HomeMy WebLinkAbout11-8505# 11-0409
POWERS, KIRN & JAVARDIAN, LLC
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id. No. 77149
Meghan K. Boyle, Esquire Id. No. 201661
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215-942-2090
SUNTRUST MORTGAGE, INC. F/K/A
CRESTAR MORTGAGE CORPORATION
1001 SEMMES AVENUE
RICHMOND VA, 23224
PLAINTIFF
VS.
ROBERT W. KOHUT,
JANICE M. KUNKLE
1363 KINER BOULEVARD
CARLISLE, PA 17013
DEFENDANT
COMPLAINT IN
MORTGAGE FORECLOSURE
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
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 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 Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
Attorneys for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. OR, 1. l ?4
dD
ip-t? a 0 -7 9a3
#11-0409
POWERS, KIRN & JAVARDIAN, LLC
Gregory Javardian, Esquire Id. No. 55669
Mary F. Kennedy, Esquire Id. No. 77149
Meghan K. Boyle, Esquire Id. No. 201661
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215-942-2090
SUNTRUST MORTGAGE, INC. F/K/A
CRESTAR MORTGAGE CORPORATION
1001 SEMMES AVENUE
RICHMOND VA, 23224
PLAINTIFF
VS.
Attorneys for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No.
ROBERT W. KOHUT,
JANICE M. KUNKLE,
1363 KINER BOULEVARD
CARLISLE, PA 17013 COMPLAINT IN
DEFENDANTS MORTGAGE FORECLOSURE
CIVIL ACTION MORTGAGE FORECLOSURE
1. SunTrust Mortgage, Inc. f/k/a Crestar Mortgage Corporation (hereinafter referred to as
"Plaintiff') is an Institution conducting business under the Laws of the Commonwealth of
Pennsylvania with a principal place of business at the address indicated in the caption hereof.
2. Robert W. Kohut and Janice M. Kunkle, (hereinafter referred to as Defendants) are adult
individuals residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between Robert W. Kohut and Janice M.
Kunkle and itself as Mortgagee by Assignment. The Mortgage dated April 17, 1998, was
recorded on April 23, 1998 in the Office of the Recorder of Deeds in Cumberland County in
Mortgage Book 1448, Page 222. Plaintiff is the Mortgagee by Assignment by virtue of the
following Assignment: Members 1st Federal Credit Union assigned its Note and Mortgage to
Crestar Mortgage Corporation recorded on April 23, 1998 in Assignment Book 574 at page 678
in the Office of the Recorder of Deeds in Cumberland County. A copy of the Mortgage and
Assignment of Mortgage are attached and made a part hereof as Exhibits'A' and 'B', respectively.
4. The Mortgage secures the indebtedness of a Note executed by Robert W. Kohut and
Janice M. Kunkle on April 17, 1998 in the original principal amount of $128,650.00 payable to
Plaintiff in monthly installments with an interest rate of 6.6250%. A copy of the Note is attached
and made a part hereof as Exhibit'B'.
5. The land subject to the mortgage is 1363 Kiner Boulevard, Carlisle, PA 17013. A copy of the
Legal Description is attached as part of the Mortgage as Exhibit'A' and incorporated herein.
6. Robert W. Kohut and Janice M. Kunkle are the Record Owners of the mortgaged property
located at 1363 Kiner Boulevard, Carlisle, PA 17013.
7. The Mortgage is now in default due to the failure of Defendants to make payments as they
become due and owing. As a result of the default, the following amounts are due:
Principal Balance $122,930.60
Interest to 10/17/2011 $8,977.01
Accumulated Late Charges $377.47
Escrow Advance $3,764.05
Property Inspections $250.75
Cost of Suit and Title Search $550.00
Attorney's Fees $1,300.00
TOTAL $138,149.88
plus interest from 10/18/2011 at $16.84 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchase at Sheriffs sale. If
the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor
with Notice of Intention to Foreclose ("Act 6 Notice") 41 P.S. Section 403 and Notice of
Homeowners' Emergency Mortgage Assistance ("Act 91 Notice") 35 P.S. Section 1680.403c.
10. Plaintiff sent the uniform Act 6 and Act 91 Notice as promulgated by the Pennsylvania Housing
Finance Agency to the Defendants by regular and certified mail on January 19, 2011. A copy of
the Notice is attached and made a part hereof as Exhibit'D' .
WHEREFORE, Plaintiff requests the Court enter judgment in Mortgage Foreclosure for the sale of the
mortgaged property in Plaintiffs favor and against the Defendants, in the sum of $138,149.88 together
with the interest from 10/18/2011 at $16.84 per day, costs of suit and attorney's fees.
