instrument a, the "Property."
Borrower understand; and aurces that \1P.RS holds only legal title to the interests granted by Borrnwci in this Security
Instrument: but. if necessary to comply xilh lase or custom. VIERS tae, nommee for Lender and L mdcr's successors
and assigns) has the right to exercise any or all o', those interest. includim,. but not limited to, th, i wht to foreclose
and sell the Property: and to take any action rccluircd of' Lender ineiudinil. but not limited to, rclrisin= or canceling
this Security Instrument.
BORROW[ R COVENANTS that Bsirrn„.: i,' fully seised of the c,tatc hereby conveyed and has the right to
mortgage, grant and conyev the Property and thFo the Property is tine ncuntbcred, except for encumhranc; s of record.
Borrower warrants and ?yill clefend acneralh_? ih,: title to die Property :gain,( all claims and denuuxi<. it bject to any
encumbrances 01' rectn•d.
THIS SECURITY 1NSTRUNtFN'T cum'inns ttrtifortn rovcliaws roe national use and non-unitOrm covenants with
limited variation, byjnrisdiction to constitute a ur.ilarn security insinuncttt covering real propcrt,
UNIFORM COVENANTS, Burro ce and Lcn;ler cmcnant I;t1U ;i rce as follows:
1. Payment of Principal, interest end I.ate C.•hartie, Bmiokkcr shall pay when duc flip principal of and
interest on, the Licht c, itlenced by the Note and laic diargcs duc undei the Note.
2. MonthlY Payment of Taxes, Insunutcc, and Other Charge(. Borrower shall inclm:lc n each monthly
payment, togeii;er -.t ilh the principal and interest a, set forth in the Noic and any late charges, a inn (c,r (a) taxes and
special asses s:nc„ts ievictl or to be Icyicd kluainst the Property, th) Icascholc payments or _round rents on the
Property. and (c) premiums fur in:nrtncc rcyoired under Para graph- -. Ili any year in which tLc Lender must pay a
mortgage insurance premium to the Secrcfary of I lousing and Urban ih:,e';opment ("Secretary"), of in any year in
11111111111111111111111111111111 Rill IIW119111MI1111NIIIMI111IIIYIIIIIIN 11111111111111 IN 11111 N llliI
08/29/2011 9:11 42 AM CUMBERLAND COUNTY Inst.# 200922950 - Page 2 of 1:
which such prcnuunt would have been required it Lcndcr till held tho Security Instrument, each monthly payment
shall also inchrdc either. (II a sun1 fur the annual mortgage msuriulcc prowourn to be paid by Lenten to the Secretary,
or (ii) a monthly char c instead of a mort_,age in?urancc prcntiurtt if this Security Instrument is held h, the Secretary,
in a reasonable amount to he delcrnuncd by the Secict;,rv. Except for the monthly --harge by the Secr ca a y, these items
are called "Escrow Itema" and the sung paid to Lender arc called "Escrow Funds."
Lender mav, at any time. collect and hold ,mounts tOr F.scro>a' Item; in an aggregate amount not to exceed the
maximum amount that mny be required for Ron ow.r's escrow account under the Real Estate Settlement Procedures
tray be amended
Act of 1914. 1: li.S,C. `2601 et sec. and implementing regulations, 24 CFR Part 3500, as thv%
from time totivic except that the cushion or rc:enepcrmittcd 1)yRESPA forunanticihilled disbursements
or disbursements before the Borro%yci's payments ,1rc it%Miabic in the accwint may not be based -n-, amounts clue for
the mortgage iwurancc premium
If the aino.:n•t,, head by Lender for Escrov, licn:s ",weed the amount; ;,omitted to be held by 1?1iC1' i. Lender shall
account to Borrower for the excess funds as required by RFSPA. 11 the amounts of funds held by. 1 :ndcr at any Hite
are not suffi:icnt to pay the Escrow ltcros when tluc. I cncler may notity the Borrower and reC16i c 13 a rower to crake
up the shortage as permitted by RFSPA.
The Escrow F(:ads arc nledgcd as additi n:al security for all sum. Secured by this Sccurit} Instrument. If
Borrower tenders to Lender the full paN runt of all Such Sumo. 130rrOUCr's account shall be credited %N ith the balance
remaining for all instalhnettt item", (a), (h), a:rd tct ai:d t+n\ mortgage insurance premium instaltmcnt that Lender has
not become obligated ro pay to the Secretary. and Lcndcr shall promptly refund any excess funds to Borrower.
Immediately prior to a foreclosure sale of the 1'roperry or its acquisition by Lender, Borrower's account shall be
credited with any halance remaining for all installments lot items (a), (ht. and (c).
3, Application of Payments. All payment: under paragraphs 1 and 2 shall be applied by i Cndcr as follows:
FIRST, to the nmrtgao,, insurance pre,l16111) In he paid by Tender III the Secretary or to the monthly charge by
the Secrcwry insred oC the nionthly mortumue insurance picniittm,
SECOND, to any tares. special asses.,mcnto. Ic ascholt: pan mcnts or ground fetus, and fire. flood and other hazard
insuran•:c pre nittm>. as required:
THIRD, to interest due under the Note:
FOUR"'1-i, to amortization or rhr princi,al of the \(Ilc: Lind
FIFTH. to late charges due under the Note.
4. Fire, Flood and Other- Hazard Insurance. Borrower shall insure all improvements (in the Property,
whether now in existence or sub-;equcntly erecrul. against any hazards. casualties, and eontingencic,, including fire.
for which Lender requires insurance. Tilts insurance shall be maintained in the amounts and for the periods that
Lender requires. Borrower shall also insure all improvements on the Property, whether no.c in existence or
subsequently erected. against loss by Iloods to the c\ tent re(luirc(t by the Scc3-etary. All insurance ,hail he carried wish
companies apprin ed by Lender. The arsons",,' pol.?.ics and any rcncn als shall ne held by Lender ;tnd shall include
loss payable clauses in favor of. a'nr: in a k,rn acecptaLlc to. I.cttclct•.
in the event of loos. Borrower shall "i\c !.en(lcr in,nadiatc nr•tiCe, he mail. Lender may make ;,mofo£ loss if not
made promptly ', y Borrower. Lath u1s( rar,cc c,,:;t;,un% a-nc•crncd is hetvlw authorized and directed to make payment
for such loss directly to Lcndcr. instead of to Berrkvker and it, l.cn(icr jointly. All or any part ol'the insurance
proceeds may he applied by Lender, 31 it> Option, either !a) to the reduction of the indebtedness nn(ier the Note and
this Security lost ur::cnt, first to any delin(Ittcm Snlounts ap')hCd in the order in Paragraph 3, and Iltctt to prepayment
of principal. or (b) to the restoration, or repair of tdtc damaced Property, Ante application of the proceeds to the
principai sHfli rot extend or postpone the due date of the monthly payments whi•-It are referred n, in paragraph 2, or
FHA PENNSYLVANIA MORTGAGE- MERS ____ AacMagice- ,..•,, 800-6+9-1362
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1AUwi11ui11iwMiuiiu0 11 IN 11111111111111 111111N 1111ii1uiri
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change the amount of such payments. Anv cNcc;s insutancc procecds o?cr al, arrount required to pad all outstanding
indebtedness under the Note and this SecuritS Iltstruntetlt shall be ;mid to 1112 sooty legally entitled thee t, .
In the event of forcclusure of this SccuIin IIt ;Tr lllnent or other Irartsf,:r of d:le to the Proper/. that extinguishes
the indebtedness. all right. title and interest of lkn ruwCr in and to insurallCC policies in force shall pas\ to the purchaser.
5. Occupancy., Preservation, Maintenance and Protection of the Property; Borrower's Loan Application;
Leaseholds. Borrower shalt occupy, establish. and use the Property as Borrower's principal residcnre within sixty
days after Gnc csccution of this Security ]nstn;malt (Or 4stthin sixty day, ora later sale ortranst:t of the Property)
and shall continue to occupy the Propcrty as borrower's principal residence for at least one year otter the date of
occupancy, unless Lender determlines that rvquircntcut will cause undue hardship for Borrower, or u,tless extenuating
circumstanc-cs exist which are beyond Borrower's cunlrol, Borrower shall notify Lender of ony extenuating
circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Pi upcrty or allow
the Property to deteriorate. rcasonahlc wear and tc.:- cxccptc(: Lcndcr may inspect the Property if the Property is
vacant or abandoned or the loan is in default Lendet may take rca>onable action to protect and prescnc such vacant
or abandoned Properly. Borrower shall also, he in default if Bonroucr, during the loan application pu,eess, gave
materially false or inaccu atc infonr:acion or statcn%crit; to Lcndcr (or failed tc provide Lendcr wirit any material
information) in connection with the loan evidenced by the Note, including, but not limited tn. representations
concerning Borroucr's occupancy of the Proacrty as a principa! resiclenee. If this Security instrument is on a
leasehold. Borrowct :hall comply tvrth tl. e pi of ,signs or the lease, tf Borrower acquires fee titc to the Property, the
leasehold and fee Lille shall not br r-.crgec! unless I imdcr a,_rces to the merger in writing.
6. Condemnation. The pro,oCdS of iuic a"ard or Claim fnr rasna es. direct or consequenrim. in connection
with any condemnation or other takin!+ of anc part of the Propcrty, or for conveyance in place of condemnation, are
hereby assiuned and sl-all be paid to Lendcr u. the extent ol'lhe full amount of the indebtedness thus remains unpaid
under the Notc and IL•is Security Inetrumcnt. Lender shall apply such proceeds to the reduction or the indebtedness
under the NOtc and this Security Instrument, firs) to any delinquent ,unounts applied in the ord:r provided in
paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal Oall not extend
or postpone the due dale of the montL•ly F.avmcnrs. a hich arc referred to in paragraph 2, or char.,c Ilse amount of such
payments. Any excess proceeds' over an anioura rc(ILIII-C(l to pay all uufsntn(ing indebtedness undo the Note and this
Security lnstrunien! ;hall he paid to the cntz legally entitled thereuh.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borros+_r shall pay all
governmental or 01111)16pal charges, fines :uhd ;mposiilons that are not included in paragraph 2 Borrower shall pay
these obligations on time directly to the ahtity which is otived the payment. If failure to pay would adsersely affect
Lender's interest in the Propcrty. upon Lendcr'c rcquea Borrower shall promptly furnish to Lender receipts
evidencing these payments.
if Borrower tails to make these payments or the paytl)etttS required by paragraph 2, or fails to perform any other
covenants and a,,rccnicrits contained in this Security instrument. or there is a legal proceeding that may significantly
affect Lender's right,, in the Property (such as a proceeding in bankruptcy. for condemnation or to :nforce laws or
regulations;. (lien 1-ender may do algal pay what n Cr is necessary to protect the value of the Propcrty and Lender's
rights in the PrcrpcrtY, including palmcr.t of Lacs- har.arl ir. uranc,: and oncQr it.-ms mentioned In paragraph 2.
Any amounts disbursed by L,enLICI under till, paragraph shall hecomc an additional debt of (borrower and be
sccttred by this SrCttriry lnsu t!ntcnt These amount; shall beat interest Frain. Hic date 0f disbursement at the Note rate,
and at the option of! -ender shall h,, inmhcdiaicly (!tic and pavi blc
Borrower shall promptly discharge arty lien s$ich has priority OVCI [III, Security [nstrumcnt unless Borrower:
(a) agrees in writing to tlhc payment of the obligation secured hg the licit in a r.hanner acceptable to I.endcr; (b) contests
in good faith The liCn bv, Or defCni:k agautst cnfO-Ccnter.t of the lie„ Ili. legal proceedings which in the Lender's
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opinion opcretc ao prcycnl the enforecnlcm of the lien: or (c) secures from the holder of the licit an agreement
satisfactorv to Lcndcr subordinating the lice to lhis Security instrument. If I.ender determines dial any part of the
Property is =ubjcct to a lien which play attailt i clarity over this Sccuritr Instrument, Lender may gite Borrower a
notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions sct Comp above within
10 days of the 6-,-ing of notice.
8. Fees. Lcndcr may collect ices anti clwrveN :uathorizcd by the Secretary.
9. Grounds for ;Acceleration of Debt.
(a) Default. Lender may. except os limited by rceul.uions issued by the Secretary in talc case of payment
defauhs. rcq.:ire inmlediate payment in IWI of all sums secured hi this Security Instrument it'.
(;) Borrower defaults by failing to hay in frill also nllmlhly payment required he this Security
Instrument prior to or or: the due date of the nCX1 monthly payment, or
(ii; Borrmt cr dc,:Iatlts by '::ai1 -g- (,a a ncri.-•d of thin) days, to perform am other obligations
contained in this S".uritV Instrument.
(b) Sale Without Credit Approval. Lcndcr shall. ifpermiucd i)y applicable law Oncltidmg ;cction 341(d)
of the {.arn-St. Germain Depository institutions Act of 1982- 12 U.S.C. 1701j-3(d)) and with the prior
appro`.:al of tic Secretary, require In1151ctllaic payment in hill of all ,Ilms secured by this Sccuriry Instrument if.
iif All or part of the Property. or a bcn6ciai inacrest in a trust owning all or pan oflhe Property, is
,hill or otherwise tanslcrrCCi lather than by devi,e or descent). and
nai The Property is not occupied by tie ^urchnwr or grani{e as his or her principal rc,idence, or the
p".1-chaser or urantee doss so occupy the Properly. hk.t his or her credit has not hc,,n approved in
;ccoidatlcc with the requirements ofthe Sccrclary
(c) No Waiver. lfcircumsuuaccs uccau that could permit Lends to require immediate p,rymcnt in full.
but Lcndcr does rot rcgcirc such lilt n?ents. 1-miter do", not n:!itc it, rights with respect to <uh,,:qucnt events.
(d) Regul'ations of Iil1D Secretary. In tllany circumstonot S rc_t!latioas issued by the Srcr,aary will limit
Lendcr', right,, in the case of payn?cat defaults. to rCquirc immcdiatc payment in full and foreclose if not
paid Tsai; Security hlscrv.nenl dncs nnl authorize ncc;acraliun car foreclosure ifnot pcrmmed by regulations
of the S :rrctary.
(e) .Nlnrtgage Not Insured. Borrower agrees that if' this Sec:arity Instrument and Cllr Note are not
determined to be eligible For insurance under the National HoUSia?C Act within 60 DAY'S
from ill,- (late ltcrcof- Lendcr nlay, it its option, regl?irc itmned6ic payment in full of all sums secured by
this Sec.:rily Instrument. A written statement Of any authorized agent of the Secretary dulcas subsequent to
60 DAYS, from the dale hereof, dcchnima to insure this Secltrity Instrument and
the Note, si ill he deemed conclusive , oot ,,f such incligibilvy \ntwithstanding the forc_toinu. this option
may nor c c,,erciscd by Lcndcr Rhen the Unavailability Of ir;AaraOU is solely due to Lcndcr', Iai-ire to remit
a ntor( lagc insurance nrcntiut?? to the SCLICMI V.
10. Reinstatement. Borrower has a right to be rcinstal:d if I.endcr llas required immediate payment in full
because of Borrowci' V failure to pay an an?otula rluc tinder talc Note of this Security Instrument. This right applies
even after forcclostnc proeee(lings arc instiwicd. To rcinstal.: tie Seclnat-, Instrument, Borrower shall tender in a
lump sum all amounts required to bring Borrwxcr's account current inelnding. to the extent thry arc obligations of
Borrower under 71)IS SeCUrity Instrument, foreclosure costs and reasonable .'Wd customary attorney: fee, and expenses
properly associa-cd with the foreclosure prolccding. Upon rcir.statemcnr h) Borrower, this Scewity instrument and
the obligations that it secures ,hall remain in effect as if Lcndcr had not required immediate p.ryment in full.
However, Lend•_r is not rCLlnired to pornaif reinstatement it (i) Lcndcr has accepted rcmm,wtemcnt after the
commencement O forcclPsUr,e t1McCCLtim?< ?+!Ihin mo years immcliiawl, hacceding the conuhcn:rmmnt of a current
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foreclosure proceeding, (ii) reinstatement \+01 preck,de t'urcclusurr On different grounds in iiic luture, or (iii)
reinstatement will ackciscly affect the priority of the lien created by this Security Instrument.
It. Borrower Not Released; Forbearance by Lender Not a Waieer. Extension of the tin.: of payment or
modification ol'amortization of'( Ile sums secured 1>y this Security Instrument granted by Lender to :my successor in
interest of Borrower shall not operate to relca;e the liability of the original Borrower or Borrowc:'s successors in
interest. Lender shall not ^,c required to eommcncc proccrdings aoain,t anv uceessor in interest or refuse to extend
time for payment or otherwise n indity amortizalion ol•the sums secured by dais Security lnstrumew by reason of any
demand made by the original Borrow•cr or l3nr•rnwc1'; suCCCSSOrS in interest. Any forbearance by Lender in exercising
any right or remedy shall not be a waiver of or preclude the exercise of am° right or remedy.
12. Successors and Assigns Bound; Join' and Several Liability; Co-Signers. The covenants and agreements
of this Security Instrument shall bind ant: hcneiit the successors and assigtu of Lender and Boi ro%N ei. subject to the
provisions of paragraph 9(b). Borrower's cotenants and agreements shail be Joint and several. \n Rorrowcr who
co-signs this Security 1nSawnent but does not eicculc the Note: (a) is co-signing this Seeurin Insntoltent only to
mortgage, grant and ;onvey that Boirowci's ir:lerest in the Property under the terms of this Scrurits lnstrumenl. IN
is not perscnalk obligaled to pay the sn n, secured h this Sceta ov tn,u unteni; and (c) agree, till Linder and any
other Borrcu ci may agree to exier.d. inodify, forbear (it- mak•e in\ accommodations with regard io the terms of this
Security htstrument or the Note wtlhout that Ronmxcr's consent.
13. Notices. Any notice to Rorrower pro\ ided for in this Sccurity Instrument shall be given h} delivering it or
by mailing it hg first class mail unless applicable ]a\v requires use Of - anothcr method. The notice .<i-all be directed
to the Properry Adeiress or anv other address Borrower designates by notice to Lender. Any mice t„ Lender shall
be given by first class mail to Lender's address stated herein or any addre,s Lender designates by not.,v to Borrower.
Any notice provided tier in this Security Instrument S1:a11 be deemed to have been given to Bon awcr of I ender when
given as provic]cd in this paragraph.
14. Governing Law; Severability. This SCCUrity In>iruntcnt Shall he Governed by federal !aid and the law of
the jurisdiction u. which the Property is located. It,, the scent that any provision or clause ofthi. Sccunty Instrument
or the Note c:onflictS with applicable law, such cunllicl shrill ant affiect olltc:r nrovisions of this Security Instrument
or the Note which can he given effect wilhtx+t the conflictntg provision. To this end the provision. w 'this Security
Instrument and the Nate arc declared to be sererablc.
15. Borrower's Cope. Fiorruwci shall be;=ivcn one conformed copy of the Note and of this Sccurity Instrument.
16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal. Storage, or relea;c
of any Hazardous Substances On or in Use Property. Borrower shall not do. nor allow anyone the io do, anything
affecting the Property that is in violation of any Enytrnnntental i.;tw The preceding two senicnCC, x11.01 not apply
to the presence, itsc, or storage on the Propcrty of small quantities of Hazardous Substances that are generally
recognized to be appropriate to normal residcntlal uscS and to maintenance of the Property.
Borrower shall promptly give ixnder w riticn notice of any investigation, claim, demand. la+ sou <lr other action
by any governincntal or rcoulator-_y arcncy or private parr; involving the Propery and any Ha/a dou, Substance or
Environmental Lave of which Bon over has actual kno%% c. If Borrtw a Icurns, or is notified 1, am -ovcrnmental
or regulatory author;;}. t]:at any removal or wrest rcrncdionon of am 113,,ordous Substances nll taint the Property
is necessary. Borimcci shall promptly take all reccssaty Icirodial action, in accordance with l miioninental Law.
As used i? this parauraph :0. "I tarnrdou tiuhst_mces" arc those sllnstances defined :i, tonic ur hazardous
substances ;:y k1lirormental Law and the fnikrwinu substance.: gasoline, kerosene, other ii:rinmable or toxic
petroleum products. toxic pesticides and herhicides, volatile so}ycnts. matci iai.scantaining asbc,nr> of lin nialdehyde,
and radioact!vc material.. As used it,. rhi; pampoph 16.. "Gmironmental i.aw" means federal t:ny, rod laws ofthe
jurisdiction where the Propcrty is pouted that refute to health, safety, or cm ironmental protectioii.
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NON-UNIFORM COVENANTS. Borrower and Lender further co%,:nant and agree as Ii611o\?s:
17, Assignment of Rents. Borrower unconditionally assign, and transfers to Lender all the iclit and revenues
of the Property. Borrower authorizes Lender or Lender' t. agents to collect the rents and revenues roil hereby directs
each tenant of the Property to pay the rents to Lcndcr or Lcndcr's agents. However, prior to Lender'S notice to
Borrower of Bon cover's breach of any covenant or agreernem in the Security instrument, Borrower :hall collect and
receive all rent: and revenues of the Propcrty as trustct for the benefit ol'i_cnder and Borrower. This assignment of
rents cumsti'ures an absolute as ignmenl an(i not an assigmncnt liar sdditionoi ,ceurity only.