POWERS, KIRN & JAVARDIAN, LLC
By: G?- -
PT ' Gregory Javadian, Esquire Id. No. 55669
? Mary F. Kennedy, Esquire Id. No. 77149
? Meghan K. Boyle, Esquire Id. No. 201661
Attorneys for Plaintiff
EXHIBIT `A'
Gre3 ?:5` ? ? iJ0
AFTER RECORDING MAIL TO: :rYU CCU'I I ; _ r ;
MEMBERS 1ST F O EDERAL CREDIT UNION rnp n?lj j? Pill 3 1+7
.. It A JUII I
MPf.II:11ANIf.SBURG. PA 17055
LOAN NO. ON=
(Spx Abar9 Ili L 4m For It-rdlea D.Ia)
MORTGAGE
TI I IS MORTGAGE ("Security Instrument") is given on A p r i l 17. 1 9 9 8 The mortgagor is
Robert W Kohut and Janice M Kunkle
('Borrower'). This Security Instrument is given to
MEMBERS 1ST FEDERAL CREDIT UNION.
which Is organized and existing under the laws of THE UNITED STATES OF A M E R [ C A . Lcndcr").
and whose address is P.O. BOX 40. MECHANICSBURG. PA 17055
Borrower owes Lender the principal sum of am Mu rlred Twenty Eight Thousand Six hundred Fifty Dollars and
no/100 Dollars (U.S. f 12 8 . 6 5 0 . 0 0 ). This debt is evidene ed by Borrower's note dated the same date as this
Security Instrument ('Note'), which provides for monthly payments, with the full debt, if not paid earlier, due and
payable on May 1. 2028 . This Security lnstrurnenl secures to Lender. (a) the repayment of the debt
evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all
other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the
performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose,
Borrower does hereby mortgage, grant and convey to Lender the following described property located in
D a u p h I n County, Pcnnsylvwda:
SC11E0ULE "A' AT I'ACRED
which has the address of 1363 Kiner Boulevard Carlisle
Isassl ICltyl
Pennsylvania 1 7 0 1 3 ('Properly Address");
Izir cock)
TOGETHER WITH all the improvements now or hereafter erected on tha properly, and all easements,
appurtenanca, and fixtures now or hereafter' a part of the property. All replaccmenls and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in Ibis Security Instrument as the 'Properly.'
BORROWER COVENANTS that Borrower is lawfully seined of the estate hereby conveyed and has the right to
mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record.
Borrower warrants and will defend generally (lie title to the Property against all claims and demands, subject to any
encumbrances of record. + p
PMN5YI.VANIA-.SH4ULS FAMD.Y-FNhWFUI.MC UNIFORM INS"ItUaIRNTgOON1Q4p ?? FORM 3039 91"
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24 Ndopos sat Atrhod. &mower's dime to teime provided is pargraph is ship etmed to am hoer prior to
tha aomeeReaaiteaa of bidding ae a dwdWs uk or other sak puma to this Sewity Inwemot.
+ ?ti hlaq If any of the debt se?rots 'by this SwA* Ieeinse et is bit to DortQM to
Ptopsrry. tbb homiso m Ad be a putoEtaae money tmttgfo .
X 11ft1v t am ARsrJsoft wt. Borrower tlpma thusdo' - taretnas pct "afbr a jod orris is amemd 00
the NOM ear Isla aaim of f modosm shag be the rate payable fives time to time order toe Note.
17. W¦sf>.tWflse?ey •
Ulmer =arm= ere esamsd br stmow" and teaadad tosaber with this Sovari y iavtmeng. do ovveaaots and
alpewta111s d tttttb soM rider tlWl be ieooeporated into sad shop ammit star sapplamat do costoms mod
tfpwetlM tt is Sam* fmtmmmtss if the dd;$) was a part of tons Security Eaarwom. 1Cbo* spplicabie
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BY lKWM BELOW, But.. um a atd spies to the tams and ooveaama coonioed in cob Safatrhy .
LaOltre I asd IM.My ride(s) Met oed by Bornower and recorded with it.
I
Robert W Kohut. +?
Social Society Number 17 9- 6 a- 2 10 4
a..?
anice M qkTMFTe
snr?.l 8etarltp Naatba Secvaty Number 1 8 8- 6 2.1 4 6 5
Social Sammy Number }
t plM.m sole. U6 ear For ACM0.MftaeW
OM1Mt01a K Rerldrttea
do heMby nerdy that tha torrxt address of tea wfdds.aamed
Ma is P.O. 901 40.?aECMANtC59•U1tG. PA 17055
glstw or bsod this 177% day of AMIL, 1998. )
i ANW arm"wap
Oaflrf1?111f1ALTH OV IV44 Y1t.VAMA. CaMedy fah
018 fflls, the 17TH dq of AML, 1998 • , bt fete tar, d a tmdasiyted otposr. pmsottapy appaaM
Robert W Kohut and J4nfce N KuARio
1110ft to alt (or sadslaeootihr peorm) to be'ttts pan ft whose stmea asssebsQibed lv fee within micas and
i l o t h e y enawasd the same fbr the proposes btxein comal0ed.
Bar w?fr!lnBys NABRB0F,1 bsaeuoto M my had god orlieW teal.
w f?omiiaaiun ?isea: 31st t
NOTAiVAL SEAL. , of 4
faunae 1 ftcator Notary Pubic f
140deburg. PA. paupN. o C;oupkty
MyOtlttsrraaio/1 bome mamh s. Mot
1 1.YA1sA.ND101,it FUMY-FNMMF L NC UNWORN Verrausu" 01001210310110"
LC4OmTFAAC"11l03af9WA00?L DAOa 6OF 6
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ALL THAT CERTAIN tract of lead aith the improvements
3
tbereoc situate is Monroe Township, Cumberland County;
Peansylvanks, bounded and described as followa:
29GINKING at a nail in the concertina of Township Road
No. 564 (Ricer Boulevard)-. on. the western lino of a private
?risbt-of-wky; thence along the latter, South It degrees 35 minutes
s loads Baat, a d.istanca of 390.33 feat to an iron pin on the
lis I lead aow or formarl'y of Dennis 0. Gotthard; thence along
tlle• tter, South 80 degreesl0 azinutes 00 seconds West, a
distance of 180.00 feet to an iron pin on the lino of land
not or foseerly of Elmer R. Road; thence along the latter. Borth
11 degrees 33 minutes 58 seconds Wont, a distanco0of 597.13 feet
4? 1
.., to a nail in the centerline of said township road; thence along
tbe`latter, North 82 degrees 20 oinutoa 02 seconda East, a distance
0['150.00 feet to a nail, the Placa of BEGINNING.