If Lender rive. notice of breach to Borrm\cr. (a) Al rents recci\ed b% Borrower shall be field h. Borrower as
trustee for benefit of L.endcr only. to be applied to the sums ,can- d by the Security tnstr umcnt; Ili) l.cnder shall he
entitled to collect and receive all ul'the rents of the Property; and ±c) each tenant of the Propene :hall )lay all rents
due and unpaid to Lender Or Lendca's agent >n Lcncfer's written dcnumd rn the tenant.
Borrower has not executed any prior assigtenen' oaf the rents and has not and will not perform :rn? act that would
prevent Lender from exercising its rights under thi, paragraph ' 7.
Lender shall tact be required to enter upon. rake control ofot maintain the Property before of niter giving notice
of breach to Borrower. Howeyer_ Lcndcr or a judicially appointed re; cic.r may do so at any time thr;-c is a breach.
Any application of rents shall not cure or w.tiyc an_r default or invalidate Xl} Other right or remacih oI t-ender. This
assignment of rent. of the Propcrt} shall tei ntinate when the debt secured by the Security Instrument is paid in till].
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9. Lender may
foreclose this Security Instrument by judicial proceed'irip andior invoke anv other remedies permitted by
applicable lat%. Ltrider shall be entitled to collect all expenses incurred in pursuing the rennedics provided or
referred to in this paragraph 18, including;. but not limited to, aitorne}s' fees and costs of title evidence to the
extent permitted by applicable laic.
If the Lender's interest in this Security Instrument is held bY the Secretary, and the Secretary requires
immediate pa}ment in full under paragraph 9, the Secretary may invoke the nonjudicial potyer of sale provided
in the Sin-le Family Mortgage Foreclosure :Act of 1994 ("Act') (12 L'. S.C. 3751 et sec].) h? requesting a
foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided
in the Act. Nothing; ]n the preceding; sentence shall deprive the Secretar% of any rights otherri ise available to
a Lender under this paragraph 18 or applicable lacy.
19. Release. Lpon payment ol'ail sums sa;:urcd by this S curet, in>trunient, this Securit Instrument and the
estate conyeved shall terminate and become uoid, Aber such occurrence. Lender shall discharge and satisfy this
Security Lanstrumcnt. Borrov,,cr shall pay :uny recordation costs. Lender mna% charge Borrower n Iec ti)r releasing thi-
Security insiniment. but only if tie Ice is pair to :bird parry r or :erviccs rendered and the cL;u in of the fee is
permitted under applicable law.
20. Waivers. Borrower. W Une extent permitted by applicable lass. salves and releases am 1n01 Of defects in
proceedings to cntiarcc this Sccurit' Instrument. and 3tcrebv svaiycs the bcnclit ofany present or luto c I:nrs providing
for stay of execution, extcnsiou 01 tin•,c, cxcnnotion front attachnient. Ies.:and sale. and homestead cxcmption.
21. Reinstatement Period. Borrower's tinnc to reinstate provided in paragraph 10 shall extcnii to erne hour prior
to the corer iencenient of bidding at a sheriffs sale or other ;ate purutanr to this Security Instnuncni.
22. Purchase Money Mortgage. Harty o' the debt secured by this SeLJrily Instrument is I-nn to Borrower to
acquire title to the Property. this Sccurit} instrua,?nt shall be it nurcl,asc money mortgage.
23. Interest Rate After Judgment. Boninvcr aurce• that the interest rate payable after :a iud_nicni is entered
on the Note m in ;m action of mortcagc lorcelosure shall inn the rate paVablc from time to lime under the Note.
1111111111 IN 111111111111111 1111111111111111121111111111 Rill Rill H ill 1111111111111111
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34. Riders to this SecuritN Instrument. I one nr more riders are executed by Borrower ;i nl rrcurJed together
with this Sccurite Instru:ncM, the cokrnants of etch Such rider shall he incorporated into mid A.a11 amend and
supplement the covertil tts and agrccfltents of this Security Instrument as it the rider(s) were it hart or' this Security
Instrument.
[Check applic;iblc bosics)j.
? Condominium Rider C Graduated Payment Ridcr ? Growtm! I yuity Rider
Punned Crit Development Rider ? Adjt:stablc Rate Rider ? Rehabilitation Loan Rider
? Nor,-Ou-ncr Oecupancy Rider ? Other [Specify]
BY SIGNING BLU) . Borrower sccca,ts,u,d a,rces to the icrmu.ontaincd in pages I through, 10 of this Security
Instrument and it) <u;y nl,r(s) executed bv Borro?kcr and recorded with it
(Seal)
Dean P. Hof`man -Borrower -Borrower
- (Seal)
-Borrower
(S-11)
-Bo -, ow•cr
W ilness:
(Seat)
Borrower
- (Seal)
-Borrower
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- -
[Space Beiow This Line For Acknowledgment]
Statc of PENNSYI,VAN _TA
County of .,-u -,-,'??'
hc[i?r:mc. _
Onths(ho 12th=day of ?T? 20C9
the undersigned officer, personally appeared Dean P. Ho-f fma_1
known to me ((li ,?ilisfactorily i)ro1'e11) to be 1hC pet',h1*) a w,c ]lalStCl l i, .n'e ,ubseribed to the -,thin instrument
and acknowleaeed that heishc tlic) csccutcd the s:une For th;: hurpo.e; therein contained.
In witness Mhereof. 1 hercunM set 01r hand and official >,?als.
COMMONVNEALTH OF PENNSYLVANIA.
LisaA Swi "'?':t+; 'Lit%tIC
My .ornm..,,_ 'r. JkAY:J4.2 r t1...._j
i; ber. Pennsylvan;a AssocRatic.;n u' Nata,ies
(seal)
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t ,
rite of officer
Certificate of Residence of Mortgagee
The tmdet> gored hereby certifies that (i) he'shc i, the %1ni-waucc or the culy authorized anort,ey or agent of
the Mortgagee named if) the within insuvnlent: and (ii) Mortgagee's preci,c residence is:
3300 S. W. 34th Avenue, Suite 101, Ocala, FL 24474, P. 0. Box
2026, Flint, Michigan 48501-2026
Witnc,s my hand this _ day' of Si n:uurc of Mortgage: or Mort ,t cc's Dily Authorized Nlionw\ or Aaent
Tv,ckahring;uII,:of otluuyrc ,, Most agee'sDulyAtithorvcJ \uorneyorA.:ent
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Loan Nur?ner: 2009029540
Date- JrJA'E 12, 2009
Property Addre": 3602. Go fview Dive
Mechanicsburg, Pennsylvania 17050
EXHIBIT "A"
LEGAL DESCRIPTION
e,':- " ,=: Boo-649-7362
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Schedule A Description
Title Number WOR17165PA
Page 1
LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT
CERTAIN PROPERTY SITUATED IN THE COUNTY OF CUMBERLAND, AND
STATE OF PENNSYLVANIA AND BEING DESCRIBED IN A DEED DATED
07/1412003 AND RECORDED 07/16/2003 IN BOOK 258 PAGE 672 AMONG
THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE,
AND REFERENCED AS FOLLOWS:
LEGAL DESCRIPTION:
ALL THOSE CERTAIN TRACT OR PARCEL OF LAND PREMISES, SITUATE,
LYING AND BEING IN THE TOWNSHIP OF HAMPDEN IN THE COUNTY OF
CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE
PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE NORTH SIDE OF GOLFRIEW DRIVE AT
THE DIVIDING LINE BETWEEN LOTS NOS. 376 AND 3770F THE
HEREINAFTER MENTIONED PLAN, SAID POINT BEING 125.04 FEET WEST
OF THE INTERSECTION OF GOLFVIEW DRIVE AND KENT DRIVE; THENCE
ALONG THE NORTH SIDE OF GOLFVIEW DRIVE NORTH 79 DEGREES 33
MINUTES 40 SECONDS WEST A DISTANCE OF 65.05 FEET TO A POINT;
THENCE ALONG THE SAME BY A CURVE TO THE LEFT HAVING A RADIUS
OF 590.00 FEET, AN ARC LENGTH OF 33.95 FEET TO A POINT AT LOT NO.
378; THENCE ALONG LOT NO. 378 NORTH 07 DEGREES 08 MINUTES 31
SECONDS EAST A DISTANCE OF 162.67 FEET TO A POINT AT :LANDS
NOW OR FORMERLY OF HAMPDEN SQUARE LTD.; THENCE ALONG SAID
LAUD NOW OR FORMERLY OF HAMPDEN SQUARE LTD. NORTH 75
DEGREES 21 MINUTES 49 SECONDS EAST A DISTANCE OF 37.57 FEET TO
A POINT; THENCE ALONG THE SAME SOUTH 37 DEGREES 33 MINUTES 40
SECONDS EAST A DISTANCE OF 100.00 FEET TO A POINT AT LOT NO.
376; THENCE ALONG LOT NO. 376 SOUTH 10 DEGREES 26 MINUTES 20.
SECONDS WEST A DISTANCE OF 110.44 FEET TO A POINT, THE PLACE
OF BEGINNING.
CONTAINING 15,717 SQUARE FEET.
BEING LOT NO. 377, FINAL SUBDIVISION PLAN NO. 3; HAMPDEN SQUARE,
SAID PLAN BEING RECORDED IN PLAN BOOK 43, PAGE 139,
CUMBERLAND COUNTY.
PARCEL NO. 10-17-1037-099
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Exhibit "A-1"
7. f
MIN: 100286220090295400 Loan Number:
now
NOTE
FHA Case No.
441-9050704-703
JUNE.12, 2009
[Dare] Way]
I tirare]
3602 Golfview Drive, Mechanicsburg, Pennsylvania 1`7[)50
I Propeny :addr-1
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns.
"Lender" means LEND AMERICA, A NEW YORK CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
TWO HUNDRED SIXTY-FIVE THOUSAND FIFTY-EIGHT AND 00/100
Dollars (U.S. S 265, 058.00
plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of
the loan proceeds by Lender, at the rate of FIVE AND 500/1000
percent
( 5.500 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, decd of trust or similar security instrument that is dated
the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from
losses which might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the 1St day of each month beginning
on AUGUST 1, 2009 . Any principal and interest remaining on the 1st day of
JULY, 2039 will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at PO BOX 986, NEWARK, NEW JERSEY 07184-0986
as Lender may designate in writing by notice to Borrower. of at su.•Ir other place
(C) Amount
Each monthly payment of principal and interest will be in the amount ofU.S. S 1,504.97
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to
principal, interest and other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants
of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge
were a part of this Note.
MULTISTATE - FHA FIXED RATE NOTE
USFHA.NTE 05101/08 Page I of 3 D-Iftgke- ?-.: •= 800-646-1362
www.doomagie.cofn
I Y? NIT IdII IIII ?? INI ?I NI NI?NI ?I III I? ?I NW VNI IIIN l1N 1111
(Check applicable box.)
? Growing Equity- Allonge
? Graduated Payment Ailonge
? Other jspecity]:
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty,
on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest
on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by' regulations
of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount
of the monthly payment unless Lender agrees in writing to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in
Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late
charge in the amount of FOUR AND 000/1000
of the overdue amount of each payment. percent( 4.000 %)
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults. require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiting its rights in
the event of any subsequent default. In many circumstances, regulations issued by the Secretary will limit Lender's
rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration
when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and
Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including-reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited
by applicable law. Such fees and costs shall hear interest from the date of disbursement at the same rate as the
principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice
of dishonor. "Presentment" means the right to require Lender to demand payment of amount. due. "Notice of
Dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note
will be given by delivering it or by mailing it by first class mail to Borrower at the Property Address above or at a
different address if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by delivering it or by mailing it by first
class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is an%en a notice of
that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises
made in this Note, including the promise to pay the full amount owed. Any person who is it guarantor, surety or
endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including
the obligations of a guarantor, surety or endorser of this Note. is also obligated to keep all of the promises made in
MULTISTATE: FHA FIXED RATE NOTE
USFHA.NTE 05/01108 Page 2 of 3 DOCaligle a- Z 800-649-1362
www.docmagie.co.
11 IN N 11111 if 111111111111111111 ill , 11 11111JI M 11111111111111111111
this Note. Lender may enforce its rights under this Note against each person individually or against all signatories
together. Any one person signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BEL4 Borrowcr acceptyand agrees to the terms and covenants contained in this Note.
(Seal)
P - HO m -Borrower
- (Seal)
-Borrower
_ (Seal)
-Borrower
- (Seal)
-Borrower
- (Seal)
-Borrower
_ (Seal)
-Borrower
(Siyn Original OnhJ
MULTISTATE - FHA FIXED RATE NOTE DoeMagic K-: ^a•.w, 600-648.1362
USFHA.NTE 05/01108 Page 3 of 3 www.dDcmagic.com
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?; . AL -ONGE TO NOTE
LOAN#: 2009029540
PROPERTY ADDRESS: 3602 Golfview Drive, Mechanicsburg, Pennsylvania
17050
PRINCIPAL BALANCE: $265,058.00
ALLONGE TO NOTE DATED: JUNE 12, 2009
INFAVOR OF: LEND AMERICA, A NEW YORK CORPORATION
AND EXECUTED BY: Dean P. Hoffman
PAY TO THE ORDER OF:
at
WITHOUT RECOURSE. LEND AMERICA, A NEW YORK CORPORATION
BY
3W N LUCAS
TITLE: VICE PRESIDENT
ALLONGE TO NOTE
ATN.LSR 11/24108 DOCM89%C C91'?: W 800.640-1362
www. doemsgk. com
III?I IBINII ill 11111111111111.1111111111111111111111111
Exhibit "A-2"
III Record 1st
Q J ` X ASSIGNMENT OF MORTGAGE
\ KNOW ALL MEN BY 'ITIRSE PRESENT'S that MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,
INCORPORATED AS A NOMINEE FOR LEND AMERICA, ITS SUCCESSORS AND ASSIGNS hereinafter
Assignor the holder of the Mortgage hereinafter mentioned, for and in consideration of the sum of ONE DOLLAR ($1.00)
lawful money unto it in hand paid by GOVERNMENT NATIONAL MORTGAGE ASSOCIATION, "Assignee," the receipt
whtmof Ts acknowledged, has granted, bargained, sold, assigned, transferred and set over unto the said Assignee, its successors
and assigns, ALL THAT CERTAIN Indenture of Mortgage given and executed by DEAN P. HOFFMAN to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR LEND AMERICA, ITS
SUCCESSORS AND ASSIGNS, hearing the date 06112/2009, in the amount of $265,058.00, said Mortgage being recorded on
0710612009 in the County of CUMBERLAND, (commonwealth of Pennsylvania, in Mortgage Instrument No. 200922950,
MIN: 100286"20090295400 HERS Phone#-1-888-679.6377.
Being Known as Premises: 3602 GOLFVIEW DRIVE, MECHANICSBURG, PA 17050-2216
Parcel No: 10-17-1037-099-
The transfer of the mortgage and accompanying rights was effective at the time the loan was sold and consideration passed to the
Assignor. This assignment is solely intended to describe the instrument sold in a manner sufficient to put third parties on public
notice of what has been sold.
Together with all Rights, Remedies and incidents thereunto belonging. And all its Right, 'title, Interest, Property, Claim and
Demand, in and to the same:
TO HAVE, HOLD, RECEIVE AND TAKE, all and singular the hereditaments and premises granted and assigned, or mentioned
and intended so to be, with the appurtenances unto Assignee, its successors and assigns, to and for its only proper use, benefit and
behoof forever-, subject, nevertheless, to the equity of redemption of said Mortgagor in the said Indenture of Mortgage named,
and his/her/their heirs and assigns therein.
IN WI SS WH REOF, the said (signor has caused this document to be duly executed by its proper officers this L1111-
day of , 201
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR LEND
AMERICA, SUCCESSORS4 ASSIGrJS
>r2 t?l,,ltJJ
By.
Sealed and Delivered Name: TRTS MCLANE
in the presence of us; Title: VICE PRESIDENT
State of VIRGINIA
ss.
City of VIRGINIA BEACH
r't /
on this doy of z0Ibefore me, the subscriber, personally appeared IRIS
MCLANE, who acknowledged him herself to be the VICE PRESIDENT of MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INCORPORATED AS A NOMINEE: FOR LEND AMERICA, ITS SUCCESSORS AND ASSIGNS, and that
helshe, as such VICE PRESIDENT,- being authorized to do so, executed the foregoing instrument for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my
stamp/Seal:
My Commission Expires:
Public
NOTARY PUBLIC
REGISTRATION # 7069247
COMMONWEALTH Of VIRGINIA
MY COMMISSION EXPIRES
The precise address of the within named
Assignee is:
550 121" St SW Potomac Center, South
Towers
Was Mgt I D?Zd 4.
By: (For Assignee)
After recording return to:
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Document Execution
PHS # 280158
ALL THOSE CERTAIN tract or parcel of land and premises, situate, lying and being in the
Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows;
BEGINNING at a point on the North side of Golfview Drive at the dividing line between Lots
Nos. 376 and 377 of the hereinafter mentioned Plan, said point being 125.04 feet West of the
intersection of Golfview Drive and Kent Drive; thence along the North side of Golfview Drive
North 79 degrees 33 minutes 40 seconds West a distance of 65.05 feet to a point; thence along
the same by a curve to the left having a radius of 590.00 feet, an are length of 33.95 feet to a
point at Lot No. 378; thence along Lot No. 378 North 07 degrees 08 minutes 31 seconds East a
distance of 162.67 feet to a point at lands now or formerly of Hampden Square Ltd.; thence
along said land now or formerly of Hampden Square Ltd. North 75 degrees 21 minutes 49
seconds East a distance of 37.57 feet to a point; thence along the same South 37 degrees 33
minutes 40 seconds East a distance of 100.00 feet to a point at Lot No. 376; thence along Lot No.
376 South 10 degrees 26 minutes 20 seconds West a distance of 110.44 feet to a point, the place
of BEGINNING.
CONTAINING 15,717 square feet.
BEING Lot No. 377, Final Subdivision Plan No. 3, Hampden Square, said Plan being recorded
in Plan Book 43, page 139, Cumberland County.
BEING THE SAME PREMISES which R. Jerome Frost, a/k/a Robert J. Frost and Annette M.
Frost, husband and wife, by deed dated January 15, 2002 and recorded March 15, 2002 in Book
250, Page 3878 at the Cumberland County Recorder of Deeds Office, granted and conveyed unto
Robert J. Frost and Annette M. Frost, husband and wife, Grantors herein.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201207311
Recorded On 3/13/2012 At 8:20:53 AM
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number -103803 User ID - SW
* Mortgagor - HOFFMAN, DEAN P
* Mortgagee - GOVERNMENT NATIONAL MTG ASSOC
* Customer - JAM TRANSFERS
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $50.50
I Certify this to be recorded
in Cumberland County PA
?
RECORDER O4 D2DS
* Total Pages - 3
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
1111111111111111111111111
Exhibit "A-3"
67
Record 2nd
Q '??? ASSIGNMENT OF MORTGAGE
KNOW ALL MEN BY THESE PRESENTS that GOVERNMENT NATIONAL MORTGAGE ASSOCIATION
hereinafter Assignor the holder of the Mortgage hereinafter mentioned, for and in consideration of the sum of ONE
DOLLAR ($1.00) lawful money unto it in hand paid by LOANCARE, A DIVISION OF FNF SERVICING, INC.,
"Assignee," the receipt whereof is acknowledged, has granted, bargained, sold, assigned, transferred and set over unto
the said Assignee, its successors and assigns, ALL THAT CERTAIN Indenture of Mortgage given and executed by
DEAN P. HOFFMAN to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A
NOMINEE FOR LEND AMERICA, bearing the date 06/12/2009, in the amount of $265,058.00, said Mortgage
being recorded on 07/06/2009 in the County of CUMBERLAND, Commonwealth of Pennsylvania, in Mortgage
Instrument No. 200922950.
Being Known as Premises: 3602 GOLFVIEW DRIVE, MECHANICSBURG, PA 17050-2216
Parcel No: 10- 17-1037-099-
The transfer of the mortgage and accompanying rights was effective at the time the loan was sold and consideration
passed to the Assignor. This assignment is solely intended to describe the instrument sold in a manner sufficient to put
third parties on public notice of what has been sold.
Together with all Rights, Remedies and incidents thereunto belonging. And all its Right, Title, Interest, Property,
Claim and Demand, in and to the same:
TO HAVE, HOLD, RECEIVE AND TAKE, all and singular the hereditaments and premises granted and assigned, or
mentioned and intended so to be, with the appurtenances unto Assignee, its successors and assigns, to and for its only
proper use, benefit and behoof forever; subject, nevertheless, to the equity of redemption of said Mortgagor in the said
Indenture of Mortgage named, and his/her/their heirs and assigns therein.