I
CONTAINING 2,4500 Acres and being described accordiog to
a survey for Lester E. Smith, at ux, by gugene A. Bockeosmitb, R.S. '
' dated December 5, 1978.
RAVING T9E1205 ERECTED a dwelling house and barn witb an
address of 1363 [iaer Boulevard. Carlisle, Pa.
-BRING the Mama premises which Harold S. Davis, Jr. and
40da L; Devis.'husband and wife, by Dead dated May R,. 1997
" sod recorded at Cumberland County. Pa. in Dead Book l57 pass '?
689, grastad'and conveyed unto Robert W. Kohut and Janice N. [aokle.•
i
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t E33lIBIT "A"
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f ? 'e
EXHIBIT `B'
f z 3 -S 'f
COMMONWEALTH OF PENNSYLVANIA
) 59
COUNTY OF CUMBERLAND )
ASSIGNMENT OF MORTGAGE(S)
THIS ASSIGNMENT OF MORTGAGE(S), executed this 17TH day of APRIL ,
I9yg, by and between MEMBERS 1ST FEDERAL CREDIT UNION, a corporation organized
under the laws of the U. S. Government (12USC1751), called ASSIGNOR, and
CRESTAR MORTGAGE CORPORATION called ASSIGNEE.
FUR VALUE RECEIVED, the within mortgage(s), together with the Note(s)
secured thereby for each and every obligation described therein, is (are) hereby
transferred and assigned to the ASSIGNEE, its successors and assigns, said
mortgage(s) being recorded in the public records of CUMBExT-asDIMCNROE TOWNSHIP
County, Pennsylvania, and duly identified as follows
Date of Book Page Clerk's
Original Moriaaaor Mortaaae No. NO. File tb.
ROBERT W. KOHUT AND 04/17/98 ?T T y ? 2
JANICE M. KUNKLE $128,650.00
1363 KINER BOULEVARD CARLISLE, PA 17013
This Assignment is made without representation, warranty or recourse on
ASSIGNOR herein.
IN WITNESS WHEREOF the undersigned MEMBERS 1ST FEDERAL CREDIT UNION has
caused these present to be signed in its name by its undersigned officers, and
its „SRfi1:Affixed this 17TH day of APR , 19 98 .
EMU 1S FEDERA ) EDIT UNION
Qa Bys
3 obert L. Marque
;g,{+t •:?? a Manager of Real Estate Lending
'L*, ,; led and delivered in
resence afi En
C33
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Z n
COMMONWEALTH OF PENNSYLVANIA ) c c ;
SS CID
COUNTY OF CUMBERLAND ) z
On this the 17TH day of APRIL 19 98, before me, a notary public,
the undersigned officer, personally appeared Robert L. Marquette, known to me
(or satisfactorily proved) to be the person whose name is subscribed hereto, and
acknowledged that he is Manager of Real Estate Lending for MEMBERS IST FEDERAL
CREDIT UNION and that he executed the same as Manager of Real Estate Lending for
the purpose herein contained.`
In Witness Whereof, I hereunto set my hand and official seal.
? Prepared Sys
n- nL
Notary Pu lit
Cumberland County, Names MEMBERS 1ST FEDERAL CREDIT UNION
Pennsylvania Address 5000 Louise Drive
Mechanicsburg, PA 17055
My Commission Expires EDa*:-VW@emi Public
i r?'G9? V
?•: i k,syw? ? ti ?,M
c?
BOOK 57¢. PACE
1
EXHIBIT ` "
L1081
T '
APO' KOHUf 031393 LW BIP.14S
NOM
c April .7. 1990 KECHAIII-OURG Peettijif•
Imo) [Cityl
1363 etner Boul•vsrd Cjr1,,,1P PA 11013
[Property Addrtss1 .`
I/
1. CORROWBA'S FQOM1.SR TO PAY
In return for a loan thct I hove received, 1 pmrnite to poy U.S. S .78 65, 09 (djb01RlIlllil
` a p p i l * ) . pin ituerea. t o tie order of On Leader. The Lender u y E R B E R S 1 S T F E Ot R A L
I tmltnituld am efts I air nay Irmsfer Mb None. The Lender or myone who tam gala {toy by uIllmdM"
who is a NW@d so receive pWmeat under this Note is cdlcd the 'Note Holder.'
2. I NY11MRSf'
Interest will- be chicr* on unpecid principal lentil the roll aacwm of priecild ho b= pd/, P '.
ing , d a yearty rde of 6 6250 S.
The icterert rote required by this Section 2 is the r=te 1 will pay cloth bsfim red c2ar tle151ti
to Section 6(B) of *As Note.
3. PAYMEM '
(A) 76ae and Fbve d Phyo>ecss
I will pay principal and interval by retaking payments every moath.