IN SS WHEREOF, the s rd Assignor s caused these presents to be duly executed by its proper officers
this V y of?x?_&, 20 tr
GOVERNMENT NATIONAL MORTGAGE ASSOCIATION,
By: Loancare, a Division of FNF Servicing, Inc.,
As Attorney in Fact under a Limited Power of Attorney
By -\--? -O-
Scaled and Delivered Name:
in the presence of us; Title: VICE PRESIDENT
State of VIRGINIA ?0 (,e e- o ? YWre w
ss.
City of VIRGINIA BEACH : f ?/ ,
-On this ! day of 4? l6w?, 20//, before me, the subscriber, personally
appeared -\X , who acknowledged him/herself to be the ASSISTANT SECRETARY
for Loancare, a division of FNF Servicing, Inc., As Attorney in Fact under a Limited Power of Attorney for
GOVERNMENT NATIONAL MORTGAGE ASSOCIATION, and that he/she, as such VICE PRESIDENT, being
authorized to do so, executed the foregoing instrument for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set myh an official seal 9 0?i
Stamp/Seal: mory Public Zf
.w,r.
Z CHERYL L. PARKER
NOTARY PUBLIC
The precise address of the within named After recording return to: REGISTRATION # 7069247
Assignee is: Phelan Hallman & Schmieg, LLP COMMONWEALTH OF VIRGINIA
3637 SENTARA WAY 1617 JFK Boulevard, Suite 1400 MY COMMISSION EXPIRES
VIR NIA BEAC 23452 One Penn Center Plaza Docu JUNE 30t 201 4
By:_ Philadelphia, PA 19103 PHS # 280158
(For Assignee) "
ALL THOSE CERTAIN tract or parcel of land and premises, situate, lying and being in the
Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the North side of Golfview Drive at the dividing line between Lots
Nos. 376 and 377 of the hereinafter mentioned Plan, said point being 125.04 feet West of the
intersection of Golfview Drive and Kent Drive; thence along the North side of Golfview Drive
North 79 degrees 33 minutes 40 seconds West a distance of 65.05 feet to a point; thence along
the same by a curve to the left having a radius of 590.00 feet, an arc length of 33.95 feet to a
point at Lot No. 378; thence along Lot No. 378 North 07 degrees 08 minutes 31 seconds East a
distance of 162.67 feet to a point at lands now or formerly of Hampden Square Ltd.; thence
along said land now or formerly of Hampden Square Ltd. North 75 degrees 21 minutes 49
seconds East a distance of 37.57 feet to a point; thence along the same South 37 degrees 33
minutes 40 seconds East a distance of 100.00 feet to a point at Lot No. 376; thence along Lot No.
376 South 10 degrees 26 minutes 20 seconds West a distance of 110.44 feet to a point, the place
of BEGINNING.
CONTAINING 15,717 square feet.
BEING Lot No. 377, Final Subdivision Plan No. 3, Hampden Square, said Plan being recorded
in Plan Book 43, page 139, Cumberland County.
BEING THE SAME PREMISES which R. Jerome Frost, a/k/a Robert J. Frost and Annette M.
Frost, husband and wife, by deed dated January 15, 2002 and recorded March 15, 2002 in Book
250, Page 3878 at the Cumberland County Recorder of Deeds Office, granted and conveyed unto
Robert J. Frost and Annette M. Frost, husband and wife, Grantors herein.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201207313
Recorded On 3/13/2012 At 8:20:55 AM
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number -103803 User ID - SW
* Mortgagor - HOFFMAN, DEAN P
* Mortgagee - GOVERNMENT NATIONAL MTG ASSOC
* Customer - JAM TRANSFERS
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $50.50
* Total Pages - 3
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
RECORDER O D EDS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
1111111111111111111
Exhibit "B"
Loan Care, a Division of FNF Servicing, Inc.
3637 Sentara Way
Virginia Beach, VA 23452
Plaintiff
VS.
Dean P. Hoffman a/k/a Dean Paul Hoffman
3602 Golfview Drive
Mechanicsburg, PA 17050
Defendant
: Court of Common Pleas
: Civil Division
: Cumberland County
: No. 11-7442-CIVIL
PLAINTIFF S AFFIDAVIT IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT
STATE OF V i rq n a,
C?OF V(VQI la? ss.
)
1:4 C5 _, being duly sworn according to law, deposes and says:
1. I am employed in the capacity of V QSL-Rc 12-? at Loan
Care, a Division of FNF Servicing, Inc., mortgage servicing agent for Plaintiff in the
within matter.
2. In said capacity, I am familiar with the account that forms the basis of the
instant
foreclosure action and am authorized to give this Affidavit.
I have reviewed the books, records, loan documents, and loan history
pertaining to the Defendant s Residential Mortgage loan being serviced by Loan Care, a
Division of FNF Servicing, Inc..
4. All proper payments made by Defendant have been credited to
Defendant s account.
Defendant s mortgage payments due March 1, 2011 and each month
thereafter are due and unpaid.
6. The amounts due on the mortgage were correctly stated in the Complaint
as
follows:
Principal Balance $259,312.30
Interest $9,467.12
February 1, 2011 through October 1, 2011
(Per Diem $39.0745)
Cumulative Late Charges $393.45
Escrow Deficit 670.99
TOTAL $269,843.86
7. Defendant has failed to reinstate the account or offer any reasonable
solution to cure the arrears on the past due mortgage payments.
Plaintiff provided Defendant with a Notice of Intention to Foreclose
Mortgage, but Defendant did not take the necessary affirmative steps to avoid
foreclosure.
The subject mortgage is insured by the Federal Housing Administration.
10. Plaintiff continues to suffer unjust financial losses as it pays the taxes and
insurance on the property as they become due to avoid a tax upset sale and/or loss to its
collateral, all of which accrues to the benefit of Defendant and to the severe detriment of
Plaintiff.
11. Plaintiff properly accelerated its mortgage to protect its interests.
ol,? IAAl.r,(C"
Name: -1C ,S
Title: V Ice,
Loan Care, a Division of FNF
Servicing, Inc.
On thic I % II day of ?eI4021060e" _ 2(l//_ before me a notarv
public, the undersigned officer, personally appeared the above named person, known to
me (or satisfactory proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that she/he executed the same for the purposes therein
contained.
In witness hereof, I hereunto set my hand and official seal.
,/,
Stamp/Seal:
CHERYL L. -PARKER
NOTARY
REGISTRATION #PUBLIC 069247
COMMONWEALTH OF VIRGINIA
8040MMMISSION EXPIRES
JUNE 30, 2014
Public
File Name: Dean P. Hoffman a/k/a Dean Paul
Exhibit "C"
PHELAN HALLINAN & SCHMIEG, LLP
Allison F. Wells, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
280158
LOANCARE, A DIVISION OF FNF SERVICING,
INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
V. Plaintiff NO I 1,- -1 14q2 e i m
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN CUMBERLAND COUNTY
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
Defendant
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
A e
ue 41(
aIi ?1 a1?a, t
File #: 280158
ATTORNEY FOR PLAINTIFF
PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
NOTICE
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.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File #: 280158
Plaintiff is
LOANCARE, A DIVISION OF FNF SERVICING, INC.
3637 SENTARA WAY
SUITE 303
VIRGINIA BEACH, VA 23452
2. The name(s) and last known address(es) of the Defendant(s) are:
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 06/12/2009 DEAN P. HOFFMAN made, executed and delivered a mortgage upon the
premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INCORPORATED AS A NOMINEE FOR LEND AMERICA which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Instrument No. 200922950. The PLAINTIFF is now the mortgagee and is in
the process of formalizing an assignment of same. The mortgage and assignment(s), if
any, are matters of public record and are incorporated herein by reference in accordance
with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach
documents to pleadings if those documents are of public record.
The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 03/01/2011 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
Pile #: 280158
6. The following amounts are due on the mortgage as of 10/01/2011:
Principal Balance $259,312.30
Interest $9,467.12
02/01/2011 through 10/01/2011
Late Charges $393.45
Escrow Deficit 670.99
TOTAL $269,843.86
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$269,843.86, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN
Cls, Es4uire
Attorney for Plain
File #: 280158
LEGAL DESCRIPTION
ALL THOSE CERTAIN tract or parcel of land premises, situate, lying and being in the township
of Hampden in the county of Cumberland and commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the north side of Golfriew drive at the dividing line between lots nos.
376 and 377 of the hereinafter mentioned plan, said point being 125.04 feet west of the
intersection of Golfview drive and Kent drive; thence along the north side of Golfview drive
north 79 degrees 33 minutes 40 seconds west a distance of 65.05 feet to a point; thence along the
same by a curve to the left having a radius of 590.00 feet, an arc length of 33.95 feet to a point at
lot no. 378; thence along lot no. 378 north 07 degrees 08 minutes 31 seconds east a distance of
162.67 feet to a point at :lands now or formerly of Hampden square Ltd.; thence along said laud
now or formerly of Hampden Square Ltd. north 75 degrees 21 minutes 49 seconds east a distance
of 37.57 feet to a point; thence along the same south 37 degrees 33 minutes 40 seconds east a
distance of 100.00 feet to a point at lot no. 376; thence along lot no. 376 south 10 degrees 26
minutes 20 seconds west a distance of 110.44 feet to a point, the place of beginning.
CONTAINING 15,717 square feet.
PROPERTY ADDRESS: 3602 GOLFVIEW DRIVE, MECHANICSBURG, PA 17050-2216
PARCEL 9 10-17-1037-099-
File #: 280158
VERIFICATION
hereby states that he/she is qla- TrO-St of, LOANCARE,
A DIVISION OF FNF SERVICING, INC., Plaintiff in this matter, that he/she is authorized to
make this Verification, and verify that the statements made in. the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and
belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
DATE: t ? i --? - -
File #: 280158 LT
Name: HOFFMAN
r-?N -?? ---'
Nance: c-N
lJ Ls _.3
Title: %,
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
File#: 280158
Exhibit "D"
Dean P. Hoffman
3602 Golf View Drive
Mechanicsburg, PA 17050
Defendant
X59
A2K
State of Pennsylvania
Cumberland County Court of
Common Pleas, Civil Division
Loancare, a division of FNF Servicing, Inc.,
PLAINTIFF
-v-
Dean P. Hoffman,
DEFENDANTS
Docket Number: 11-7442 Civil
ANSWER TO
FORECLOSURE COMPLAINT
Defendant, Dean P. Hoffman, answers Plaintiff s Complaint as follows:
1. Defendant admits to the following paragraphs of the Complaint: 2, 4
2. Defendant denies the following paragraphs of the Complaint: 6
3. Defendant lacks knowledge with regards to the following paragraphs of the Complaint: 1, 3, 5,
7,8
AFFIRMATIVE DEFENSES
1. Plaintiff fails to provide documented proof of the alleged mortgage default.
2. Plaintiff fails to provide documented evidence that it the current owner of this mortgage
note and therefore lacks standing to sue.
WHEREFORE, Defend gut, D P. Hoffman, request Judgment dismissing Plaintiffs Complaint
and for-sac ther relief as ourt deems fit.
Dean P. H"o - -
Defendant 17-r-o Se
DATED: October 4, 2011
Exhibit "E"
PHELAN HALLINAN & SCHMIEG, LLP
BY: Joseph P. Schalk, Esquire
Identification No.: 91656
Mario J. Hanyon, Esquire
Identification No.: 203993
126 Locust Street
Harrisburg, PA 17101
(215) 563-7000
Loan Care, a Division of FNF Servicing, Inc
Plaintiff
VS.
Attorneys for Plaintiff
COURT OF COMNfOht:PLEAS
Cumberland County`"' .y'-a
CIVIL DIVISION t*
e
Dean P. Hoffman a/k/a Dean Paul Hoffman
Defendant
No. 11-7442-CIVIL
PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER
Plaintiff, Loan Care, a Division of FNF Servicing, Inc., by its attorney, Mario J. Hanyon, Esquire,
hereby files the within Reply to New Matter of Defendant Dean P. Hoffman a/k/a Dean Paul Hoffman
and states as follows:
Plaintiff incorporates herein by reference the averments of paragraphs one (1) through eight (8)
of its Complaint as if set forth herein at length.
9. The averments of Defendant's affirmative defense in paragraph one (1) is denied. By way
of further answer, the allegations set forth in paragraph one (1) does not serve as a defense to the
foreclosure action. By way of further answer, Plaintiff s Complaint complies with the applicable Rules
280158
of Civil Procedure governing actions in mortgage foreclosure.
10. The averments of paragraph two (2) of Defendant's affirmative defense are denied. By
way of further answer, the Plaintiff is in the process of formalizing an Assignment and is now the
Mortgagee and under the law of Assignments, the Assignee stands in the same shoes as the Assignor.
The Assignment does not confer the Assignee any greater rights than those possessed by the Assignor.
Pennsylvania Higher Education Assistance v Debore, 67 Pa.Super 74, 416 A.2d 343, 344 (1979); U.S.
------- --------- __-.---
Steel Homes Credit Corporation v. South Shore Development Corporation, 277 Pa.Super 3808, 419
A.2d 785 (1980). Furthermore, the Superior Court has held that a party is not required to have an
assignment recorded prior to filing a complaint in mortgage foreclosure. US Bank N.A. v. Mallory,
2009 Pa. Super. 182, ¶ 18 (2009). Therefore, the Plaintiff is the proper party and has standing to bring
this suit for Defendant's failure to tender monthly payments.
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and
against Defendant as requested in Plaintiffs Complaint.
Respectfully submitted,
PHELAN HALLINAN & SCHMIEG, LLP
Date: - By;
[anyon, Esquire
for Plaintiff
280158
VERIFICATION
Joseph P. Schalk, Esquire, hereby states that he is the attorney for the Plaintiff in this action, that
he is authorized to make this verification, and that the statements made in the foregoing Reply to New
Matter are true and correct to the best of his information and belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S.
§4904 relating to unswom falsifications to authorities.
PHELAN HALLINAN & SCHMIEG, LLP
Date: _ j b BY: ?-' ?n?A 'r?- Z U
ose h P Schalk. Esouire
J. Hanyon, Esquire
ey for Plaintiff
>cust Street
)urp-. PA 17101
(215) 563-7000
280158
------PHELAN
BY: Mario J. Hanyon, Esquire
Identification No.: 203993
126 Locust Street
Harrisburg, PA 17101
(215) 563-7000 Attorneys for Plaintiff
Loan Care, a Division of FNF Servicing, Inc.
Plaintiff
COURT OF COMMON PLEAS
Cumberland County
CIVIL DIVISION
vs.
Dean P. Hoffman a/k/a Dean Paul Hoffman
Defendant
No. 11-7442-CIVIL
CERTIFICATION OF SERVICE
I certify that a true and correct copy of Plaintiff's Reply to Defendant's New Matter was sent via
first class mail to the person listed below on the date indicated:
Dean Paul Hoffman, Pro Se
3602 Golfview Drive
Mechanicsburg, PA 17050
Date: 4 L
[anyon, Esquire
for Plaintiff
280158
Exhibit "F"
Date: Mav 4, 2011
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on .your home is in default, and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM (HEMAP) may be able to help to save your home. This Notice
explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER
CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF
THIS NOTICE. Take this Notice with you when you meet with the
Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions,
you mac all 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 IMPORANCIA, PLIES
AFECTA SU DERECHO A CONTINUAR VIVENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA
TRADUCCION INMEDIATAMENTE LLAMANDA ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR
EL PROGRAMA LLAMDO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Dean P Hoffman
3602 Golfview Drive
Mechanicsburg PA 17050
GNMA
LoanCare
HOMEOWNER'S 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 (30) days from the date of this
Notice (plus three (3) days for mailing). During that time you must arrange and attend
a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS OF
THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO
DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this notice, the lender may NOT
take action against you for thirty (30) days after the date of this meeting. The names,
addresses and 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.) 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 forwarded to PHFA and received within thirty (30) days of your face-to-face
meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATIONAS SOONAS POSSIBLE. IF YOU HAVE
A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK
DATE OF THIS NOTICE AND FILE ANAPPLICA77ON WITH PHFA WITHIN 30 DAYS
OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILYPREVENTED
FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED
ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILEA HEMAPAPPLICATIONEVENBEYOND THESE
TIME PERIODS. ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM
STARTINGA FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS 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 Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that time, no foreclosure proceedings
will be pursued against you if you have met the time requirements set forth above. You
will be notified directly by the Pennsylvania Housing Finance Agency of its decision on
your application.
NOTE: THIS' COMMUNICATION IS FROM A DEBT COLLECTORAND IS AN ATTEMPTTO
COLLECT A DEBT. ANY INFORM,ATIOIN'OBTAINED MAY BE USED:FOR THAT PURPOSE. IF
VOLT ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, HE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION` PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
„(It you, have filed bankruptcy you can still apply for Emergency Mortgage. Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your
property located at: 3602 Golfview Dr, Mechanicsburg PA 17050
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 payments from 03-01-11 thru 05-04-11
(mos. At $/month) $5,901.48
(b) Late charges from 04-18-11 thru 05-04-11
(mos. at $/month) $78.69
(c) Other charges; Escrow, Inspec., NSF Checks $685.00(lnspections and Attorney Fees)
(d) Other provisions of the mortgage obligation, if any
TOTAL AMOUNT PAST DUE: 6,665.17
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 $ 6,665.17 , 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;
LoanCare, a Division of FNF Servicing, Inc.
3637 Sentara Way
Virginia Beach, VA 23452
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 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 attorneys' 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 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 Sheriff s 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: LoanCare, a Division of FNF, Inc.
Address: 3637 Sentara Way
Virginia Beach, VA 23452
Phone Number: 1-800-909-9525
Fax Number: 1-757-466-2828
Contact Person: Shawn Middleton
E-Mail Address: LC-lossmitigation@loancare.net
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 or _ may not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will assume the mortgage debt,
provided that all the outstanding payments, charges and attorney's fees and costs are paid
prior to or at the sale and that the other requirements of the mortgage are satisfied.
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.
HEMAP Consumer Credit Counseling Agencies
Report last updated: 8/1/2008 10:08:21 AM
ADAMS County Mon Valley Unemployment Committee
1800 West Street
Adams County interfaith Housing Authority 3rd Floor
40 E High Street Hcmestead, PA 15120
Gettysburg, PA 17325 412.462.9962
717.334.1518
Nazareth Housing Services
American Red Cross - Hanover Chapter 301 Bellevue Road
529 Carlisle Street Pittsburgh, PA 15229
Hanover, PA 17331 412.931.6996
717, 637,3768
Neighborhood Housing Services, no.
CCCS of Westem PA 710 5th Avenue
2000 Linglestown Road Suite 1000
Harrisburg, PA 17102 Pittsburgh, PA 15219
888.511.2227 412.281.9773
888.511.2227
Pennsylvania Housing Finance Agency
Maranatha 2275 Swallow Hill Road
43 Philadeiphia Avenue Bldg 200
Waynesboro, PA 17268 Pittsburgh, PA 15220
717.762.3285 412.429.2842
ALLEGHENY County Urban League Of Pittsburgh
Acorn of Allegheny County 610 Wood Street
5907 Penn Avenue Pittsburgh, PA 15222
Suite 300 412.227.4802
Pittsburgh, PA 15206 ARMSTRONG County
412,441.6551
Armstrong County Community Action Agency
Action Housing, Inc • 124 Armsdale Road
425 6th Avenue Suite 211
Suite 950 Kittanning, PA 16201
Pittsburgh, PA 15219 724.548.3405
412.281.2102
800.792.2801 CCCS of Western PA
Royal Remax Plaza
CCCS of Western PA 917 A Logan Boulevard
River Park Commons Altoona, PA •16602
2403 Sidney Street, Suite 400 888.511.2227
Pittsburgh; PA 15203 868.511.2227
888 51 1.2227
888.511.2227 Indiana Co. Community Action Program
827 Water Street
Community Action Southwest Box 187
58 East Greene Street Indiana, PA 15701
Waynesburg, PA 15370 724.465.2557
724.852.2893
Fair Housing Partnership of Greater Pittsburgh, Inc
2840 Liberty Avenue
Suite 205
Pittsburgh, PA 15222
412.391.2535
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
41"-:665.5200
BEAVER County
Action Housing; Inc
425 6th Avenue
Suite 950
Pittsburgh, PA 16219
412.281.2102
800.792.2801
Pagel of 18
HEMAP Consumer Credit Counseling Agencies
Report last updated: 81112008 10:08:21 AM
CCCS of Western PA CCCS of Lehigh Valley
971 Third Street 36671 Crescent Court East
Beaver, PA 15009 Whitehall, PA 18052
888.511.2227 61 0.821,4011
888.511.2227 800.837.9815
Housing Opportunities of Beaver County ; Community Action Committee
320 College Avenue of the Lehigh Valley
unit 1 .1337 l=ast Fifth Street
Beaver, PA 15009 Bethlehem, PA 18015
724.728.7511 510.691.5620
BEDFORD County Neighborhood Housing Services of Reading
213 N 5th Street
CCCS of Western PA Suite 1030
Royal Remax Plaza Reading, PA 19601
917 A Logan Boulevard 610.372.8433
Altoona, PA 16602
,888.511.2227
'08
511
2227 Schuylkill Community Action
.