1 will make my monthly paymertts on the I : Iday of exh mmnh beSirrua2 oa June .1, 1!?
I will note thm pMam every month until 1 have pad all of the pritxgnl and inresi sad agp•odw
described below then 1 may, owe under this Now. My neomhly payatestts will be applied to hrlslsg •,l
principal. I f , on M a y I . 2078 1 still owe amounts under this Noe, 1 a W pay t1of `.?
roll ore thet date. which is edled the 'mnurity date."
I will m a k e my i n " A l y payments r s t' t ' + ' a *l ; - S B U R G PA 37064.
Of O 0 differs plane WaP%411!
Note Holder.
(B) Amos=2 of Mk=I ly PaycxW
My monthly payment will be in the amour of U.S S '
d. BORROWER'S RIGHT TO PWAY
I have die right to mile payments of principal it any team before they are der A payreent of pr(nokd it*
is known as a'plcpaylnpt.' When I make a le paymeni. 1 will tell the Mile llolek r in writing dm I Mdiltaa
I may make a full prepayment of Partial prepayments without paying any prepayment cberre. lb Mm
Holder win we all of my prepayastas to reduce the amount of principal this 1 eve under ibis Note. -if 1 elfin a
Partial pre?eyniea, Ow will be no dusges in the due date at in the a tiouni of my mnmbty I --at adm
the Note Holder agrees in writing to thow changes.
S. LOAN CHARGES
If a tar. wbici applies to this loan and which scu mancmum last charges. is finally iasetprited all lr7a
isactest or other loss chsrga collected or to be colleeued is connection with this lam excited to pmmW
limier, than: (i) my such loon charge shill be nAxed by the antoum necessary to reduce the dop in do
pertained limit: sad (ti) any stmu already mileded from ax which exceeded permined limits wilt- owhow
to on. The Hoot Holder may dmoae to make this refund by reducing the principal I owe under Leis WSW 1S
maidsg a direct paymaa to me. If a refund reduces principal, the redurnion will be basted as a Psimal
prepaymet.
KI&TWATR 1FIXtrD RATE 111CM-SIcale F=ffy--FNMA1FF1.MC UNIFMM PMUU10>tlMr >11t??
lWjC7e0t"/I0I"13=I223)-L Pane I of t
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API KOHUT 034393
•
LN$ 019746
lL NORMWER'S /AU UR2 TO PAY AS RW=En
(A) late Chmp for Opel dae Pgraestls
if the NMe Hi*W bait not tsodved the k0 ?bt of my MONNy payment by the cad of IS
days diet rise diet is is due. 1 will pay a lee chimp to the Note Holder. The asooaM of do clmW ?.
0 . 0 0 0 0 X of ely ovtsdete pgnteat orprincipal and imenese. I will pay this lm chor a prontA
titre on ab lies paytma.
(10) Dd4N
If 1 do ant pay the IWl moi of each monthly pays m on the date it is due. I will be in dtdseth. r
(C)NMtea a(Dah a
If 1 am in ddadt. die Nome Haider racy mod me a wrinen notice telling tie tho if 1 do ant ply tttsiimilllft
t h ro a t b y a eetra'a date. the Note Holder m y agnire Ise to pay tmtttdinely the full m o m s of p-
, mch boom bom paid acid all dw interest that I am on that amuav. This: dme trios M at Ier=a 30 dap tt>lot'
t@: daoe on wbieh the notice is delivemd or nailed to art. ,
(03 No Wtsbw By Ntes IUdder
Hymn if. st a time wbQn I am in defaall, do Note Holds don tai eegatre nit to pay it?tedilody to t"
Omwilted above, the Note holder will still harm the right to do so if I am in defoAt at a Irsr Brno.
(Rl lstysnaal of Noes Igoi Ws Coss and Egiinines
If ab•: Note Holder has ttse)tmirsd me a pq i I Namely in full as described shove, the Noe 1hn WM No ?
Cis tight la be paid becit by ate for oft of its cads tssd eaptttsca is caforcitq this Nott to rite et=-an
p n hibieed by a4Plicab11 law. Thos expmm include. for eaempie, reeoaeble naresys' feet.
7. (UMM IN NOVICES
Ualca apptieabh bw regWrw a diflere n tnphod. any notice this must he given to me tmda this Mae tee
bo given by ddivwbS h or by antifing it by firrt dw mail to me a( the Property Address above or m a da1'Alm
rya if I given die Nm Holder a aamhs of arty differon mddrea.
Any ebtice Ibm artist be given so the Note Holder under this Note will he given by mailiq it by that tilt
isma to the Now Haider at the address stated in Section 3(A) above or at a differm address if 1= tires a
notice of that dilTeses , kW=.
0. OZUGATK0 Q OP P RSOM UMM MUS NOTE
if ants than tae paten signs this Note. etch person is fully raid personally obligated w keep an of the
petty - mtda in this Noes. including the promise to pay the full mount owed. Any pttvnn W60 Is a
0rsumor. sanely or tsadent- of this Note is alto obligated to do these things. Any person am tales oral
these obligations. kah diq tit obliplons of a guarmor. way or adtrsscm of this Note. is arse obligted a
keep all of floe peomoa trade in this Note. The Note Holder may enforce its rights under Ihb Nerve spilms
cub pasoa individodly or at aisot dtof es together. This meens dal any one of us nay be nqwmd to pay all
o(dn amounts owed tndcr this Note.
9. WAIVfDtq
1 and day-other person who hm obligations under this Nate waive it rights of prr.urtinew and maim of
didicam. 'Preaeetmem• atem the right to require the Nave Ifolder to demand payment of araraswa dir.
'Notice of dishonor mew the right to mquire the Note Holder to give notice to other penow the aspotueb
dse have rat beta paid.
10. UNIpORM IIMCURLD NM
This Naga it a aailiarm inttrootnn with limited vmiutavi to mine junsdtcti xis. to addition w the proaaetial?
given to the Note Holder under this Note. a Mortgage. Deed of Trust ur Security Iksd libe '9eatshy
Imtsoataa'), dated the sane date as this Note. Prances the Nate llAkr from possrhic Iman winds might
rmh if I do not keep the promise which I make to tnts Note. Thu Socuray Instrument deecrtbes how ad
uWa what t70aditi0m 1 insy be raquired to slake inen, We payaem in (till of all aumnis 1 owe =do tbb
Noe. Sate of dicta aoadilims are dee cribad as follows:
MULTWATB 1RQZ;D RATE NOT17-NIC310 Rally--¢Mt0AMILMC IINIFIR M IN.%-Mt)191tff
ISC1C74OT'NI019S/3200(1203)-L Ape I of I Pbrrrs 32111 120
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API7 K0001 034393 lri •?iz
TfYemmillffefthe h"mily cr o BmdkW lot- In oomwer. Ifallormayperia(dallimmeft
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Of ANY I I - in h IS sold or mmf and for if a beneficial m1efto it Borrower is sold or trn?
tad Borrower is not a aOWd persatI witMut Lender's prior wrilm nromera. Lsader r0'• U ft
s 14
option. rogoite ioraedialu pay=e=r is feB of all sums secured by this Security Immanent. Hoe+sor, r
this opion shalt als be exercised by Lender if exercise is pnthibiled by federal taw m of dw due a!
this Security Immuasaa.
If !.ender czercisea This oplioe. Leader stint give Rornnwcr notice of amcleminn. 1Uo nod=
"I provide a period of rrt lea chart 3D days from ft dale the mice is defivemd or ndlod aridtilt
which Borrower =W pay aB suns cmmd by this Savr9y Instrumera. If Borrower rails a pay dbraa
turn prior (o tht apiraioa of this pedal, Lender may invoke say remWies pwmkW by this
Security los rumor without (enlter Holies or detrtatxl on Barn,wer
BY SIGNING BELOW. Bormwcr cccgKs tad aptem to the trrr+ and covencnts comained is Vasa I
throush 3 of this Note.
WrTNESS THE HAND(S) AND SEAUSI Of THE UNDERSIC-141' 1"i
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.Borrower
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EXHIBIT `D'
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
DATE: 01 / 19/2011
TO: ROBERT W KOHUT
JANICE M KUNKLE
1363 KINER BLVD.
CARLISLE PA 17013
91 7108 2133 3438 6667 2980
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE 1S SENT TO YOU IN AN
ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM
YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,
BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
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 servingyour County
are listed at the end of this Notice. If you have any questions, you mgy call the Pennsylvania Housing
Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
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HOMEOWNER'S NAME(S)-
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
ROBERT W KOHUT and JANICE M KUNKLE
1363 KINER BLVD. CARLISLE PA 17013
Members I" Federal Credit Union
SunTrust Mortgage, Inc
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 THIRTY-THREE (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 APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK; DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED
FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPO*,4RY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL
BE STOPPED.
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AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at:
1363 KINER BLVD.
CARLISLE PA 17013
1S SERIOUSLY IN DEFAULT because:
A.YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: Stan/End: 06/01/10 through 11/0110 at $ 845.56 for 6 months and $847.98 for 2 months.
Monthly Payments $ 6,769.32
Late Charges Accrued $ 135.95
NSF: $ 0,00
Inspections: $ 120.00
Other (please specify): $ 2,667.57
(Suspense): 0,00
TOTAL AMOUNT PAST DUE: $ 9,692.84
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable)
HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this
notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 9,692.8 4, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. As of the date of this letter, you owe the amount specified above. Because of interest, late charges, and other
charges that may vary from day to day, the amount due on the day that you pay may be greater. Hence, if you pay the
amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you
before depositing the check for collection. For further information, write the undersigned or call (215) 563-7000 and ask
for the Foreclosure Resolution Department. Payments must be made either by cash, cashiees check, certified check or
money order made payable and sent to:
SunTrust Morteaee, Inc.
1001 Semmes Avenue
Richmond, VA 23224
Mail Code: RVW 3042
Attn: Payment Processine
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do
not use if not applicable.)
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J' 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 Tiff-MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs.
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 mortQate. 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 six (6) months from the date of this Notice. A notice of
the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
SpnTrust Mortgage. Inc.
Address: 1001 Semmes Avenue
Richmond VA 23224
Phone Number: 800 -443-1032
Fax Number: 804- 291- 0134
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.
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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.
If this is the first notice that you have received from this office, be advised that: You may dispute the validity of the
debt or any portion thereof. If you do so in writing within thirty (30) days from receipt of this letter, this firm will
obtain and provide you with written verification thereof, otherwise the debt will be assumed to be valid. Likewise if
requested within thirty (30) days from receipt of this letter, the firm will send you the name and address of the
original creditor if different from above.