. 225 N. Centre Street
Pottsville, PA 17901
Tableland Services Inc, 570.622.1995
535 East Main Street
Somerset, PA 15501 BLAIR County
814,445.9628
800.452.0148 Blair County Community Action Agency
2100 6th Avenue Suite 102
BERKS County PO Box 1833
Altoona, PA 16602
American Credit Counseling Institute 814,946,3651
9.37 North Hanover Street
Pottstown, PA 19460 CCCS of Northeastern PA
888.212.6741 202 W. Hamilton Avenue
888.212.6741 State College, PA 16801
814.238.3668
American Credit Counseling Institute 800.922.9537
300 North Pottstown Pike
Suite 210 CCCS of Western PA
Exton, PA 19341 Royal Remax Plaza
888.212.6741 917 A Logan Boulevard
888,212,6741 Altoona, PA 16602
888.511.2227
American Financial Counseling Services 888.511.2227
2880 Bergey Road
Suite 4 13RADFORD County
Hatfield, PA 19440
267.228.7903 CCCS of Northeastern PA
411 Main Street
American Financial Counseling Services Suite 104
906 Penn Avenue Stroudsburg, PA 18360
Wyomissing, PA 19610 570.420,8980
267,228.7903 800
922
9537
BO.b,490,3039 .
.
CCCS of Northeastern PA
Budget Counseling Center 401 Laurel Street
247 North Fifth Street Pittston, PA 18640
Reading, PA 19601 570.602.2227
610.375.7856 600.922.2537
,11k,
aim+!
Page 2 of 18
HEMAP Consumer Credit Counseling Agencies
Report last updated: 811/2008 10:08:22 AM
The Trehab Center of Northeastern PA Sucks County Housing Group
1225 Main Street 470 Old Dublin Pike
Honesdale, PA 18431 Doylestown, PA 18901
570.253,8941 866.866.0280
800, 982,4045 866.866.0280
The Trehab Center of Northeastern PA Bucks County Housing Group
The Enterprise Center 515 West End Boulevard
703 S. Elmer Avenue Suite M.6 Quakertown, PA 18951
Sayre, PA 18840 866.866,0260
570.888.0412 866.866.0280
800.982.4045
Bucks County Housing Group
'BUCKS County 349 Durham Road
Penncial, PA 19047
Acorn Housing Corporation 866.866.0280
846 North Broad Street 866.886.0280
Philadelphia, PA 18130
X,, 15.765
, .1221
Bucks County Housing Group
200 West Bridge Street
American Credit Counseling Institute Morrisville, PA 19067
937 North Hanover Street 866.866.0280
Pottstown, PA 19460 866.866.0280
888.212.6741
888,212.6741 Bucks Count w- s' G
American Credit Counseling Institute
530 West Street Road
Suite 201
Warminster, PA 18974
215.444.9429
888,212.8741
American Credit Counseling Institute
300 North Pottstown Pike
Suite 210
Exton, PA 19341
888,212,6741
888.212.6741
American Credit Counseling Institute
845 Coates Street
Coatesville; PA 19320
888.212.6741
888.212.6741
American Financial Counseling Services
175 Trafford Avenue
Suite One
Wayne, PA 19087
267.228.7903
800:490.3039
American Financial Counseling Services
1917 Welsh Road
Philadelphia, PA 19115
267.228.7903
r
rt
Y u rng coup
2324 Second Street Pike
Sulte 17
Wrightstown, PA 18940
866.886.0280
866.866.0280
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
215.563.5665
CCCS of Delaware valley
1608 Walnut Street
10th Floor
Philadelphia, PA 19107
215.563.5665
CCCS of Delaware Valley
1230 New Rodgers Road
Suite F1
Bristol, PA 19007
215.563, 5665
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, °A 18052
610.821.4011
800,837,9815
Credit Counseling Center
832 Second Street Pike
Rlchboro, PA 18954
215.396.1880
Page 3 of 18
HENiAP Consumer Credit Counseling Agencies
Report last updated: 8/1/2008 10:08:22 AM
"Diversified Community Services Indiana Co. Community Action Program
Dixon House 827 Water Street
1920 South 20th Street Box 187
Philadelphia, PA 19145 Indiana, PA 15701
215.336.3511 724.465.2657
FOB CDC Tableland Services Inc.
1201 West Olney Avenue 535 East Main Street
Phlaldelphia, PA 19141 Somerset, PA 15501
215,549.8755 814.445.9628
8oo•452.0148
'Germantown Settlement
5538 Wayne Avenue The NORCAM Group
4ldg C 4200 Crawford Avenue
Philadelphia, PA 19144 Suite 200
215.849.3104 Northern Cambria, PA 15714
814.948.4444
-RACE
, 7'N. AllaghonyAvenue CAMERON County
end FI
Philadelphia, PA 19140 CCCS, of Weston PA
215.426.8025 The Franklin Center !
524 Franklin Avenue
Northwest Counseling Service Aliquippa, PA 15001
5001 North Broad Street 888.511.2227
Philadelphia, PA 19141 `888.511.2227
215,3247500 !
Northern Tier Community Action Corp, i
Urban League of Philadelphia P•0. Box 389
1818 Market Street 135 West 4th Street
20th Floor Emporium, PA 15834
Philadelphia, PA 19103 814.485,1161
215.561.6070
CARBON County
BUTLER County
CCCS of Lehigh Valley
Action Housing, Inc 3671 Crescent Court East
425 6th Avenue Whitehall, PA 18052
Suite 950 610.821.4011
Pittsburgh, PA 152'9 800.837.9815
412.281.2102
80'0,792.2801 CCCS of Northeastern PA I
401 Laurel Street
CCCS of Western PA Pittston, PA 18640
Butler County Career Link Pullman Commerce Center 570.602.2227
112 Hollywood Drive 6D0.922.9537
Butler, PA 16001
888.511.2227 CCCS of Northeastern PA
886,511.2227 411 Main Street
Suite 104
CAMBRIA County Stroudsburg, PA 18360
570.420.8980
CCCS of Western PA 800.922.9537
Royal Remax Plaza
9,,7,A Logan Boulevard Comm. on Econ Opportunity of Luzerne County
Altoona, PA 16602 163 Amber lane
868.5111.2227 Wiikes,Barre, PA 18702 j
89u511.2227 570.826.0510
800.822.0359
Page 4 of 16
i
HEMAP Consumer Credit Counseling Agencies
Report last updated: 8/112008 10:08:23 AM
ColmmunAyActlon Committee American Financial Counseling Services
of the Lehigh Valley 2880 Bergey Road
1337 East Fifth Street Suite 4
Bethlehem, PA 18015 Hatfield, PA 19440
610.691.5620 267.228,7903
Schuylkill Community Action American Financial Counseling Services
225 N. Centre Street '175 Trafford Avenue
Pottsville, PA 17901 Suite One I
570.622.1995 Wayne, PA 19087
CENTRE Cou
t 267,228.7903
y
n .800.490.3039
CCCS of Northeastern PA American Red Cross of Chester
,201 Basin Street
` 1729 Edgemont Avenue j
9uite 6 Chester, PA 19013
Williamsport, PA 17701 610.874.1484
570,323.6627 f
[660.922.9537 APM
lvkF 2147 North Sixth Street
CCCS of Northeastern PA Philadelphia, PA 19122
202 W. Hamilton Avenue 215.235,6788
State College, PA 16801
814.238.3668 Budget Counseling Center
800.922,9537 247 North Fifth Street
Reading, PA 19601
CCCS of Western PA 610,375.7866
Royal Remax Plaza
917 A Logan Boulevard Carroll Park Community Council, Inc,
Altoona, PA 16602 5218 Master Street
888.511.2227 Philadelphia, PA 19131
888.511.2227 215,877.1157
Lycom.Clntn Co Comm fo Comm Action CCCS of Delaware Valley
2138 Lincoln Street 790 E. Market St,
P.C. Box 3568 Suite 170, Marshall Building
Williamsport, PA 17703 West Chester, PA 19382
570.326.0587 215.563,5665
CHESTER County Chester Community Improvement Project
412 Avenue of the States
Acorn Housing Corporation PO Box 541
846 North Broad Street Chester, PA 19016
Phlladelphla, PA 19130 610,876.8663
215.765,',221
I
DiversN`led Community Services j
American Credit Counseling Institute Dixon House
21 South Church Street 1920 South 20th Street
West Chester, PA 19380 Philadelphia, PA 19145
888.212.6741 215.336.3511
888.212.6741
FOB CDC
Arerican Credlt Counseling Institute 1201 West Olney Avenue
843 Coates Street Phlaldelphla, PA 19141
Cdatesville. PA 19320 215.549,8755
888,212.6741
8881212.674' Germantown Settlement
5538 Wayne Avenue
Bldg C
4 Philadelphia, PA 19144
215, 849.3104
Page 5 cf 18
HEMCAP I?onsurner Credit Counseling Agencies
Report last updated: 81112008 10:08:23 AM
'RACE CCCS of Western PA
157 W. Allegheny Avenue Royal Remax Plaza
2nd FI 917 A Logan Boulevard
Philadelphia, PA 19140 Altoona, PA 16602
215,426,8025 888.511.2227
888.511.2227
Housing Partnership of Chester County
41 West Lancaster Ave Indiana Co. Community Action Program
Downingtown, PA 19335 827 Water Street
610.516,1522 Box 187
Indiana, PA 15701
Media Fellowship House 724.465.2657
302 South Jackson Street
(Media, PA 19063 The NORCAM Group
610.565.0434 4200 Crawford Avenue
Suite 200
,Northwest Counseling Service
8601 North Broad Street Northern Cambria, PA 15714
Kiiladelphla, PA 19141 814.948,4444
215.324.7500 CLINTON County
Phila Council For Community Advmnt CCCS of Northeastern PA
1 CC North 17th Street 201 Basin Street
Suite 600 Suite 6
Philadelp'ia, PA 19103 Williamsport, PA 17701
215.567.7803 570.323,6627
800.930.4663 800.922.9537
Tabor Community Services, Inc. CCCS of Northeastern PA
308 E King Street 202 W. Hamilton Avenue
Suite 1 State College, PA 16801
Lancaster, PA 17602 814.238.3668
717.397.5182 800.922, 9537
800.788.5062
Lycom.Cintn Co Comm to Comm Action
Urban League of Philadelphia 2138 Lincoln Street
1818 Market Street P.O. Box 3568
20th Floor
' Williamsport, PA 17703
Phlladelphia,
PA 19103 570.326,0587
215.561,6070
CLARION County
CCCS of Western PA
Butler County Career Link Pullman Commerce Center
112 Hollywood Drive
Butler, PA 16001
888,511.2227
888,511.2227
CI.,EARFIELD County
CCCS of Northeastern PA
202 W. Hamilton Avenue
3tka College, PA 16801
814.238.3668
800.922.9537
P-;
COLUMBIA County
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
570.602.2227
800.922.9537
CRAWFORD County
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
814.453.5744
CC CS of Western PA
4402 Peach Street
Erie, PA 16509
888,511.2227 ext
108
888.511.2227 ext
108
Page 6 of 18
HEMAP Consumer Credit Counseling Agencies
Report last updated: 6!1/2008 10.08:24 AM
Center for Family Services, Inc. Community Action Commission of Captlal Region
213 Center Street 1514 Derry Street
Meadville, PA 16335 Harrisburg, PA 17104
814,337.8450 717,232,9757
Greater Erie Community Action Committee Loveship, Inc.
18 West 9TH Street 2320 North 5th Street
Erie, PA 16501 Harrisburg, PA 17110
814.459.4581 717,232.2207
S,henango Valley Urban League, Inc, PHFA
601 Indiana Avenue 211 North Front Street
Farrell, PA 16121 Harrisburg, PA 17110
724.981.5310 .717.780.3940
800.342.2397
St. Martin Center
701 Parade Street DELAWARE County
Lila, PA 16503
81F4.452.6113 Acorn Housing Corporation
846 North Broad Street
CUMBERLAND County Philadelphia, PA 19130
215.765.1221
Adams County Interfaith Housing Authority
40 E High Street Advocates for Financial Independence
Gettysburg, PA 17325 202 East HlnkleyAvenue
717.334,1518 Ridley Park, PA 19078
215,389.2810
CCCS of Western PA
24.00 Linglestown Road American Credit Counseling Institute
F arrisburg, PA 17102 175 Strafford Avenue
888.511.2227 Suite 1
888.511.2227 Wayne, PA 19087
610.971.2210
Community Action Commission of Captial Region 888.212.6741
1514 Derry Street
Harrisburg, PA 17104 American Financial Counseling Services
717.232.9757 175 Trafford Avenue
Suite One
Loveship, Inc. Wayne, PA 19087
2320 North 5th Street 267.228.7903
Harrisburg, PA 17110 800.490.3039
717.232.2207
American Red Cross of Chester
Maranatha
' 1729 Edgemont Avenue
43
?hlladelphla Avenue Chester, PA 19013
Waynesboro, PA 17268 810.874,14 84
717.762.3285
APM
PHFA 2147 North Sixth Street
211 North Front Street Philadelphia, PA 19122
Harrisburg, PA 17110 215.235.6788
717'780.3940
800.342.2397 Carroll Park Community Council, Inc.
5218 Master Street
DAUPHIN County Philadelphia, PA 19131
CCCS of Western PA 215.877,1157
200V Jrglestown Road
Harrsburg, PA 17102
88r11.2227
888.511.2227
Page 7 of 18
HEMAR Consumer Credit Counseling Agencies
'Report last updated: 81112008 10:08:24 AM
CCCS of Delaware Valley Ph11a Council For Community Advmnt
1608 Walnut Street 100 North 17th Street
10th Floor suite 600
Philadelphia, PA 18107 Philadelphia, PA 19103
215.563.5665 215.567.7803
CCCS of Delaware Valley '800.930.4663
280 North Providence Road .Urban League of Philadelphia
Media, PA 19063 1818 Market Street
-2,15.563,5665 20th Floor
Philadelphia, PA 19103
.CCCS of Delaware Valley 215.561.5070
.79C E. Market St.
Suite 170, Marshall Building ELK County
West Chester, PA 19382
15.563.5665
Northern Tier Community Action Corp,
?,,-,?'t
?u'?hester Community Improvement Project P.O. Box 389
135 W
412 Avenue of the States est 4th Street
Emporium, PA 15834
PO BOX 541 814.486.1151
Chester, PA 19016
610.876.8663 ERIE COUnty
Diversified Community Services Booker T. Washington Center
Dixon House 1720 Holland Street
1920 South 20th Street Erie, PA 16503
Philadelphia, PA 19145 814.453.5744
2:1:5.336.3511 CCCS of Western PA
FaB CDC 4402 Peach Street
1201 West Olney Avenue Erie, PA 16509
Phialdelphis, PA 19141 888.511.2227 ext
108
215,549.8755
888.511.2227 ext
Germantown SefBement 108
5538 Wayne Avenue Greater Erie Community Action Committee
Bldg C 18 West 9TH Street
Philadelphla,'PA 19144 Erie, PA 16501
21.5.849.3104 814.459.4581
HACE St, Martin Center
167 W. Allegheny Avenue 1701 Parade Street
2nd F1 Erie, PA 16503
Philadelphia, PA 19140 814-452.6113
215.426.8025
Voices for Independence
Housing Partnership of Chester County 1107 Payne Avenue
41 West Lancaster Ave Erie, PA 16503
Downingtown, PA 19335 814.874.0064
610.518.1522 600,838,9890
Media Fellowship House j
FAYETTE County
302 South Jackson Street
Media, PA 19063 Action Housing, Inc
61 6.565.0434 425 6th Avenue
Suite 950
Norkhwest Counseling Service
5North Broad Street Pittsburgh, PA 15219
412.281.2102
PhTfadelphla, PA 19141
215.324.7500 800.792.2801
Page 8 of 1 8
HEMAP Consumer Credit Counseling Agencies
Report last updated: 81112008 10:08:25 AM
CCCS of Western PA Maranatha
1 North Gate Square 43 Philadelphia Avenue
#2 Garden Center Drfve Waynesboro, PA 17268
Greensburg, PA 15601 717.762.3285
868.511.2227
888.511.2227 FULTON County
Communlty Action Southwest CCCS of Western PA
58 East Greene Street Colonial Shopping Center
VW
aynesburg, PA 15370 970 S. George St
24.852.2893
7 York, PA 17403
` 888.511,2227
,Fayette Co, Community Action Agency, Inc. 888.511.2227
137 North Beeson Avenue
Uniontown, PA 15401 Maranatha
24.437.6050 43 Philadelphia Avenue
r,V,10.427INFC,
y Waynesboro, PA 17268
t 717.762.3285
Tableland Services Inc.
535 East Main Street GREENE County
Somerset, PA 15501 Action Housing, Inc
814.445.9628 425 6th Avenue
800.452,0148 Suite 950
FOREST County Pittsburgh, PA 15219
412.281.2102
Warren-Forest Counties Economic Opportunity Council -800.792.2801
1209 Pennsylvania Ave, West
P.O. Box 547 CCCS of Western PA
Warren, PA 16365 1 North Gate Square
814.726.2400 #2 Garden Center Drive
Greensburg, PA 15601
FRANKLIN County 888,511.2227
888.511.2227
Adams County Interfaith Housing Authority
4C E Hfgh Street Community Action Southwest
Gettysburg, PA 17325 58 East Greene Street
717.334.1518 Waynesburg, PA 15370
724.852,2893
American Red Cross - Hanover Chapter
529 Carlisle Street HUNTINGDON County
Hanover, PA 17331
717.637.3768 CCCS of Northeastern PA
202 W. Hamilton Avenue
CCCS of Western PA State College, PA 16801
2000 Linglestown Road 814.238.3668
Harrisburg, PA 17102 800.922.9537
888,511,2227
888.511.2227 CCCS of Western PA
Royal Remax Plaza
CCCS of Wastem PA 917 A Logan Boulevard
Cofonfal Shopping Center Altoona, PA 16602
970 S. George St 868.511.2227
York, PA 17403 888.511.2227
888.511.2227
888„511.2227
C`gomuhlty Action Commission of Captiat Region
1514 Derry Street
Harrisburg, PA 17104
717.232 9767
Page 9 of 18
HEMAP Consumer Credit Counseling Agencies
Report last updated: 8/1/2008 10:08:25 AM
INDIANA County United Neighborhood Centers of Northeastern PA
425 Alder Street
COOS of Western PA Scranton, PA 18505
1 North Gate Square 57D.346.0759
#2 Garden Center Drive
Greensburg, PA 15601 LANCASTER County
888,511,2227
888.511.2227 Base, Inc,
447 South Prince Street
Indiana Co, Community Action Program Lancaster, PA 17603
,827 Water Street 717.392.5467
Box 187
'Indlana, PA 15701 CCCS. of Lehigh Valley
724.465.2657 3671 Crescent Court East
Whitehall, PA 18052
3&F°ERSON County 610.821.4011
IRV
800,837,9818
CCCS of Western PA
Butler County Career Link Pullman Commerce Center CCCS of Western PA
112 Hollywood Drive Colonial Shopping Center
Butler, PA 16001 970 S. George St
888,511.2227 York, PA 17403
888.511.2227 868.511.2227
888.511,2227
Indiana Co. Community Action Program
827 Water Street ;Opportunity inc. i
Box 187 301 East Market Street
Indiana, PA 15701 York, PA 17403
724.465.2657 717.424.3645
JUNIATA County Tabor Community Services, Inc.
308 E King Street
CCCS of Northeastern PA Suite 1 I
202 W, Hamilton Avenue Lancaster, PA 17602
State College, PA 16801 717,397,5182
814.238.3668 800.788.5062
922.9537
800.922.9537
LAWRENCE County
CCC8 of Western PA
Royal Remax Plaza CCCS of Western PA
917A Logan Boulevard 312 Chestnut Street
Altoona, PA 16602 Suite 227
888.511.2227 Meadville, PA 16335
888.511.2227 888.511.2227
888,511.2227
LACKAWANNA County
Housing Opportunities of Beaver County
Catholic Socla! Services 320 College Avenue
Saint Catherine Manor Unit 1
5 Knox Road Beaver, PA 15009
S6'r'anton, PA 18505 724.728.75.11
570,.558.3019
Lawrence County Social Services, Inc.
COOS of Northeastern PA PO Box 189
40,1,1-aurel Street 241 West Grant Street
Pf",Jton, PA 18640 New Castle, PA 16103
51`602,2227 724,656.7258
800,922.9537 724.658.7664
Page 1 0 of 18
EMAP Consumer Credit Counseling Agencies
;Report last updated: 8/1 /2008 10:08:26 AM
Shenango Valley Urban League, Inc. LYCOMING County
601 Indiana Avenue
Farrell, PA 16121 CCCS of Northeastern PA
724,981.5310 401 Laurel Street
Pittston, PA 18640
LEBANON County 570.602.2227
800.922.9537
Schuylkill Community Action
'225 N. Centre Street CCCS of Northeastern PA
Pottsville, PA 17901 201 Basin Street
'570,622.1995 Suite 6
Williamsport, PA 17701
Tabor Community Services, Inc. 570.323.6627
308 E King Street 800.922.9537 i
Suite 1
ht ncaster, PA 17602
1 i
Lycom.Clntn Co Comm fo Comm Action
7.397,5182 2138 Lincoln Street
800,788,5062 P.O. Box 3568
Williamsport, PA 17703
LEHIGH County 570.326,0587
CCCS of Lehigh Valley MCKEAN County
3671 Crescent Court East
Whitehall, PA 18052
Northern Tler Community Action Corp.
610.821
,4811 P.O. Box 389
800,837.9615 135 West 4th Street
Emporium, PA 15834
CommunltyAction Committee 814.486.1161
of1he Lehigh Valley
1337 East Flfth Street MERCER County
Bethlehem, PA 18015
610.691.5620 CCCS of Western PA
Butler County Career Link Pullman Commerce Center
Schuylkill Community Action 112 Hollywood Drive
225 N. Centre Street Butler, PA 16001
Pottsville, PA 17901 888.511.2227
570,622.1.995 888,511,2227
LUZERNE County Shenango Valley Urban League, Inc.
501 Indlaria Avenue
CCCS of Northeastern PA Farrell, PA 16121
401 Laurel Street 724,981.5310
Pittston, PA 18640
570.602.2227 MIFFLIN County
800.922.9537
CCCS of Northeastern PA
Comm, on Econ Opportunity of Luzerne County 202 W. Hamilton Avenue
163 Amber Lane State College, PA 16801
WINes,Barre, PA 18702
576%26
0610 814.238.3658
. 800.922.9537
8QM22.0359
i
S66bylkill Community Action CCCS of Western PA
Royal Remax Plaza
225 N, Centre Street 917 A Logan Boulevard
Pottsville, PA 17901 Altoona, PA 16602
57;17, 22.1995 888.511.2227
888,51'.2227
United Neighborhood Centers of Northeastern PA
425 Alder Street
Scranton, PA 18505
570.346, 0759
Page 11 of 18
HENYAP Consumer Credit Counseling Agencies
Report last updated:.811/2008 10:08:26 AM
MONROE County American Credit Counseling Institute
845 Coates Street
Catholic Social Services Coatesville, PA 19320
Saint Catherine Manor 888.212.6741
5 Knox Road 888.212.6741
Scranton, PA 185D5
570.558.3019 American Financial Counseling Services
175 Trafford Avenue
CCCS of Northeastern PA Suite One
401 Laurel Street Wayne, PA 19087
Pittston, PA 18640 267.228.7903
570.602.2227 800.490,3039
800,922.9537
American Financial Counseling Services
.rr'CS of Northeastern PA 1917 Welsh Road
I Main Street Philadelphia, PA 19115
Suite 104 267,228.7903
Stroudsburg, PA 18360
570,420.8950 American Financial Counseling Services
800.922.9537 871 N Easton Road
Glenside, PA 19038
Community Action Committee 267,2283903
of the Lehigh Valley
1337 East Fifth Street American Financial Counseling Services
Bethlehem, PA 18015 2880 Bergey Road
6f0.691.5620 Suite 4
-Hatfield, PA 19440
MONTGOMERY County 267.226.7903
Acorn Housing Corporation American Financial Counseling Services
846 North Broad Street 405 West Germantown Pike
Philadelphia, PA 19130 Norristown, PA 19403
215.765.1221 267.228.7903
American Credit Counseling Institute CCCS of Delaware Valley
937 North Hanover Street 1608 Walnut Street
Pottstown, PA 19460 10th Floor
888,212,6741 Philadelphia, PA 19107
$86;212.6741 215.563.5665
American,Credit Counseling Institute CCCS of Delaware Valley
300 North Pottstown Pike 1777 Sentry Parkway West
Suite 210 Suite 200
Exton, PA 19341 Blue Bell, PA 19422
888,212.6741 215,563,5665
888.212.6741
Chester Community improvement Project
American Credit Counseling Instltute 412 Avenue of the States
628 Dekaib Street PO Box 541
Norristown, PA 19401 Chester, PA 19016
6,10.971.2210 610.876 8663
68x,212.6741
i Community Action Development Comm
American Credit Counseling Institute CADCOM
530 West Street Road 113 E Main St
Suite 201 Norristown. PA 19401
WIrminster, PA 18974 610.277.6363
.444.9429
NN-
2126741
Page 12 of 16
HEMAP Consumer Credit Counseling Agencies
i
Report East updated: 8/1i2008 10:08:27 AM
Germantown Settlement CCCS of Northeastern PA
5538 Wayne Avenue 201 Basin Street
Bldg C Suite 6
Philadelphia, PA 19144 Williamsport, PA 17701
215.849.3104 570, 323.6627
800.922.9537 l
Housing Partnership of Chester County
:4,1 West Lancaster Ave Schuylkill Commurilty Action
Downingtown, PA 19335 225 N, Centre Street
;810,518,1522 Pottsville, PA 17901 i
570,622.1995
Media Fellowship House
302 South Jackson Street PERRY County
Media, PA 19063
x'`]0.565.0434 CCCS of Western PA
2000 Linglestown Road
Northwest Counseling Service Harrisburg, PA 17102
5001, North Broad Street 888.51'1,2227
Philadelphia, PA 19141 888.511.2227
215,324,7500
Community Action Commission of Captial Region
Phila Council For Community Advmnt 1514 Derry Street
100 North '7th Street Harrisburg, PA 17104
S uite 600 717.232.9757
Philadelphia, PA 19103
215.667.7803 Loveship, Inc.
800.930.4663 2320 North 5th Street
Harrisburg, PA 17110
MONTOUR County 717.2322207
CCCS of Northeastern PA Maranall
401 Laurel Street 43 Philadelphia Avenue
Pittston, PA 18640 Waynesboro, PA 17268
570.602.2227 717.762.3265 '•
800.922.9537
PHILADELPHIA County
NORTHAMPTON County Acorn Housing Corporation
CCOS of Lehigh Valley 846 North Broad Street
3671 Crescent Court East Philadelphia, PA 19130
Whitehall, PA 18052 215.765.1221
610.$21.4011
800.837.9815 Advocates for Financial Independence
1806 South Broad Street
Community Action Committee Suite 1 B
of the Lehigh Valley Philadelphia, PA 19145
1337 East Fifth Street 215.389.2810
Bethlehem, PA 18015
61.691.5620 American Credit Counseling Institute
845 Coates Street
NORTHUMBERLAND County Coatesville, PA 19320
888.212.6741
CCCS of Northeastern PA 888.212.6741
401 Laurel Street
Pitlstcn, PA 18640 American Credit Counseling Institute
01l).602.2227 530 West Street Road
(7.922.9537 Suite 201 l
Warminster, PA 18974
215.444.9429
888.212.6741
Page 13 of 18
KEM P Consumer Credit Counseling Agencies
Report last updated: 811/2008 10:08:27 AM
American Financial, Counsel Ing Services Diversified Community Services
175 Trafford Avenue Dixon House
Suite One 1920 South 20th Street
Wayne, PA 19087 : Philadelphla, PA 19145
267.228.7903 215, 336,3511
800.490.3039
Esperanza
gmerican Financial Counseling Services 4261 North 5th Street
19.17 Welsh Road Philadelphia, PA 19140
P.hiladeiphia, PA 19115 215,324.0746
267.2281903
FOB CDC
APM 1201 West Olney Avenue
2147 North Sixth Street Phialdelphia, PA 19141
P;hJ1adelphia, PA 19122 215.549.8755
235,6788
Germantown Settlemert
Carroll Park Community Council, Inc. 5538 Wayne Avenue
5218 Master Street Bldg C
Philadelphia, PA 19131 Philadelphia, PA 19144
215.877.1157 215,849.3104
CCCS of Delaware Valley HACE
1608 Walnut Street 167 W, Allegheny Avenue
10th Floor grid FI
Philadelphia, PA 19107 Philadelphia, PA 19140
215.563.5665 215.426.6025
C'C'CS of Delaware Valley Hispanic Alliance for Community Advancement
One Cherry Hill 2740 North Front Street
Suite 215 Philadelphia, PA 19133
Cherry Hill, PA 08002 215.667.8932
215,563.5665
Housing Association of Delaware Valley
CCCS of Delaware Valley. 1500 Walnut Street
Catholic Social Services Building Suite 601
7340 Jackson Street Philadelphla, PA 19102
Philadelphia, PA 19136 215,545.6010
21'$.563'.5665
Housing Association of Delaware Valley
Centro Pedro Claver, Inc. 658 North Watts Street
627 West Erie Avenue Philadelphia, PA .19123
Philadelphia, PA 19140 215. 978.0224
215.227,711',
Intercultural Family Services, Inc.
Chester Community Improvement Project _ 4225 Chestnut Street
412 Avenue of the States Philadelphia, PA 19104
PO Box 541 215.386.1298
Chester, PA 19016
610;876.8653 Korean Community Development 5ervlces Center
Can
reso 6055 North 5th Street
g Philadelphia, PA 19120
216 West Somerset Street 215.276.8830
Philadelphia, PA 19133
215,763.8870 liberty Resources
1jl
Cr cif of Spanish Speaking Organization 714 Market Street
Suite 100
705=09 North Franklin Street Philadelphia, PA 19106
Philadelphia, PA 19123 215.834.2000
215.527.3100
Page 14 of ".8
HEMAP Consumer Credit Counseling Agencies
Report last updated: 8/112008 10:08:28 AM
Mt. Airy, USA PIKE County
6703 Germantown Avenue
Suite 200 CCCS of Northeastern PA
Philadelphia, PA 19119 401 Laurel Street
215.844.6021 Pittston, PA 18640
570.602.2227
New Kensington Community Development Corp 800.922.9537
2515 Frankford Avenue
Philadelphia, PA
19125 CCCS of Northeastern PA
.
'215,427.0350 411 Main Street
Suite 104
Northwest Counseling Service Stroudsburg, PA 18360
5001 North Broad Street 670.420.8980
,Pmhiladelphia, PA 19141 800.922,9537
¢115.324,7500
POTTER County
Phila Council For Community Advmnt
100 North 17th Street Northern Tier Community Action Corp,
Suite 600 P.O. Box 389
Philadelphia, PA 19103 135 West 4th Street
215.567.7803 Emporium, PA 15834
800.930.4663 814,486.1161
Philadelphia Senior Center SCHUYLKILL County
509 South Broad Street Budget Counseling Center
Philadelphia, PA 19147 247 North Fifth Street
215,546.5879 Reading, PA 19601
South Phlla0elphla H.O,M.E.S. 610.375,7866
1444 Paint Breeze Avenue CCCS of Lehigh Valley
Philadelphia, PA 19146 3671 Crescent Court East
215.334.4430 Whitehall, PA 18052.
Southwest Community Development Corporation 610.821.4011
8328 Paschall Avenue 800,837.9815
Philadelphia, PA 19142 Comm. on Econ Opportunity of Luzerne County
215.729.0800 163 Amber Lane
The Partnership CDC WiRes,Barre, PA 18702
40'20 Market Street 570.825.0510
Suite 100 800.822.0359
Philadelphia, PA 19104 Schuylkill Community Action
215.662.1612 225 N. Centre Street
United Communities Southeast Philadelphia Pottsville, PA 17901
2029 South 8th Street 570.622.1995
Philadelphia, PA 19148 I
SNYDER County
215.467.8700
CCCS of Western PA
Urban League of Philadelphia 2000 Linglestown Road
1818 Market Street Harrisburg, PA 17102
20th Floor 888.511.2227
PhHadelphia, PA 19103 888.511.2227
215.561.6070
Community Action Commission of Captial Region
West Oak Lane CDC 1514 Derry Street
6259 Limekiln Pike Harrisburg, PA 17104 t
R,4adeiphla, PA 19141 717.232.9757
215,224.0880
Page 15 of 18
HEMAP Consumer Credit Counseling Agencies
Report last updated: 811/2008 10:08'28 AM
SOMERSET County TiOGA County
CCCS of Western PA CCCS of Northeastern PA
1 North Gate Square 401 Laurel Street
42 Garden Center Drive Poston, PA 18640
Greensburg; PA 15601 570.602.2227
888.511.2227 800.922,9537
888.511.2227
The Trehab Center of Northeastern PA
Fayette Co. Community Action Agency, Inc. 144 E. East Avenue
1.37 North Beeson Avenue Wellsboro, PA 16901
Uniontown, PA 15401 570.724.5252
724.437,6050 800,982.4045
800.427.INF0
The Trehab Center of Northeastern PA
7t7 island Services Inc. 1225 Main Street
535 East Main Street Honesdale, PA 18431
Somerset, PA 15501 570.253.8941
614.445.9628 800.982,4045
800.452.0148
UNION County
SULLIVAN County CCCS of Northeastern PA
CCCS of Northeastern PA 401 Laurel Street
401 Laurel Street Pittston, PA 18640
Pittston, PA 18640 570.602.2227
570.6021227 800.922.9537
8P0.922.9537
CCCS of Northeastern PA
The Trehab Center of Northeastern PA 201 Basin Street
1226 Main Street Suite 6
Honesdale, PA 18431 Williamsport, PA 17701
570,253.8941 570,323.6627
800.982,4045 800.922.9537
The Trehab Center of Northeastern PA CCCS of Western PA
German Street Royal Remax Plaza
P.O. Box 389 917 A Logan Boulevard
Diiphore; PA 18614 Altoona, PA 16802
$70.928.9.667 888.511.2227
800.982.4045 888.61 1 .2227
SUSQUEHANNA County Lycom.Clntn Co Comm fo Comm Action
2138 Lincoln Street
The Trehab Center of Northeastern PA P.C. Box 3568
10 Public Avenue Williamsport, PA 17703
PO Box 366 570.326.0587
Montrose, PA 18801
570,278.3338 VENANGO County
806.982.4045
CCCS of Western PA
The Trehab Center of Northeastern PA Butler County Career Link Pullman Commerce Center
1225 Main Street 112 Hollywood Drive
Honesdale, PA' 18431 Butler, PA 16001
570.253.8941 888,511.2227
8Q?k, 82.4045 888.511.2227
Center for Family Services, Inc.
213 Center Streel
Meadville, PA 16335
814.337.8450
Page 16 of 18
HEMAP Consumer.Credit Counseling Agencies
Report last updated: 8/1/2008 10:08:29 AM
Greater Erie Community Action Committee Community Action Southwest
18 West 9TH Street 58 East Greene Street
Erie, PA 16501 Waynesburg, PA 15370
814.459.4581 724.852.2893 I
St. Martin Center Community Action Southwest
1701 Parade Street 160 West Beau Street I
Erie, PA 16503 Suite 304
814.452.6113 Washington, PA 15301
724.225.9550
WARREN County
Mon Valley Unemployment Committee
Booker T, Washington Center 1800 West Street
1
720 Holland Street 3rd Floor
,
eiie, PA 16503
? Homestead, PA 15120
O?4.453 5744
412,462.9962
CCCS of Western PA WAYNE County
4402 Peach Street
Erie, PA 16509 Catholic Social Services
888.511.2227 ext Saint Catherine Manor
108 5 Knox Road
888.511,2227 ext Scranton, PA 18505
108
570.558.3019
Greater Erie Community Action Committee CCCS of Northeastern PA
18 West 9TH Street 411 Main Street
Erle, PA 16501 Suite 104
814,459.4581 Stroudsburg, PA 18360
St. Martin Center 570,420.8980
1701 Parade Street 800,922.9537
Erie, PA 16503 CCCS of Northeastern PA
814.452.6113 401 Laurel Street
Warren-Forest Counties Economic Opportunity Council Pittston, PA 18540
1209 Pennsylvania Ave, West 570.602.2227
P, 0, Box 547 800,922.9537
Warren, PA 16365 The Trehab Center of Northeastern PA
874.726.2400 1225 Main Street
WASHINGTON County Honesdale, PA 18431
570.253.8941
Actitin Housing, Inc 800.982.4045
425 6th Avenue
Suite 950 United Neighborhood Centers of Northeastern PA
Pittsburgh, PA 15219 425 Alder Street
412.281.2102 Scranton, PA 18505
800.792.2801 570.346.0759
CCCS of Western PA WESTMORELAND County
1 North Gate Square Action Housing,.lnc
#2 Garden Center Drive 425 6th Avenue
Greensburg, PA 15601 Suite 950
888.5112227 Pittsburgh, PA ".5219
888.511.2227 412.281.2102
CCCS of Western PA 800792.2801 '
411wt
?ast Chestnut Street
WSWngton, PA 15301
888.511,2227
888,511,2227
Page 17 of 18
H'EMAP Consumer Credit Counseling Agencies
Report last updated; 8/1/2008 10.0&29 AM
CCCS of Western PA United Neighborhood Centers of Northeastern PA
1 North Gate Square 425 Alder Street
#2 Garden Center Drive Scranton, PA 18505
Greensburg, PA 15601 570.345.0759
888.511.2227
886.511.2227 YORK County
'G"ommunityAction Southwest Adams County Interfaith Housing Authority
58 East Greene Street 40 E High Street
Waynesburg, PA 15370 Gettysburg, PA 17325
724.852.2893 717, 3 34.1518
Indiana Co. Community Action Program Amarlcan Red Cross - Hanover Chapter
827 Water Street 529 Carlisle Street
x 187 Hanover, PA 17331
tdiana, PA 15701 7'7,637.3768
724.485.2657 Base, inc.
Mon Valley Unemployment Committee 447 South Prince Street
1800 West Street Lancaster, PA 17603
3rd Floor 717392.54.67
Homestead, PA 15120 000S of Western PA
412.462.9962 2000 Linglestown Road
Tableland Services Inc, Harrisburg, PA 17102
535 East Main Street 888,511,2227
Somerset, PA 15501 888,511,2227
814.445.9628 CCCS of Western PA
800.452.0148 Colonial Shopping Center
WYOMING County 970 S. George St
York, PA 17403
Catholic Social Services 888.511.2227
Saint Catherine Manor 888.511.2227
5 Knox Road
Scranton, PA 18505 Housing Alliance of York
570.558,3019 35 South Duke Street
York, PA 17401
CCCS of Northeastern PA 717.854.1541
4,01 Laurel Street
Fitt`ston, PA 18640 Opportunity lnc,
570.602.2227 301 East Market Street
800.922,9537 York, PA 17403
717.424, 3645
Comm. on Econ Opportunity of Luzerne County
163 Amber Lane
Wilkes.Barre, PA 18702
570.826.0510
800,822.0359
T1 e67rehab Center of Northeastern PA
115 SR 92S
T06khannock, PA 18657
57.0.836.8840
800:982.4045
The Trehab Carter of Northeastern PA
14MU Main Street
H6;ajasdale, PA 18431
570.253.8941
800.982,4045
SENDER: COMPLETE THIS SECDON COPOPLETE TiIIS SECTION 0/'4
¦ Complete items 1, 2, and 3. Also complete A. Signature
item 4 if Restricted Delivery is desired. ? Agent
¦ Print your name and address on the reverse X ? Addressee
so that we can return the card to you. B. Received by (Printed Name) C. Date of Delivery
s Attach this card to the back of the mailpiece,
or on the front if space permits.
D. Is delivery address different from item 1? ? Yes
1. Article Addressed to: If YES, enter delivery address below: ? No
DEAN P HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG PA 17050
3. Service Type
? Certified Mail ? Express Mail
? Registered ? Return Receipt for Merchandise
? Insured Mall ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number
701,1, 0470 0000 2524 31,61,
(Transfer from rom service /abed
1 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
a 911vilrill =-I all IN
m m
ru Ri
Ltd 11) Postage $
?...?..? r1J ru
Certified Fee
a
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Return Receipt Fee Postmark
CI O (Endorsement Required) Here
E3
Restricted Delivery Fee
?.+..r?
C3 (Endorsement Rr.r it-r+'
_-r _-I- Total PDStag DEAN P HOFFMAN
o ° 3602 GOLFVIEW DRIVE
---- -gent To.
MECHANICSBURG PA 17050
-
° a ?
? Street, ?IpE No.
N of PO fkax No.
Girt' State, ZiPi
rr 2006
oz F
See Reverse for Instructfo,
Exhibit "G"
r-TTRTCIMF ACCOUNT ACTIVITY STATEMENT DATE 11/17/11
REQ BY SAE PAGE 1
DEAN P HOFFMAN THE ENCLOSED INFORMATION IS PROVIDED IN RESPONSE'
3602 GOLFVIEW DR TO YOUR RECENT REQUEST. WE HOPE YOU WILL FIND
MECHANICSBURG PA 17050 THIS MATERIAL HELPFUL.