Very truly yours,
SunTrust Mortgage, Inc.
Mailed by 1"` Class Mail and by Certified Mail
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
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(Rev,9/2008)
APPENDIX B
Consumer Credit Couneiitntt Attencv
Notification of Face-ta-Face ?V tuna-
Date:
Mortgagee Name & Address
accordance with the Pennsylvania Housing Finance Agency's Homeownces Emergency Mortgage Assistance Program (PHFA-HEMAP) (Act
f 1983), this is to inform you that we have been approached for mortgage counseling assistance by:
(Nqt F-sndAddress of AgWicant)
Mortgage Loan Number
counseling agency has had a face-to-face meeting with the above-named applicant on , who indicated that they are more
i sixty (60) days delinquent on their mortgage payments and have received an Act 91 Notice of Intention to Foreclose dated
from:
Name and Addroas of Mortgagee
i accordance with the homeowner's Emergency Mortgage Assistance Program, this is to inform you that:
within 30 days from the date of this notice, we intend to forward an application to the Pennsylvania Rousing Finance Agency, Homeowner's
rrgency Mongage Assistance Program on behalf of the above-mentioned applicant(s).
By a copy of this Notice, we art: notifying any other mortgagees, identified by the applicant(s) as also having it mortgage on the property
itifted above.
No legal action to enforce the mortgage may occur if a timely application is tiled. The homeowner(s) must have a face-to-face meeting
h a Consumer Credit Counseling Apncy within 33 days !roan the date of the Act 91 Notice and an application most be received by
FA-HEMAP within 30 days of the face-to-face aseetiag is order to be protected by this forbearance period.
Name of Counseling Agency:
Address:
Telephone Number:
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Comprehensive Housing
Y
HFA
?'ENNSYiV.iNl.. 17, fIh.RNC: ACEMl:Y Counseling Agencies
Agencias de Conselo al Cllente para Vivienda
Dauphin County
'CCCS of Western PA - Harrisburg
2000 Linglestown Rd; STE 302
Harrisburg PA 17110
888.511.2227 / 888.511.2227
www.ccc$08.0
ra
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactricounty.orn
Harrisburg Fair Mousing Council
2100 N 6th St
Harrisburg PA 17110
717.238.9540
Loveship, Inc.
2320 N 5th St
Harrisburg PA 17110
717.232.2207
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.rurali .ora/palhslone oa.htm
NOTE: Many of the agencies offer workshops at various location sites: call to find a location near you. i
Report last updated: 1019/2009 3:27:33 PM Page 1 of 1
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HEMAP Consumer Credit Counseling Agencies
DAUPHIN County
Report last updated: 8/30/2010 2:55:34 PM
GCCS of Western PA
2000 I_Ingtestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Capital Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
•
A
VERIFICATION
The undersigned hereby states that the statements made in the foregoing pleadings are
true and correct to the best of his/her knowledge, information and belief. The undersigned
understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
Name: /
Title: OTC&-R )
SunTrust Mortgage, Inc. f/k/a
Crestar Mortgage Corporation
POWERS, KIRN & JAVARDIAN, LCC
GREGORY JAVARDIAN, ESQUIRE Id. No. 55669_>1
MARY F. KENNEDY, ESQUIRE Id. No. 77149 , kD rf,0N0TA ; `MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 21) 12 FEB 22 Arf I i : 19
SEAN P. MAYS, ESQUIRE Id No. 307518
1? 10 INDUSTRIAL BOULEVARD CUMBERLAND COUNTY
1 FLOOR. SUITE 101 PENNSYLVANIA
SOUTHAMPTON, PA 18966
(215) 9=12-2090
SUNTRUST MORTGAGE, INC
1001 SEMMES AVENUE
RICHMOND, VA 23224
vs.
Robert Kohut
Janice Kunkle
1363 Kiner Boulevard
Carlisle. PA 17013
COURT OF COMMON PLEAS
Cumberland COUNTY
No.: 11-8505
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against Robert Kohut and Janice Kunkle,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs darnages as
follows:
As Set forth in Complaint $138,149.88
Interest 10/18/2011 to 02/16/2012 2.037.64
TOTAL $140.187.52
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown
above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
Gre ry J ar i n, Esquire Id. No. 55669
?Mary F. Kenn y, Esquire Id. No. 77149
CMeghan K. Boyle, Esquire Id. No. 201661
C'Sean P. Mays, Esquire Id. No. 307518
Attorneys for Plaintiff
Damages are hereby assessed as indicated
DATE.:
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PRO FROTHY
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POWERS, k IRN & JAVARDIAN, LLC
B,Y: Gregory Javardian, Esquire
ID No. 55669
1310 Industrial Boulevard, Suite 101
Southampton, PA 18966
Telephone: 215-942-2090
Attorneys for Plaintiff
SunTrust Mortgage, Inc. f/k/a Crestar Mortgage In the Court of Common Pleas
Corporation CUMBERLAND COUNTY
Plaintiff
vs. No. 11-8505 CIVIL
Robert W. Kohut
Janice M. Kunkle
Defendants
Robert W. Kohut Janice M. Kunkle
1363 Kiner Boulevard 400 Independence Court
Carlisle, PA 17013 Mechanicsburg, PA 17050
DATE OF NOTICE: December 20, 2011
NOTICE, RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed to take action required by you in this case. Unless you act
within ten (10) days from the date of this notice, a judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a
lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office
to find out where you can get legal help.