CUSTOMER SERVICE DEPARTMENT'
LOAN NUMBER:
-------------------------- CURRENT ACCOUNT INFORMATION -----------------------
DATE TOTAL PRINCIPAL LOAN CURRENT
PAYMENT PAYMENT & INTEREST INTEREST PRINCIPAL ESCROW
DUE AMOUNT PAYMENT RATE BALANCE BALANCE
03-01-11 1,967.16 1,504.97 5.50000 259,312.30 880.57-
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
------------------------------------------------------------------------------
11-09-11 00-00 304
3,987.78- 0.00 0.00 0.00 3,987.78- RESTRICTED ESCROW
11-04-11 03-11 161 ESCROW ADVANCE
104.79 0.00 0.00 104.79
11-04-11 07-12 310 MORTGAGE INSURANCE DISBURSEMENT
104.79- 0.00 0.00 104.79-
880.57- NEW PRINCIPAL/ESCROW BALANCES
10-18-11 00-00 632 STATUTORY EXPENSES
125.00 0.00 0.00 0.00
10-18-11 00-00 632 STATUTORY EXPENSES
110.00 0.00 0.00 0.00
10-18-11 00-00 632 STATUTORY EXPENSES
100.00 0.00 0.00 0.00
10-18-11 00-00 632 STATUTORY EXPENSES
15.00 0.00 0.00 0.00
10-18-11 00-00 632 STATUTORY EXPENSES
92.00 0.00 0.00 0.00
10-18-11 00-00 630 ATTORNEY ADVANCES
650.00 0.00 0.00 0.00
10-05-11 03-11 161 ESCROW ADVANCE
104.79 0.00 0.00 104.79
10-05-11 07-12 310 MORTGAGE INSURANCE DISBURSEMENT
104.79- 0.00 0.00 104.79-
775.78- NEW PRINCIPAL/ESCROW BALANCES
CUSTOMER ACCOUNT ACTIVITY STATEMENT DATE 11/17/11
REQ BY Y SAR 1 GE 2
DEAN P NUMBER: HOFFMAN
LOAN NUMBER: :
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
---------------
TRANSACTION ------------------------------------------
PRIN. PAID/ ESCROW PAID/ -------- ----------------------
----OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT
-------------------- CODE/DESCRIPTION
----------------------
._---------------
10-05-11 00-00 ----------------------
631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
09-30-11 00-00 601 MISC. CORPORATE DISBURSEMENT
40.00 0.00 0.00 0.00
09-26-11 00-00 304
6,237.28- 0.00 0.00 0.00 6,237.28- RESTRICTED ESCROW
09-02-11 03-11 161 ESCROW ADVANCE
104.79 0.00 0.00 104.79
09-02-11 07-12 310 MORTGAGE INSURANCE DISBURSEMENT
104.79- 0.00 0.00 104.79-
670.99- NEW PRINCIPAL/ESCROW BALANCES
09-01-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
08-18-11 00-00 631 PROPERTY PRESERVATION
55.00 0.00 0.00 0.00
08-16-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
08-10-11 03-11 161 ESCROW ADVANCE
566.20 0.00 0.00 566.20
08-10-11 08-11 315 SCHOOL TAX DISBURSEMENT
2,645.21- 0.00 0.00 2645.21-
566.20- NEW PRINCIPAL/ESCROW BALANCES
08-05-11 07-12 310 MORTGAGE INSURANCE DISBURSEMENT
104.79- 0.00 0.00 104.79-
2079.01 NEW PRINCIPAL/ESCROW BALANCES
08-05-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
08-04-11 00-00 304
5,112.53- 0.00 0.00 0.00 5,112.53- RESTRICTED ESCROW
07-18-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
07-11-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
07-05-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
2183.80 NEW PRINCIPAL/ESCROW BALANCES
CUSTOMER ACC LINT ACTIVITY STATEMENT DATE 11/17/11!
REQ BY SAB PAGE 3.
DEAN P HOFFMAN
LOAN NUMBER: vmww
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
--------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
06-30-11 03-11 169
15,337.59 0.00 0.00 0.00 15,337.59 RESTRICTED ESCROW
06-28-11 07-11 351 HAZARD INSURANCE DISBURSEMENT
1,110.00- 0.00 0.00 1110.00-
2290.18 NEW PRINCIPAL/ESCROW BALANCES
06-16-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
06-03-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
3400.18 NEW PRINCIPAL/ESCROW BALANCES
06-03-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
05-16-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
05-05-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
3506.56 NEW PRINCIPAL/ESCROW BALANCES
04-27--11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
04-18-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
04-12-11 04-11 313 CITY TAX DISBURSEMENT
694.33- 0.00 0.00 694.33-
3612.94 NEW PRINCIPAL/ESCROW BALANCES
04-05-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
4307.27 NEW PRINCIPAL/ESCROW BALANCES
03-21-11 03-11 173 PAYMENT
0.00 0.00 0.00 0.00 78.69 1 LATE CHARGE
78.69- UNAPPLIED FUNDS
03-16-11 03-11 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
03-04-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
4413.65 NEW PRINCIPAL/ESCROW BALANCES
03-02-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
CUSTOMER ACCOUNT ACTIVITY STATEMENT DATE 11/17/11
RFO BY SAR PAGE 4
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE'.
DATE DATE CODE DESCRIPTION OF TRANSACTION.
-------------
TRANSACTION -----------------------
PRIN. PAID/ ------------
ESCROW PAID/ -------------------------------
------------OTHER-------------
AMOUNT BALANCE INTEREST
---------- BALANCE
------------ AMOUNT CODE/DESCRIPTION
-------------------------------
-------------
A;?.-28-11 02- -------------
11 173 PAYMENT
1,967.16 315.01 1,189.96 462.19
259,312.30 4520.03 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 01- 11 173 PAYMENT
1,967.16 313.57 1,191.40 462.19
259,627.31 4057.84 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 12- 10 173 PAYMENT
1,967.16 312.14 1,192.83 462.19
259,940.88 3595.65 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 11- 10 173 PAYMENT
1,967.16 310.72 1,194.25 462.19
260,253.02 3133.46 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 10- 10 173 PAYMENT
1,967.16 309.30 1,195.67 462.19
260,563.74 2671.27 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 09- 10 173 PAYMENT
1,967.16 307.89 1,197.08 462.19
260,873.04 2209.08 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 08- 10 173 PAYMENT
1,967.16 306.49 1,198.48 462.19
261,180.93 1746.89 NEW PRINCIPAL/ESCROW BALANCES
02-28-11 08- 10 173 PAYMENT
60.00 0.00 0.00 0.00 60.00
02-28-11 00- 00 745 CORP. ADVANCE ADJUSTMENT
60.00- 0.00 0.00 0.00
02-28-11 08- 10 173 PAYMENT
5.61 0.00 0.00 0.00 5.61 K ONE TIME DRAFT FEE
02-28-11 08- 10 173 PAYMENT
157.38 0.00 0.00 0.00 157.38 1 LATE CHARGE
02-28-11 08- 10 173 PAYMENT
78.69 0.00 0.00 0.00 78.69 UNAPPLIED FUNDS
02-24-11 00- 00 632 STATUTORY EXPENSES
325.00 0.00 0.00 0.00
02-24-11 00- 00 632 STATUTORY EXPENSES
110.00 0.00 0.00 0.00
02-24-11 00- 00 632 STATUTORY EXPENSES
10.00 0.00 0.00 0.00
C'TTBTOMFR AMOTTNT AC'TTUTTY STATEMENT nATF g i /'1 7 /'1 1
REQ BY SAB PAGE 5
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE.
DATE DATE CODE DESCRIPTION OF TRANSACTION
----------------------------------._---------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
02-24-11 00-00 630 ATTORNEY ADVANCES
200.00 0.00 0.00 0.00
02-04--11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1284.70 NEW PRINCIPAL/ESCROW BALANCES
02-02-11 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
01-18-11 08-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
01-05-11 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1391.08 NEW PRINCIPAL/ESCROW BALANCES
12-16-10 08-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
12-03-10 07--11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1497.46 NEW PRINCIPAL/ESCROW BALANCES
12-02-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
11-29-10 08-10 173 PAYMENT
0.00 0.00 0.00 0.00 9.39 K ONE TIME DRAFT FEE
9.39- UNAPPLIED FUNDS
11-29-10 08-10 173 PAYMENT
0.00 0.00 0.00 0.00 15.00 2 NSF FEE
15.00- UNAPPLIED FUNDS
11-29-10 08-10 173 PAYMENT
0.00 0.00 0.00 0.00 78.69 1 LATE CHARGE
78.69- UNAPPLIED FUNDS
11-22-10 08-10 148 RETURNED CHECK REMOVAL
0.00 306.49- 1,198.48- 462.19- 15.00-K ONE TIME DRAFT FEE
261,487.42 1603.84 NEW PRINCIPAL/ESCROW BALANCES
11-22-10 09-10 148 RETURNED CHECK REMOVAL
0.00 307.89- 1,197.08- 462.19-
261,180.93 2066.03 NEW PRINCIPAL/ESCROW BALANCES
11-22-10 10-10 148 RETURNED CHECK REMOVAL
0.00 309.30- 1,195.67- 462.19-
260,873.04 2528.22 NEW PRINCIPAL/ESCROW BALANCES
CUSTOMER ACCOUNT ACTIVITY STATEMENT DATE 11/17/11
PRO RY RAR PAGE C.
DEAN P NUMBER:
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE'
DATE DATE CODE DESCRIPTION OF TRANSACTION
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
11-22-10 11-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
11-22-10 11-10 148 RETURNED CHECK REMOVAL
0.00 310.72- 1,194.25- 462.19-
260,563.74 2990.41 NEW PRINCIPAL/ESCROW BALANCES
11-19-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
11-15-10 11-10 173 PAYMENT
0.00 310.72 1,194.25 462.19
260,253.02 3452.60 NEW PRINCIPAL/ESCROW BALANCES
11-15-10 10-10 173 PAYMENT
0.00 309.30 1,195.67 462.19
260,563.74 2990.41 NEW PRINCIPAL/ESCROW BALANCES
11-15-10 09-10 173 PAYMENT
0.00 307.89 1,197.08 462.19
260,873.04 2528.22 NEW PRINCIPAL/ESCROW BALANCES
11-15-10 08-10 173 PAYMENT
7,883.64 306.49 1,198.48 462.19 15.00 K ONE TIME DRAFT FEE
261,180.93 2066.03 NEW PRINCIPAL/ESCROW BALANCES
11-05-10 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1603.84 NEW PRINCIPAL/ESCROW BALANCES
10-21-10 08-10 173 PAYMENT
0.00 0.00 0.00 0.00 20.00
20.00- UNAPPLIED FUNDS
10-21-10 00-00 745 CORP. ADVANCE ADJUSTMENT
20.00- 0.00 0.00 0.00
10-21-10 08-10 173 PAYMENT
0.00 0.00 0.00 0.00
10-18-10 08
0.00
10-18-10 00
20.00
10-15-10 08
0.00
10 152 LATE CHA
0.00
00 631 PROPERTY
0.00
10 173 PAYMENT
0.00
2GE ASSESSMENT
0.00 0.00
PRESERVATION
0.00 0.00
0.00 0.00
78.69 1 LATE CHARGE
78.69- UNAPPLIED FUNDS
78.69-1 LATE CHARGE
80.00 *
80.00- UNAPPLIED FUNDS
C TgTOM'RR ACCOUNT ACTIVITY gTATFMRNT DATE 11 11 11 1
REQ BY SAB PAGE 7
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE'
DATE DATE CODE DESCRIPTION OF TRANSACTION:
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
------------------------------------------------------------------------------
10-15-10 00-00 745 CORP. ADVANCE ADJUSTMENT
80.00- 0.00 0.00 0.00
10-14-10 08-10 173 PAYMENT
517.84 0.00 0.00 0.00 236.07 1 LATE CHARGE
281.77 UNAPPLIED FUNDS
10-14-10 07-10 173 PAYMENT
1,982.16 305.09 1,199.88 462.19 15.00 K ONE TIME DRAFT FEE
261,487.42 1710.22 NEW PRINCIPAL/ESCROW BALANCES
10-05-10 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1248.03 NEW PRINCIPAL/ESCROW BALANCES
09-16-10 07-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
09-15-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
09-03-10 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
1354.41 NEW PRINCIPAL/ESCROW BALANCES
08-18-10 08-10 311 CITY/COUNTY TAX DISBURSMENT
2,708.50- 0.00 0.00 2708.50-
1460.79 NEW PRINCIPAL/ESCROW BALANCES
08-16-10 07-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
08-05-10 07-11 310 MORTGAGE INSURANCE DISBURSEMENT
106.38- 0.00 0.00 106.38-
4169.29 NEW PRINCIPAL/ESCROW BALANCES
08-02-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
07-16-10 07-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
07-09-10 07-10 351 HAZARD INSURANCE DISBURSEMENT
1,029.00- 0.00 0.00 1029.00-
4275.67 NEW PRINCIPAL/ESCROW BALANCES
07-07-10 07-10 173 PAYMENT
157.38 0.00 0.00 0.00 157.38 1 LATE CHARGE
07-07-10 06-10 173 PAYMENT
0.00 303.70 1,201.27 462.19
261,792.51 5304.67 NEW PRINCIPAL/ESCROW BALANCES
CUSTOMER ACCOUNT ACTIVITY STATEMENT DATE 11/17/11.
REQ RY SAR PAGE
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE!
DATE DATE CODE DESCRIPTION OF TRANSACTION'
------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------'
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
07-07-10 05-10 173 PAYMENT
3,949.32 302.31 1,202.66 462.19 15.00 K ONE TIME DRAFT FEE
262,096.21 4842.48 NEW PRINCIPAL/ESCROW BALANCES
07-06-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4380.29 NEW PRINCIPAL/ESCROW BALANCES
06-30-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
06-16-10 05-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
06-04-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4488.17 NEW PRINCIPAL/ESCROW BALANCES
05-17-10 05-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
05-05-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4596.05 NEW PRINCIPAL/ESCROW BALANCES
04-19-10 05-10 173 PAYMENT
78.69 0.00 0.00 0.00 78.69 1 LATE CHARGE
04-19-10 04-10 173 PAYMENT
1,982.16 300.93 1,204.04 462.19 15.00 K ONE TIME DRAFT FEE
262,398.52 4703.93 NEW PRINCIPAL/ESCROW BALANCES
04-16-10 04-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
04-08-10 04-10 313 CITY TAX DISBURSEMENT
744.63- 0.00 0.00 744.63-
4241.74 NEW PRINCIPAL/ESCROW BALANCES
04-05-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4986.37 NEW PRINCIPAL/ESCROW BALANCES
03-31-10 04-10 173 PAYMENT
78.69 0.00 0.00 0.00 78.69 1 LATE CHARGE
03-31-10 03-10 173 PAYMENT
0.00 299.56 1,205.41 462.19
262,699.45 5094.25 NEW PRINCIPAL/ESCROW BALANCES
CUSTOMER ACCOUNT ACTIVITY STATE'ME'NT DATR 11_/17/11
REQ BY SAB PAGE 9!
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
-------------------------------------------------------------------------------
TRANSACTION PRIN. PAID/ ESCROW PAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
-------------------------------------------------------------------------------
03-31-10 02-10 173 PAYMENT
3,949.32 298.19 1,206.78 462.19 15.00 K ONE TIME DRAFT FEE
262,999.01 4632.06 NEW PRINCIPAL/ESCROW BALANCES
03-31-10 00-00 631 PROPERTY PRESERVATION
20.00 0.00 0.00 0.00
03-16-10 02-10 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
03-05-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4169.87 NEW PRINCIPAL/ESCROW BALANCES
02-05-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
4277.75 NEW PRINCIPAL/ESCROW BALANCES
01-20-10 02-10 173 PAYMENT
78.69 0.00 0.00 0.00 78.69 1 LATE CHARGE
01-20-10 01-10 173 PAYMENT
0.00 296.83 1,208.14 462.19
263,297.20 4385.63 NEW PRINCIPAL/ESCROW BALANCES
01-20-10 12-09 173 PAYMENT
3,949.32 295.48 1,209.49 462.19 15.00 K ONE TIME DRAFT FEE
263,594.03 3923.44 NEW PRINCIPAL/ESCROW BALANCES
01-05-10 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
3461.25 NEW PRINCIPAL/ESCROW BALANCES
12-16-09 12-09 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
12-02-09 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
3569.13 NEW PRINCIPAL/ESCROW BALANCES
11-30-09 12-09 173 PAYMENT
78.69 0.00 0.00 0.00 78.69 1 LATE CHARGE
11-30-09 11-09 173 PAYMENT
1,979.16 294.13 1,210.84 462.19 12.00 W
263,889.51 3677.01 NEW PRINCIPAL/ESCROW BALANCES
11-16-09 11-09 152 LATE CHARGE ASSESSMENT
0.00 0.00 0.00 0.00 78.69-1 LATE CHARGE
REQ BY SAB CUSTOMER ACCOUNT ACTIVITY STATEMENT DATE 11/17/11
PACK In
DEAN P HOFFMAN
LOAN NUMBER:
ACTIVITY FOR PERIOD 01/01/00 - 11/17/11
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
---------------
TRANSACTION ---------------
PRIN. PAID/ ----------------------------
ESCROW PAID/ -------- ----------------------
---- OTHER -------------.
AMOUNT BALANCE INTEREST BALANCE AMOUNT CODE/DESCRIPTION
11-03-09 07-10 310 MORTGAGE INSURANCE DISBURSEMENT
107.88- 0.00 0.00 107.88-
3214.82 NEW PRINCIPAL/ESCROW BALANCES
tr°'40 z
PHELAN HALLINAN & SCHMIEG, LLP
BY: JOSEPH P. SCHALK, ESQUIRE
Identification No. 91656
126 Locust Street
Harrisburg, PA 17101
(215) 563-7000
Loan Care, a Division of FNF Servicing, Inc.
3637 Sentara Way, Suite 303
Virginia Beach, VA 23452
Plaintiff
VS.
Dean P. Hoffman a/k/a Dean Paul Hoffman
3602 Golfview Drive
Mechanicsburg, PA 17050
Defendant
f 2` P74
I (U
Attorney for Plaintiff
: Court of Common Pleas
: Civil Division
: Cumberland County
: No. 11-7442-CIVIL
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion for Summary Judgment
and attached Exhibits were sent via first class mail to the person on the date listed below:
Dean P. Hoffman
A/K/A Dean Paul Hoffman
3602 Golfview Drive
Mechanicsburg, PA 17050
Dean P. Hoffinan
A/K/A Dean Paul Hoffman
3450 North Sourthport Avenue
Chicago, IL 60657
Date: I By:
Schalk, Esq
for Plaintiff
&0 ? C t
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
l6 ; I I AN10 C0U. "!T..,
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
---------------------------------------------------------------------------------------------------------
Loan Care, a Division of FNF Servicing, Inc. Court of Common Pleas
3637 Sentara Way, Suite 303
Virginia Beach, VA 23452 Civil Division
Plaintiff
VS. : Cumberland County
Dean P. Hoffman a/k/a Dean Paul Hoffman No. 11-7442-CIVIL
3602 Golfview Drive
Mechanicsburg, PA 17050
Defendant
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to
complaint, etc.):
Plaintiff's Motion for Summary Judgment
2. Identify counsel who will argue case:
(a) for plaintiff. Joseph P. Schalk, Esquire
Address: 126 Locust Street
Harrisburg, PA 17101
(b) for defendant: Dean P. Hoffman, pro se
Address: 3602 Golf View Drive
Mechanicsburg, PA 17050
3. I will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date: July 13, 2012
Date: May 18, 2012 *Joep Schalk, Esquire
for Plaintiff
Aft */1.7SPd r a
cr-A 1) q1 ugto
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LOANCARE, a Division of FNF IN THE COURT OF COMMON PLEAS OF
Servicing, Inc., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
vs. NO. 11-7442 CIVIL
DEAN P. HOFFMAN a/k/a DEAN
PAUL HOFFMAN,
Defendant
IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
BEFORE HESS, P.J., MASLAND AND PECK J J
ORDER
AND NOW, this 30. day of July, 2012, the Court being in receipt of
correspondence from the parties and following careful review thereof, it is ORDERED AND
DIRECTED that proceedings in this matter be stayed for a period of sixty (60) days from the
date of this order to afford the defendant/borrower an opportunity to qualify for participation in
court-supervised Conciliation Conference in accordance with the Notice of Residential Mortaas
Foreclosure Diversion Program and Financial Worksheet attached hereto.
BY THE COURT,
i? Joseph P. Schalk, Esquire
j? Andrew Marley, Esquire
For the Plaintiff
Dean P. Hoffman
3602 Golfview Drive
Mechanicsburg, PA 17050
Attachments Form 1 and 2
Kevin . Hess, P. J.
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FORM 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
Plaintiff(s)
Defendant(s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOS
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you mal
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with you
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliati(
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer comply
a financial worksheet in the format attLched hereto, your lawyer will prepare and file a Request for Conciliati
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date
[Signature of Counsel for Plaintiff)
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State:_ Zip:
Is the property for sale? Yes ? No E] Listing date: _Price: $ _
Realtor Name: Realtor Phone: -.-
Borrower Borrower Occupied? Yes F] No ?
Mailing Address (if different): _
City: State: Zip:
Phone Numbers: Home:_ Office:
Cell: Other:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender:
Type of Loan:
Loan Number: _
Second Mortgage Lender:
Type of Loan: _
Loan Number:
Total Mortgage Payments Amount: $
Date of Last Payment:
Primary Reason for Default:
How long?
Home:
Cell:
Office:
Other:
State: Zip:
How long?
Date You Closed Your Loan:
Included Taxes & Insurance:
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate:
$ _
$
Retirement Funds:
$ _
$
Investments: _
Checking: $ $
Savings:
$ _
$
Other:
$ _
$
Automobile #l: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other transportation (automobiles, boats, motorevcles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
Year:
Year:
2.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: _ Co-Borrower Pay Days: _
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage _
Food
2° Mortgage Utilities
Car Payment(s) Condo/Nei h. Fees
Auto Insurance _
Med. not covered
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending M:one
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes F1 No ?
If yes, please provide the following information:
Counseling Agency:_
Counselor:
Phone (Office): --------- ----- Fax: - ----------- -
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Servicing Company (Name):
Contact: Phone:
Phone:
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we am/are under no obligation to use the services provided by the above
named _
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this document along with the following information to lender and
lender's counsel:
V Proof of income
Past 2 bank statements
VI Proof of any expected income for the last 45 days
V Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
? Listing agreement (if property is currently on the market)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Loan Care,a Division of FNF Servicing,Inc. : Court of Common Pleas
3637 Sentara Way,Suite 303 n 1".
Virginia Beach,VA 23452 : Civil Division c -E
Plaintiff
VS. : Cumberland County= - ,
v3r— I
< Cn
Dean P.Hoffman a/k/a Dean Paul Hoffman - No. 11-7442-CIVIL r-
<
3602 GoNview Drive �C-'
Mechanicsburg,PA 17050
Defendant
ORDER
AND NOW,this day of 2013 upon consideration
of Plaintiffs Motion for Summary Judgment and Brief in Support thereof, and upon consideration
of the Response, if any, filed by Defendant, the Court determines that Plaintiff is entitled to
Summary Judgment as a matter of law,and it is hereby:
ORDERED and DECREED that an in rem judgment is entered in favor of Plaintiff and
against Defendant,Dean P. Hoffinan a/k/a Dean Paul Hoffman, for$269,843.86 plus interest from
October 1, 2011 at the rate of$39.0745 per them and other costs and charges collectible under the
mortgage,for foreclosure and sale of the mortgaged property.
BY THE COURT:
J.
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#280158
PRAECIPE TO ENTER JUDGMENT PURSUANT TO COURT ORDER
LOANCARE,A DIVISION OF FNF SERVICING,INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V. NO.: 11-7442-CIVIL
CUMBERLAND COUNTY
DEAN P.HOFFMAN
A/K/A DEAN PAUL HOFFMAN
Defendant(s)
PRAECIPE TO ENTER THE JUDGMENT PURSUANT TO COURT ORDER
To the Prothonotary:
Kindly Enter the Judgment per the Court Order dated 04/05/2013 in favor of the Plaintiff and against
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN, defendant(s).
As Set Forth in the Order $269,843.86
Phelan Hallinan,LLP
Adam H. Davis,Esq.,Id. No.203034
Attorney for Plaintiff .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Loan Care,a Division of FNF Servicing,Inc. : Court of Common Pleas
3637 Sentara Way,Suite 303
Virginia Beach,VA 23452 : Civil Division
Plaintiff
a
VS. : Cumberland County:j,-M= ;�b
cn
Dean P. Hoffman a/k/a Dean Paul Hoffman No. 11-7442-CIVIL
C:)
3602 Golfview Drive
Mechanicsburg,PA 17050
Defendant >
ORDER
AND NOW,this day of 2013 upon consideration
of Plaintiffs Motion for Summary Judgment and Brief in Support thereof, and upon consideration
of the Response, if any, filed by Defendant, the Court determines that Plaintiff is entitled to
Summary Judgment as a matter of law,and it is hereby:
ORDERED and DECREED that an in rem judgment is entered in favor of Plaintiff and
against Defendant,Dean P. Hoffman a/k/a Dean Paul Hoffman, for$269,843.86 plus interest from
October 1,2011 at the rate of$39.0745 per them and other costs and charges collectible under the
mortgage,for foreclosure and sale of the mortgaged property.
BY THE COURT:
J.
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#280158
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
LOANCARE,A DIVISION OF FNF SERVICING,INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 11-7442-CIVIL
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s)
CUMBERLAND COUNTY
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due $269,843.86
Interest from 04/06/2013 to Date of Sale $6,742.72
($44.36 per diem)
TOTAL $276,586.58
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
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Note: Please attach description of property. :3
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
LOANCARE,A DIVISION OF FNF SERVICING,INC.
Plaintiff
V.
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Filed:
Address where papers may be served:
/Y �/,—�1%��►i�� DEAN P.HOFFMAN
Phelan Hallinan,LLP A/K/A DEAN PAUL HOFFMAN
Adam H.Davis,Esq.,Id.No.203034 3602 GOLFVIEW DRIVE
Attorney for Plaintiff MECHANICSBURG,PA 17050-2216
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 11-7442 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LOANCARE,A DIVISION OF FNF SERVICING,INC.
Plaintiff(s)
From DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
(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;
(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: $269,843.86 L.L.: $.50
Interest FROM 4/6/2013 TO DATE OF SALE($44.36 PER DIEM)-$6,742.72
Atty's Comm: Due Prothy: $2.25
Atty Paid: $214.50 Other Costs:
Plaintiff Paid:
Date: 6/6/13
David D.Buell,Prothonot
(Seal)
Deputy
REQUESTING PARTY:
Name:ADAM H.DAVIS;ESQUIRE
Address: PHELAN HALLINAN,LLP
1617 JFK BLVD.,SUITE 1400
ONE PENN CENTER
PHILADELPHIA,PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 203034
LEGAL DESCRIPTION
ALL THOSE CERTAIN tract or parcel of land and premises,situate,lying and being in the
Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows: I
BEGINNING at a point on the North side of Golfview Drive at the dividing line between Lots Nos.
376 and 377 of the hereinafter mentioned Plan, said point being 125.04 feet West of the intersection
of Golfview Drive and Kent Drive; thence along the North side of Golfview Drive North 79 degrees
33 minutes 40 seconds West a distance of 65.05 feet to a point;thence along the same by a curve to
the left having a radius of 590.00 feet, an arc length of 33.95 feet to a point at Lot No. 378;thence
along Lot No. 378 North 07 degrees 08 minutes 31 seconds East a distance of 162.67 feet to a point
at lands now or formerly of Hampden Square Ltd.; thence along said land now or formerly of
Hampden Square Ltd. North 75 degrees 21 minutes 49-seconds East a distance of 37.57 feet to a
point;thence along the same South 37 degrees 33 minutes 40 seconds East a distance of 100.00 feet
to a point at Lot No. 376; thence along Lot No. 376 South 10 degrees 26 minutes 20 seconds West a
distance of 110.44 feet to a point,the place of BEGINNING.
CONTAINING 15,717 square feet.
BEING Lot No. 377, Final Subdivision Plan No. 3,Hampden Square,said Plan being recorded in
Plan Book 43, page 139, Cumberland County.
TITLE TO SAID PREMISES IS VESTED.IN Dean P. Hoffman, single, by Deed from Robert J.
Frost and Annette M. Frost,h/w, dated 0711412003, recorded 07116/2003 in Book 258,Page 672.
PREMISES BEING: 3602 GOLFVIEEW DRIVE,MECHANICSBURG,PA 17050-2216
PARCEL NO. 10-17-1037099
PHELAN HALLINAN,LLP F I L E O-0 r F I C Attorneys for Plaintiff
Adam H. Davis, Esq., Id. No.203034r '� PCT�IOh�O f1�rcY y
1617 JFK Boulevard, Suite 1400 2013 _ (( ; $
One Penn Center Plaza
Philadelphia, PA 19103 CUMBERLAND COUNTY
215-563-7000 PENNSYLVANIA
LOANCARE,A DIVISION OF FNF SERVICING,INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 11-7442-CIVIL
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s) CUMBERLAND COUNTY
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91. because:
(X) the mortgage is an FHA Mortgage
( ) the premises is non-owner occupied
( ) the premises is vacant
( ) Act 91 procedures have been fulfilled
( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
r
By:
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
LUANCARE,A DIVISION OF FNF SERVICING, INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 11-7442-CIVIL
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN,
Defendant(s)
CUMBERLAND COUNTY
AFFIDAVIT PURSUANT TO RULE 3129.1
LOANCARE,A DIVISION OF FNF SERVICING,INC.,Plaintiff in the above action,by the undersigned attorney,sets forth
as of the date the Ptaecipe for the Writ of Execution was filed,the following information concerning the real_property located at 3602
GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216. C,
1. Name and address of Owner(s)or reputes'..Owner(s):
Name Address(if address cannot be reasonably ascertained, =-'
please so indicate) n
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN MECHANICSBURG,PA 17050-2216
C)
2. Name and address of Defendant(s)in the judgment: T�
Name Address(if address cannot be reasonably
ascertained,please so indicate)
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN MECHANICSBURG,PA 17050-2216
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
- MERS AS A NOMINEE FOR MICHIGAN P.O.BOX 2026
FIDELITY ACCEPTANCE CORP DBA FLINT,MI 48501-2026
FRANKLIN FUNDING
MERS,INC. FRMLY 3300 SW 34TH AVE,STE 101 OCALA,
FL 34474
AS OF 12/6/10,1901 E.VOORHEES STREET,
SUITE C
DANVILLE,IL 61834
MICHIGAN FIDELITY ACCEPTANCE CORP 100 HIGH TOWER BOULEVARD
DBA FRANKLIN FUNDING SUITE 200
PITTSBURGH,PA 15205
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY#875
DBA FRANKLIN FUNDING SOUTHFIELD,MI 48076
PHS #280158
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY 4875
+` DBA FRANKLIN FUNDING SOUTHFIELD,MI 48076
` C/O CHARLENE BUSSELAAR,VICE
PRESIDENT
MICHIGAN FIDELITY ACCEPTANCE CORP 520 BROADHOLLOW ROAD
DBA FRANKLIN FUNDING SUITE 100E
C/O LEND AMERICA MELVILLE,NY 11,747 .
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be.
reasonably ascertained,please indicate)
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.
Name Address(if address cannot be
reasonably ascertained,please indicate)
a;
None.
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:
Name Address(if address cannot be
reasonably ascertained,please'indicate)
TENANT/OCCUPANT 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
CUMBERLAND COUNTY COURT I COURTHOUSE SQUARE
ADMINISTRATOR'S OFFICE ROOM 301
C/O CUSTODY CONCILIATION CARLISLE,PA 17013
DEPARTMENT
ATTN:JACQUELINE M.VERNEY,
ESQUIRE,CUSTODY CONCILIATOR
PAULA HOFFMAN 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
PAULA HOFFMAN 44 SOUTH HANOVER STREET .
C/O CARUCOLI&ASSOCIATES,P.C. CARLISLE,PA 1.7013
ATTN:JACQUELINE M.VERNEY,
ESQUIRE,CUSTODY CONCILIATOR
PAULA HOFFMAN 4010 GLENFINNAN PLACE
C/O SUSAN KAY CANDIELLO,ESQUIRE MECHANICSBURG,PA 17055
BANK OF AMERICA,N.A. 1800 TAPO CANYON ROAD
MAIL ID#CA6-414-01-43
SIMI VALLEY,CA 93063-6712
BANK OF AMERICA,N.A. 100 NORTH TRYON STREET
SUITE 170
CHARLOTTE,NC 28202
MERS AS A NOMINEE FOR BANK OF P.O.BOX 2026
AMERICA,N.A. FLINT,MI 48501-2026
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN,PRO SE MECHANICSBURG,PA 17050-2216
PHS #2801.58
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY 13 NORTH HANOVER STREET
CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE
HARRISBURG,PA 17105.
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE
DISTRICT OF PA PO BOX 11754
FEDERAL BUILDING HARRISBURG,PA 17108-1754
I verify that the statements made in this affidavit are true and correct to the best of
knowledge or information and belief. I understand-that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. my Personal
F
Date:
By'
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id. No.203034
Attorney for Plaintiff
PHELAN HALLINAN,LLP
1617 JFK Boulevard,Suite 1.400
One Penn Center Plaza,Philadelphia,PA 19103
215-563-7000
PHS #280158
LOANCARE,A DIVISION OF FNF SERVICING,INC. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
VS. NO.: 11-7441-CIVIL
C_-
r C-0
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s) CUMBERLANI1j%UTgy
00
-<
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
Z-6 ri
TO: DEAN P.HOFFMAN
A/K/A DEAN PAUL HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house(real estate)at 3602 GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216 is
scheduled to be sold at the Sheriff s Sale on 09/04/2013 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$269,843.86 obtained by
LOANCARE,A DIVISION OF FNF SERVICING,INC.(the mortgagee) against you. In the event the sale is
continued, an announcement will be made at said sale in compliance with PaR.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
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.
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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
j 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 215-563-7000.
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 proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. 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 the filing of the proposed schedule.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
(800)990-9108
t
{ s
SHORT DESCRIPTION
By virtue of a Writ of Execution No. 11-7442-CIVIL
LOANCARE,A DIVISION OF FNF SERVICING,INC.
V.
DEAN P. HOFFMAN A/KIA DEAN PAUL HOFFMAN
owner(s) of property situate in the TOWNSHIP OF HAMPDEN, CUMBERLAND County,
Pennsylvania, being
3602 GOLFVIEW DRIVE MECHANICSBURG PA 17050-2216
Parcel No. 10-17-1037-099-
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $269,843.86
Attorneys for Plaintiff
Phelan Hallinan, LLP
LEGAL DESCRIPTION
ALL THOSE CERTAIN tract or parcel of land and premises, situate,lying and being in the
Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the North side of Golfview Drive at the dividing line between Lots Nos.
376 and 377 of the hereinafter mentioned Plan,said point being 125.04 feet West of the intersection
of Golfview Drive and Kent Drive; thence along the North side of Golfview Drive North 79 degrees
33 minutes 40 seconds West a distance of 65.05 feet to a point;thence along the same by a curve to
the left having a radius of 590.00 feet, an arc length of 33.95 feet to a point at Lot No. 378;thence
along Lot No. 378 North 07 degrees 08 minutes 31 seconds East a distance of 1.62.67 feet to a point
at lands now or formerly of Hampden Square Ltd.;thence along said land now or formerly of
Hampden Square Ltd. North 75 degrees 21 minutes 49 seconds East a distance of 37.57 feet to a
point; thence along*ihesame South 37 degrees 33 minutes 40 seconds East a distance of 100.00 feet
to a point at Lot No. 376; thence along Lot No.376 South 10 degrees 26 minutes 20 seconds West a
distance of 110.44 feet to a point,the place of BEGINNING.
CONTAINING 15,717 square feet.
BEING Lot No. 377,Final Subdivision Plan No. 3,Hampden Square,said Plan being recorded in
Plan Book 43,page 139,Cumberland County.
TITLE TO SAID PREMISES IS VESTED IN Dean P. Hoffman, single, by Deed from Robert J.
Frost and Annette M. Frost, h/w, dated 07/14/2003,recorded 07/16/2003 in Book 258,Page 672.
PREMISES BEING: 3602 GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216
PARCEL NO. 10-17-1037-099
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
LOANCARE,A DIVISION OF FNF SERVICING,INC.
PUS#284158
DEFENDANT SERVICE TEAM/bdi
DEAN P.HOFFMAN A/K/A DEAN PAUL ROFFMAN COURT NO.:11-7442-CIVIL c:
SERVE DEAN P.ROFFMAN AIK/A DEAN PAUL HOFFMAN AT: TYPE OF ACTION n ,
3662 GOLFVIEW DRIVE XX Notice of Sheriff's Sale
MECHANICSBURG,PA 17656-2216 SALE DATE: September 4,2613 -O x c—, t;
ice"'
SERVED
Served nd made known to DEAN P.HOFFMAN A/IfJA DEAN PAUL HOFFMAN,Defendant on the of �- '
20 at
' o'clock . CA M.,at �� P ,in the manner described below: Arri
Defendant pJrsonally served. y.
Adult family member with whom Defendant(s)resides).
'
Relationship is
Adult in charge of Defendant's residence who refused to give name or relationship.
—Manager/Clerk of place of lodging in which Defendant(s)reside.0%.
Agent or person in charge of Defendant's office or usual place of business.
_ an officer of said Defendant's company.
_Other:
Description.- Age t Height�_ Weight�Race�K�Sex M.Other
I (�fV PC ,a competent adult,hereby verify that I personally handed a true and correct copy of the
N of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to
unworn falsification to authorities.
DATE:_q-. 110 t� NAME:
PRINTED NAME:WS"A (C-OPJ
TITLE: mamas ALLIf rL
NOT SERVED
On the da of ,20 at o'clock_.M_,I, a competent adult hereby
state that DeTendYant]ROT OUNDTbecause:
_Vacant Does Not Exist Moved _Does Not Reside(Not Vacant)
_No Answer on at LSi KA at
_Service Refused
Other.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1404
One Penn Center Plaza
Philadelphia,PA 19143
(215)563-7000
RO
13 'J 12 31
PHELAN HALLINAN,LLP ttorne for Plaintiff
Adam H. Davis,Esq.,Id. No.203034 CUt`iBER�SYLVAN 1 y
1617 JFK Boulevard,Suite 1400f
One Penn Center Plaza
Philadelphia,PA 19103
Adam.Davis @PhelanHallinan.com
215-563-7000
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
LOANCARE,A DIVISION OF FNF SERVICING, CUMBERLAND COUNTY
INC.
Plaintiff, COURT OF COMMON PLEAS
V. CIVIL DIVISION
DEAN P.HOFFMAN A/K/A DEAN PAUL No.: 11-7442-CIVIL
HOFFMAN
Defendant(s)
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named,at that address,set forth on the Affidavit and as amended if
applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A".
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
Date: ! G
IMPORTANT:NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PH#773990
}
1
LOANCARE,A DIVISION OF FNF SERVICING,INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 11-7442-CIVIL
DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s)
CUMBERLAND COUNTY
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
LOANCARE,A DIVISION OF FNF SERVICING,INC.,Plaintiff in the above action,by the undersigned attorney,sets forth
as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 3602
GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably ascertained,
please so indicate)
DEAN P.HOFFMAN A/K/A DEAN PAUL 3602 GOLFVIEW DRIVE,MECHANICSBURG,
HOFFMAN PA 17050-2216
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
DEAN P.HOFFMAN A/K/A DEAN PAUL 3602 GOLFVIEW DRIVE
HOFFMAN MECHANICSBURG,PA 17050-2216
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
MIDLAND FUNDING LLC C/O WILLIAM T. WELTMAN WEINBERG&REIS
MOLCZAN 1400 KOPPERS BUILDING
PITTSBURGH,PA 15219
MIDLAND FUNDING,LLC. 8875 AERO DRIVE
SUITE 200
SAN DIEGO,CA 92123
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
MERS AS A NOMINEE FOR MICHIGAN P.O.BOX 2026
FIDELITY ACCEPTANCE CORP DBA FLINT,MI 48501-2026
FRANKLIN FUNDING
MERS,INC. FRMLY 3300 SW 34TH AVE,STE 101 OCALA,
FL 34474
AS OF 12/6/10,1901 E.VOORHEES STREET,
SUITE C
DANVILLE,IL 61834
PH#773990
MICHIGAN FIDELITY ACCEPTANCE CORP 100 HIGH TOWER BOULEVARD
DBA FRANKLIN FUNDING SUITE 200
PITTSBURGH,PA 15205
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY#875
DBA FRANKLIN FUNDING SOUTHFIELD,MI 48076
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY#875
DBA FRANKLIN FUNDING C/O CHARLENE SOUTHFIELD,MI 48076
BUSSELAAR,VICE PRESIDENT
MICHIGAN FIDELITY ACCEPTANCE CORP 520 BROADHOLLOW ROAD
DBA FRANKLIN FUNDING C/O LEND SUITE 100E
AMERICA MELVILLE,NY 11747
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
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.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
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:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
CUMBERLAND COUNTY COURT 1 COURTHOUSE SQUARE
ADMINISTRATOR'S OFFICE C/O CUSTODY ROOM 301
CONCILIATION DEPARTMENT ATTN: CARLISLE,PA 17013
JACQUELINE M.VERNEY,ESQUIRE,
CUSTODY CONCILIATOR
PAULA HOFFMAN 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
PAULA HOFFMAN C/O CARUCOLI& 44 SOUTH HANOVER STREET
ASSOCIATES,P.C.ATTN:JACQUELINE M. CARLISLE,PA 17013
VERNEY,ESQUIRE,CUSTODY
CONCILIATOR
PAULA HOFFMAN C/O SUSAN KAY 4010 GLENFINNAN PLACE
CANDIELLO,ESQUIRE MECHANICSBURG,PA 17055
BANK OF AMERICA,N.A. 1800 TAPO CANYON ROAD
MAIL ID#CA6-914-01-43
SIMI VALLEY,CA 93063-6712
BANK OF AMERICA,N.A. 100 NORTH TRYON STREET
SUITE 170
CHARLOTTE,NC 28202
PH#773990
MERS AS A NOMINEE FOR BANK OF P.O.BOX 2026
AMERICA,N.A. FLINT,MI 48501-2026
DEAN P.HOFFMAN A/K/A DEAN PAUL 3602 GOLFVIEW DRIVE
HOFFMAN,PRO SE MECHANICSBURG,PA 17050-2216
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE•ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
e
Date: 117 By:
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
PHELAN HALLINAN,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza,Philadelphia,PA 19103
215-563-7000
PH#773990
• " cr fa
Nam:and Phelan Nallinan,LLP "
Address 1617 JFK Boulevard,Suite 1400 U N
Of Sender One Pann Center Plan
Philadclphig,PA 19103 AZ".CS-0910#12013 SAL£ A i
Line Article Number ]Name of Addressee Strte and Post Office Address Postu e �
I w+wr TENANTIOCCUPANT a+
sa.4s
3601 GOLI"VIEW DRIVE (_� a d5
MECHANICSBUR PA 17050-2216 R
2 wM s BANK OF AMERICA,N.A. $0.45
1800 TAPO CANYON ROAD
MAIL ID#CA6.914-01-43 }
SIM1 VALLEY CA 93063-6712
3 w«w« BANK OF AMERICA.N.A. $0.45
100 NORTH TRYON STREET
SIIITF,170
CRA.RLOTTE NC 28201
4 w«rt CUMBERLAND COUNTY COURT ADMINTSTRATOR-S OFFICE CIO CUS'T'ODY CONCILIATION S0.4s tDEPARTMENT ATTN.JACQUELINE M.VERNEY,ES URF,CUSTODY CONCILIATOR
1 COURTHOUSESQUARIE
ROOM 301 4 � T r yIyY
CARLISLE PA 17013
5 *""« DEAN P.HOFFMAN AWA DEAN PAUL HOFFMAN,PRO SE $0.45
3602 GOLFVIEW DRIVE
MECHANICSBUR PA 17050-2216
6 ***• MFRS AS A NOMINEE FOR RANK OF AMERICA,N.A. 40.45
P.O,BOX 2026
FLINT MI 48501-2026
7 w:.« MERS AS A NOMINEE FOR MICHIGAN FIDELITY ACCEPTANCE CORP DBA FRA44KLIIN FUNDING $0.45
P.O.BOX 2026
F'LIN'T' MT 48501-4016
8 "''; MERS,INC. $0.45
1901 E.VOORIIEES STREET,SUITE C
DAlNVILI,F IL61M4
9 MICHIGAN FIDELITY ACCEPTANCE CORP DBA fRAr,'XLIN FUNDYNC 50,AS
100 HIGH TOWER AO'ULEVARD
SUITE 200
PI'TTSB'URGH PA 15205
RE:DEAN P.HOFFMAN A/WA PAUL HOFFMAN(CUMBERLAND) PHS#250158/1021.