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Phone: 717-243-9400
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone: 717-249-3166
Gt
Gr?goor favardian squire
r
Usted se encuentra en estado de rebeldia por no haber tomado la a ion requiida de su parte en este caso.
Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notifieaeion, el tribunal
podra, sin necesidad de compararecer usted en corte o escuchar prueba alguna, dictar sentencia en su
contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un
abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para. tal servicio, vaya
en persona o ]lame por telpfono a la oficina, cuya direccion se encuentra escrita abajo para averiguar
donde se puede conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE"
POWERS, KIRN & JAVARDIAN, LCC
GREGORY JAVARDIAN, ESQUIRE Id. No. 55669
MARY F. KENNEDY, ESQUIRE Id. No. 77149
MEGHAN K. BOYLE, ESQUIRE Id. No. 201661
SEAN P. MAYS, ESQUIRE Id No. 307518
1310 INDUSTRIAL BOULEVARD
1 s ` FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-2090
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St-NTRtJST MORTGAGE, INC. COURT OF COMMON PLEAS
vs. Cumberland COUNTY
Robert Kohut No.: 11-8505
Janice Kunkle
VERIFICATION OF NON-MILITARY SERVICE
The undersigned hereby verifies that he/she is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he/she has knowledge of
the following facts, to wit:
(a) Defendant(s), Robert Kohut and Janice Kunkle, is/are not in the
Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended.
(b) Defendant, Robert Kohut, is over 18 years of age, and resides at 1363
Kiner Boulevard, Carlisle, PA 17013.
(c) Defendant, Janice Kunkle, is over 18 years of age, and resides at 400
Independence Court, Mechanicsburg, PA 17050.
(d) Plaintiff, SUNTRUST MORTGAGE, INC., is an institution
conducing business under the Laws of the Commonwealth of Pennsylvania with an
address of 1001 SEMMES AVENUE, RICHMOND, VA 23224.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities. r?
dGre?ory Ja, ar i ' , Esquire Id. No. 55669
?Mary F. Ken y, Esquire Id. No, 77149
?Meghan K. Boyle, Esquire Id. No. 201661
?Sean P. Mays, Esquire Id. No. 307-418
Attorneys for Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff e ry j�
4114 �-Z I f u P{� P -
Jody S Smith I _7
Chief Deputy : vg
Richard W Stewart °' CUMBERLAq GUL+� >
Solicitor _ wt PEIMS ' D C to 'l
Suntrust Mortgage, Inc. Case Number
vs. 2011-8505
Robert W. Kohut(et al.)
SHERIFF'S RETURN OF SERVICE
01/02/2013 05:10 PM - Deputy Ryan Burgett, 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 1363 Kiner Boulevard, Carlisle, PA 17013, Cumberland
County.
01/02/2013 05:10 PM -Deputy Ryan Burgett, 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:
Robert W. Kohut at 1363 Kiner Boulevard, Monroe Township, Carlisle, PA 17015, Cumberland County.
01/07/2013 03:48 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:
Janice M. Kunkle at 400 Independence Court, Silver Spring Township, Mechanicsburg, PA 17050,
Cumberland County.
03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold
the same for the sum of$ 1.00 to Attorney Gregory Javardian, on behalf of Federal Home Loan Mortgage
Corporation being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,021.38 SO ANSWERS,
April 30, 2013 RbNW R ANDERSON, SHERIFF
SUNTRUST MORTGAGE, INC. F/K/A COURT OF COMMON PLEAS
CRESTAR MORTGAGE CORPORATION
CUMBERLAND COUNTY
VS.
No.: 11-8505 Civil
Robert W. Kohut
Janice M. Kunkle
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 1363 Kiner Boulevard
Carlisle,PA 17013:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address(if address cannot be
reasonably ascertained,please indicate)
Robert W. Kohut 1363 Kiner Boulevard
Carlisle, PA 17013
Janice M. Kunkle 400 Independence Court
Mechanicsburg,PA 17050
2. Name and address of Defendant(s) in the judgment:
Robert W. Kohut 1363 Kiner Boulevard
Carlisle, PA 17013
Janice M. Kunkle 400 Independence Court
Mechanicsburg, PA 17050
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name Last Known Address(if address cannot be
reasonably ascertained,please indicate)
Franklin Credit Management Corporation 101 Hudson Street
Jersey City,NJ 07302
Franklin Credit Management Corporation c/o Mark J. Udren, Esq.
Woodcrest Corporate Center
1 I 1 Woodcrest Road
Cherry Hill,NJ 08003
4. Name and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained,please indicate)
Plaintiff.
Community Bank of Northern VA 8150 Leesburg Pike
Vienna,VA 22182
The Huntington National Bank, as Trustee for 7 Easton Oval
Franklin Mortgage Asset Trust 2009-A Columbus, OH 43219
Suntrust Mortgage, Inc. 1001 Semmes Avenue
P.O. Box 27767
Richmond,VA 23224-7767
Suntrust Mortgage, Inc. c/o Michele M. Bradford, Esq.