Page I of 2 Writ'Fram
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=e rxPtcaSfHSOdtavtnrarraatuuttganloetttsr�eu. per
pixe:ntdcta to�3{rdt of aSttOA00gzrtxtur+era.The rnainwta finder»try ryysitc m Cspttxc Maii titaetnndlsG k S9D0.
7h.naxurnmt i«deaniiy pya64 u SJSAQQ fe,naieiKre/twtl eerMwith apttoat i+euenx.Set Damertic 13«1 Ma<wa1
174fiC S9lJ tad 5421 for iitmuribrrc ofaewre -.
Form 3877 Faesimile
Nanaatxl Phelanllalliww3 LLP
Address 1617 TFK Boulevard,Suite't 400 N
Of Sender Ore Penn Center Plaza
Philadt hia,PA 19103 /1LKI8(:J-09/04/Z013 SALE Ci
Line Artic_Ic Numbcr Name of Addressee.Street.and Post Office Address Postage w
rs
i "*•* MICHIGAN FfDEL"1TY ACCEPTANCE CORP DBA FRANKLIN FUNDING $0.45 M
25800 NORTHWESTERN HIGHWAY#875 t
SOUTHFI.F..Lri MI 48076 w
2 •**" MICHIGAN FIDELITY ACCEPTANCE CORP DBA FRANKLIN FUNDING CIO CHARLENIZ WAS •=-3t wo°o
BUSSELAAR,'VICE PRESIDENT f•
25800 NORTHWESTERN HIGHWAY#875 s
SOUTHFIELD M148076
MICHIGAN FIDELITY ACCEPTANCE CORP DBA FRANKLIN FUNDING CIO LEND AMERICA $0,45
520 BROADHOLLOW ROAD,SUITE IOOE
MELVILLE NY 11747
4 k*** PAULA HOFFMAN $0.45 r
3602GOLFVIEW DRIVE f-
MFCHANICSBCIRG PA 17050.2216 Ls,
5 ""`* PAULA HOFFMAN C/O CARUCOLI&ASSOCIATES,P.C.ATTN.-JACQUELINE M.VERNEY, WAS o
ESQUIRE,CUSTODY CONCILIATOR t A;!t,+
44 SOL t"1:1 HANOVER STREET
CARLISLE,PA 17017
6 ""*" PAULA HOFFMAN C/O SUSAN KAY C.4NDIELLO,ESQUIRE $0.45
4010 GLENFINNAN PLACE
iMECHANICSBURG,PA 17055
7 "*** Domestic Relations of $0.45
Cumberland County
13 North Hanover Street
Carlisle PA 1.7013
8 """ Commonwealth of Pennsylvaula SOAS
Department of Welfare,P.O.Box 2675
Harrisburg,PA 17105
9 k,lk* Internal Revenue Service Advisory $0.45
1000 Liberty Avenue Room 704
Pittsburgh,PA 15222
10 "*** U.S.Department ofJustice,U.S.Attorney for the Middle District of PA SOA5
Federal Building
228 Walnut Street,Suite 210,P.O.Box 11754
liarrisbur ,PA 17108-1754
Lj: RE.DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN(CUMBERLAND) PHS!1.280158/.1021 58.55
Page 2 of 2 Writ Team
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19005913 and S121 fur limUtiom 31`cowmpe.
Form 3877 Facsimile
Nafne elld Plicllin Mom,LLP
Address 1,617)YK Boulevard,Suite 1400 h
Of Sender One Penn Center Plaza k7 c
Philadelphia, PA 19103 A7k1JSG-09104/2013SAI.F., ^�
Line Article Number IVsasa of Addrrswe Strec and Post Office Address Postage 0
MIDLAND FUNDING LLC CIO WILLIAM M MOLCZAN 50.46 0
WELTMAN WEINBERG&AEIS
140]COPPERS BUILDING �40 o
IffrMOURGH,PA 15219
MIDLAND FUNDING,LLC. SOA6
ON AEAO DRIVE 0
$uITE 220
BAN NEGO CA 92123
-J>90MEAN P.NOFFMAN AWA DICAN PAUL HOFFMAN(CUMBERLAND) PH it 77349011026 T0.92
- Fftelotl -45 Da
7oul Number of ToeY 1AWLcro!'tkces Poarmaet,Pat(Nance of Te all&CL3111013 efvatoe is rtgwedon all domestic W hrxmnlonal teyiicnd assn,Twrr}
Viaua 13aad by&nd« a«.:..d w Rae off_ lk"& *Gmp4:+e) fa dr—owbvrtioa ofr ptlsblr docuumus udw s Mail docwnn«neawuotia�n l9
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'lle arxiwum Frdttudtr p1Y+b"a&StS,U00.fir mpsuted mail,xrt with op'Foni ixslpsrce! # t�.
Kv1a1 S9i)ttl SYLl forhmWitun oft _ .' ty ,.�,
Form 3877 Facsimile
i
PH#773990
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
r. 1
4 4{ cvitot r ri n ±3 i rj
Jody S Smith r'44 PV # 1 t':
Chief Deputy LLi3 P C'� 27 AM 9' nv
rt
Richard W Stewart
FF CE PTE r ERIFF ,U l r r, a; i C C LIY Y
PENNSYLVANIA
LoanCare, A Division of FNF Servicing Inc
vs. Case Number
Dean P. Hoffman a/k/a Dean Paul Hoffman 2011-7442
SHERIFF'S RETURN OF SERVICE
06/25/2013 06:17 PM - Deputy Noah Cline, 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 3602 Golfview Drive, Hampden -Township,
Mechancisburg, PA 17050, Cumberland County.
06/25/2013 06:17 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Dean P. Hoffman a/k/a Dean Paul Hoffman at 3602 Golfview Drive, Hampden Township, Mechanicsburg,
PA 17050, Cumberland County.
09/03/2013 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/4/2013
11/22/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $727.11 SO ANSWERS,
November 25, 2013 RONNK ANDERSON, SHERIFF
a• ,s" 42,
O# y d--3
,1► a9c7W
. .Faun ySuite: I-.eft:Tel esofl Inc.
LOANCARE, A DIVISION OF FNF SERVICING, INC. • COURT OF COMMON PLEAS
Plaintiff •
•
CIVIL DIVISION
v. •
•
NO.: 11-7442-CIVIL
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN •
Defendant(s) •
CUMBERLAND COUNTY
AFFIDAVIT PURSUANT TO RULE 3129.1
LOANCARE,A DIVISION OF FNF SERVICING,INC.,Plaintiff in the above action,by the undersigned attorney,sets forth
as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 3602
GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216.
1. Name and address of Owner(s)or reputed.Owner(s):
Name Address(if address cannot be reasonably ascertained,
please so indicate)
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN MECHANICSBURG,PA 17050-2216
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN MECHANICSBURG,PA 17050-2216
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
MERS AS A NOMINEE FOR MICHIGAN P.O.BOX 2026
FIDELITY ACCEPTANCE CORP DBA FLINT,MI 48501-2026
FRANKLIN FUNDING
MERS,INC. FRMLY 3300 SW 34TH AVE,STE 101 OCALA,
FL 34474
AS OF 12/6/10, 1901 E.VOORHEES STREET,
SUITE C
DANVILLE,IL 61834
MICHIGAN FIDELITY ACCEPTANCE CORP 100 HIGH TOWER BOULEVARD
DBA FRANKLIN FUNDING SUITE 200
PITTSBURGH,PA 15205
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY#875
DBA FRANKLIN FUNDING SOUTHFIELD,MI 48076
PHS #280158
MICHIGAN FIDELITY ACCEPTANCE CORP 25800 NORTHWESTERN HIGHWAY#875
DBA FRANKLIN FUNDING SOUTHFIELD,MI 48076
C/O CHARLENE BUSSELAAR,VICE
PRESIDENT
MICHIGAN FIDELITY ACCEPTANCE CORP 520 BROADHOLLOW ROAD
DBA FRANKLIN FUNDING SUITE 100E
C/O LEND AMERICA MELVILLE,NY 11747
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
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.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
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:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
CUMBERLAND COUNTY COURT 1 COURTHOUSE SQUARE
ADMINISTRATOR'S OFFICE ROOM 301
C/O CUSTODY CONCILIATION CARLISLE,PA 17013
DEPARTMENT
ATTN:JACQUELINE M.VERNEY,
ESQUIRE,CUSTODY CONCILIATOR
PAULA HOFFMAN 3602 GOLFVIEW DRIVE
MECHANICSBURG,PA 17050-2216
PAULA HOFFMAN 44 SOUTH HANOVER STREET
C/O CARUCOLI&ASSOCIATES,P.C. CARLISLE,PA 17013
ATTN:JACQUELINE M.VERNEY,
ESQUIRE,CUSTODY CONCILIATOR
PAULA HOFFMAN 4010 GLENFINNAN PLACE
C/O SUSAN KAY CANDIELLO,ESQUIRE MECHANICSBURG,PA 17055
BANK OF AMERICA,N.A. 1800 TAPO CANYON ROAD
MAIL ID#CA6-914-01-43
SIMI VALLEY,CA 93063-6712
BANK OF AMERICA,N.A. 100 NORTH TRYON STREET
SUITE 170
CHARLOTTE,NC 28202
MERS AS A NOMINEE FOR BANK OF P.O.BOX 2026
AMERICA,N.A. FLINT,MI 48501-2026
DEAN P.HOFFMAN 3602 GOLFVIEW DRIVE
A/K/A DEAN PAUL HOFFMAN,PRO SE MECHANICSBURG,PA 17050-2216
PHS #280158
V
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND CO,UNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date: V f / / By: C° /1411412"11--Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
PHELAN HALLINAN,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza,Philadelphia,PA 19103
215-563-7000
PBS #280158
fo
LOANCARE, A DIVISION OF FNF SERVICING, INC. : COURT OF COMMON PLEAS
• Plaintiff : CIVIL DIVISION
vs. : NO.: 11-7442-CIVIL
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN
Defendant(s) : CUMBERLAND COUNTY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: DEAN P. HOFFMAN
A/K/A DEAN PAUL HOFFMAN
3602 GOLFVIEW DRIVE
MECHANICSBURG, PA 17050-2216
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house(real estate) at 3602 GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216 is
scheduled to be sold at the Sheriff's Sale on 09/04/2013 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$269,843.86 obtained by
LOANCARE,A DIVISION OF FNF SERVICING,INC. (the mortgagee) against you. In the event the sale is
continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
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.
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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
•
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 215-563-7000.
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 proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. 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 the filing of the proposed schedule.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
r' -
SHORT DESCRIPTION
By virtue of a Writ of Execution No. 11-7442-CIVIL
LOANCARE,A DIVISION OF FNF SERVICING, INC.
v.
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN
owner(s) of property situate in the TOWNSHIP OF HAMPDEN, CUMBERLAND County,
Pennsylvania, being
3602 GOLFVIEW DRIVE,MECHANICSBURG, PA 17050-2216
Parcel No. 10-17-1037-099-
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $269,843.86
Attorneys for Plaintiff
Phelan Hallinan, LLP
i • •
LEGAL DESCRIPTION
ALL THOSE CERTAIN tract or parcel of land and premises, situate, lying and being in the
Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the North side of Golfview Drive at the dividing line between Lots Nos.
376 and 377 of the hereinafter mentioned Plan, said point being 125.04 feet West of the intersection
of Golfview Drive and Kent Drive; thence along the North side of Golfview Drive North 79 degrees
33 minutes 40 seconds West a distance of 65.05 feet to a point; thence along the same by a curve to
the left having a radius of 590.00 feet, an arc length of 33.95 feet to a point at Lot No. 378; thence
along Lot No. 378 North 07 degrees 08 minutes 31 seconds East a distance of 162.67 feet to a point
at lands now or formerly of Hampden Square Ltd.; thence along said land now or formerly of
Hampden Square Ltd. North 75 degrees 21 minutes 49 seconds East a distance of 37.57 feet to a
point; thence along the same South 37 degrees 33 minutes 40 seconds East a distance of 100.00 feet
to a point at Lot No. 376; thence along Lot No. 376 South 10 degrees 26 minutes 20 seconds West a
distance of 110.44 feet to a point,the place of BEGINNING.
CONTAINING 15,717 square feet.
BEING Lot No. 377, Final Subdivision Plan No. 3,Hampden Square, said Plan being recorded in
Plan Book 43, page 139, Cumberland County.
TITLE TO SAID PREMISES IS VESTED IN Dean P. Hoffman, single, by Deed from Robert J.
Frost and Annette M. Frost, h/w, dated 07/14/2003, recorded 07/16/2003 in Book 258, Page 672.
PREMISES BEING: 3602 GOLFVIEW DRIVE,MECHANICSBURG,PA 17050-2216
PARCEL NO. 10-17-1037-099
WRIT OF EXECUTION and/or ATTACHMENT
" COMMONWEALTH OF PENNSYLVANIA) NO. 11-7442 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LOANCARE,A DIVISION OF FNF SERVICING,INC.
Plaintiff(s)
From DEAN P.HOFFMAN A/K/A DEAN PAUL HOFFMAN
(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;
(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: $269,843.86 L.L.: $.50
Interest FROM 4/6/2013 TO DATE OF SALE($44.36 PER DIEM)-$6,742.72
Atty's Comm: Due Prothy:$2.25
Atty Paid: $214.50 Other Costs:
Plaintiff Paid:
Date: 6/6/13
David D. Bue 1,Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: ADAM H.DAVIS,ESQUIRE
Address:PHELAN HALLINAN,LLP
1617 JFK BLVD.,SUITE 1400
ONE PENN CENTER
PHILADELPHIA,PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 203034
LIE COPY F
In TT ROM RECORD
stiF�mony whereof. I here unto set my hand
and the s a;of said Cou at Carlisle, Pa.
This day of
—, 20 5
Fr [�orot�r,
•
LXII 30 CUMBERLAND LAW JOURNAL 07/26/13
2011-7442 Civil Term
LOANCARE,A Division of FNF
Servicing,Inc.
vs.
DEAN P. HOFFMAN a/k/a
DEAN PAUL HOFFMAN
Atty.:Joseph Schalk
By virtue of a Writ of Execution
No. 11-7442-CIVIL, LOANCARE,
A DIVISION OF FNF SERVICING,
INC. v. DEAN P. HOFFMAN a/k/a
DEAN PAUL HOFFMAN owner(s) of
property situate in the TOWNSHIP
OF HAMPDEN, CUMBERLAND
County, Pennsylvania, being 3602
GOLFVIEW DRIVE, MECHANICS-
BURG,PA 17050-2216.
Parcel No. 10-17-1037-099.
Improvements thereon:RESIDEN-
TIAL DWELLING.
Judgment Amount:$269,843.86.
60
•
•
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_:
July 26,August 2 and August 9, 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.
mil,
sa Marie Coyne, Eitor
SWORN TO AND SUBSCRIBED before me this
9 da of August, 2013
�..�,I �
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY'
My Commission Expires Apr 28,2014
The Patriot-News Co. e atriotXews
Mechanicsburg, PA 17050
Inquiries - 717-255-8213 Now you know
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
Michael J. Morrow, being duly sworn according to law, deposes and says:
That he is the Controller 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 1900 Patriot Drive, 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 he 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 he 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.
2A42 Civil Tenn This ad ran on the date(s)shown below:
• LOANCARE,A Division of FNF
Servicing,Inc. 07/28/13
vs.
DEAN P.HOFFMAN A/K/A DEAN 08/04/13
PAUL HOFFMAN
AY Joseph Schalk 08/11/13
By virtue of a Writ of Execution No.
11-7442-CIVIL
LOANCARE, A DIVISION OF FNF
SERVICING,INC.
V.
Swor to _ d ubsc ibed •efore me this 3 da of August, 2013 A.D.
DEAN P.HOFFMAN A/K/A DEAN PAUL � 9
HOFFMAN
°wells) xi TOWNSHIP .property F HAMPDEN, r1�.a ■1 • - (I
CUMBERLAND _°Qtly, Pennsylvania, . ary P blic
3602- GOLFVIEW DRIVE,
MECHANICSBURG,PA 17050-2216Parce1
No.10-174037-099 -
(Acreage'ozStrcet address) Ctai� 10,WE LTH r `t=V;s SYLVANIA
_ is thereon: RESIDENTIAL -- ..--
1 lotar�al Seat
Judgment Amount:$269,843.86 I Holty t.ytnn 4Varfet,Notdri Pub9ic
MWast fnr�ton Twp,,Daunhsn County
�o"?missfan expires Dec.12,2016
MEMBER,PEN1tSYt VANIA ASSOCIATION OF NOTARIES
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
E PRO 'HONO Q J 4 '1..
2014 AUG 27 NI 9: 58
CUMB RLANQ
P NNSYLVANINNTY
Attorney For Plaintiff
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
Plaintiff
v.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 11 -7442 -CIVIL
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF
PURSUANT TO Pa.R.C.P., 2352
TO THE PROTHONOTARY:
Kindly substitute SELENE FINANCE, LP as successor Plaintiff for the originally named
Plaintiff.
Date:
The material facts on which the right of succession and substitution are based as follows:
SELENE FINANCE, LP is the current holder of the mortgage by virtue of that
certain Assignment of Mortgage, which Assignment has been executed and sent for
recording in CUMBERLAND County on or about 08/04/2014.
Kindly amend the information on the docket accordi gly.
PH # 773990
By: A_✓r:
Kenya : •at , Esq., Id. No.203664
Attorney for Plaintiff
00,\661 SOp
Cu it/vs907i
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
Plaintiff
v.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 11 -7442 -CIVIL
PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF
TO THE PROTHONOTARY:
Please mark the judgment in the above -captioned matter to the use of SELENE FINANCE, LP,
located 9990 Richmond Ave., Suite 400 South, Houston, TX 77042
Date: d205//1
PH # 773990
PHELAN HALLINAN, LLP
By:
Kenya Bates 'Esq., Id. No.203664
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
Plaintiff
v.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 11 -7442 -CIVIL
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of SELENE FINANCE, LP.
Date: d•S1/,
PH # 773990
PHELAN HALLINAN, LLP
By:
Kenya Bate (Esq., Id. No.203664
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
LOANCARE, A DIVISION OF FNF
SERVICING, INC.
Plaintiff
v.
DEAN P. HOFFMAN A/K/A DEAN PAUL
HOFFMAN
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 11 -7442 -CIVIL
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of the foregoing Plaintiffs Praecipe to Mark
Judgment to SELENE FINANCE, LP, Substitution of Party Plaintiff and Entry of Appearance were
served by regular mail on the person(s) on the date listed below:
DEAN P. HOFFMAN A/K/A DEAN PAUL HOFFMAN
3602 GOLFVIEW DRIVE
MECHANNICSBURG, PA 17050-2216
Date: exai
PHELAN HALLINAN, LLP
By:
Kenya Bates, Esq., Id. No.203664
Attorney for Plaintiff