1617 JFK Boulevard, Ste. 1400
Philadelphia, PA 19103
5. Name and address of every other person who has any record lien on the property:
Name Last Known 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 Last Known Address (if address cannot be
reasonably ascertained,please indicate)
Cumberland County Domestic Relations 13 North Hanover Street
P.O. Box 320
Carlisle,PA 17013
Cumberland County Tax Claim Bureau 1 Courthouse Square
Old Courthouse, Room 106
Carlisle,PA 17013
PA Department of Public Welfare Health and Welfare Building--Room 432
Bureau of Child Support Enforcement P.O. Box 2675
Harrisburg,PA 17105-2675
Asset Acceptance LLC 28405 Van Dyke Avenue
Warren, MI 48093
Asset Acceptance LLC c/o Joel M. Flink, Esq.
1001 East Hector Street, Ste. 220
Conshohocken, PA 19428
Janice Kohut a/k/a Janice M. Kunkle c/o Sandra L. Meilton, Esq.
635 North 12th Street, Ste. 101
Lemoyne, PA 17043
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 Last Known Address(if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 1363 Kiner Boulevard
Carlisle,PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge,information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities.
9GregA Javardian, s ' e Id.No. 55669
❑Mary F.Kennedy, uire Id.No. 77149
❑Meghan K.Boyle,Esquire Id.No. 201661
❑Sean P.Mays, Esquire Id.No. 307518
❑Richard J.Nalbandian,Esquire Id.No. 312653
Attorneys for Plaintiff
September 26,2012
POWERS,KIRN&JAVARDIAN,LLC
GREGORY JAVARDIAN,ESQUIRE Id.No.55669
MARY F.KENNEDY,ESQUIRE Id.No.77149
MEGHAN K.BOYLE,ESQUIRE Id.No.201661
SEAN P.MAYS,ESQUIRE Id No.307518
RICHARD J.NALBANDIAN,III,ESQUIRE Id No.312653
1310 INDUSTRIAL BOULEVARD
2nd Floor,SUITE 201
SOUTHAMPTON,PA 18966
(215)942-2090
SUNTRUST MORTGAGE, INC. F1KIA COURT OF COMMON PLEAS
CRESTAR MORTGAGE CORPORATION
CUMBERLAND COUNTY
vs.
No.: 11-8505 Civil
Robert W. Kohut
Janice M. Kunkle
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Robert W. Kohut
Janice M. Kunkle
1363 Kiner Boulevard
Carlisle,PA 17013
Your house(real estate) at 1363 Kiner Boulevard Carlisle PA 17013, is scheduled to be
sold at Sheriffs Sale on MARCH 6,2013 at 10:00 A.M., in the Cumberland County Courthouse,
One Courthouse Square, Carlisle,PA 17013, to enforce the court judgment of$140,187.52, obtained
by SUNTRUST MORTGAGE,INC.FIK1A CRESTAR MORTGAGE CORPORATION,
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call; 2215)
942-2090.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one,the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling(215)942-2090.
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 Powers, Kim&Javardian, LLC at(215) 942-2090.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff. 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.
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
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717)249-3166
(800) 990-9108
ALL THAT CERTAIN tract of land with the improvements thereon situate in Monroe Township,
Cumberland County, Pennsylvania,bounded and described as follows:
BEGINNING at a nail in the centerline of Township Road No. 564 (Kiner Boulevard), on the
Western line of a private right-of-way; thence along the latter, South 11° 35' 55"East, a distance of
590.33 feet to an iron pin on the line of land now or formerly of Dennis B. Gotthard; thence along
the latter, South 80° 10' 00"West, a distance of 180.00 feet to an iron pin on the line of land now or
formerly of Elmer R. Reed; thence along the latter,North 11° 33' 58"West, a distance of 597.13 feet
to a nail in the centerline of said Township Road; thence along the latter,North 82°20' 02"East, a
distance of 180.00 feet to a nail, the place of BEGINNING.
CONTAINING 2.4500 acres and being described according to a survey for Lester E. Smith, et ux,
by Eugene A. Hockensmith,R.S.,dated December 8, 1978.
BEING THE SAME PREMISES which Harold S. Davis, Jr. and Linda L. Davis,husband and wife,
by Deed dated May 8, 1997 and recorded May 15, 1997 in the Office of the Recorder of Deeds in
and for Cumberland County in Deed Book Volume 157,Page 669, granted and conveyed unto
Robert W. Kohut and Janice M. Kunkle,joint tenants with the right of survivorship.
BEING KNOWN AS: 1363 Kiner Boulevard , Carlisle, PA 17013
PARCEL#22-25-0047-014
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 11-8505 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION-LAW
TO THE S14ERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due SUNTRUST MORTGAGE,INC.F/K/A CRESTAR
MORTGAGE CORPORATION Plaintiff(s)
From ROBERT W.KOHUT,JANICE M.KUNKLE
(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 garnishees)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 Ievied 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: $140,187.52 L.L.:.50
Interest FROM 2/17/12 TO DATE OF SALE @$23.04 PER DIEM
Atty's Comm: % Due Prothy:$2.25
Arty Paid: $239.50 Other Costs:
Plaintiff Paid:
Date: 10/1/12
David D. Buell,Prothonotary
(Seal) P tv Azck
Deputy
REQUESTING PARTY:
Name: GREGORY JAVARDIAN,ESQUIRE
Address: POWERS, KIRN&JAVARDIAN,LLC
1310 INDUSTRIAL BOULEVARD
2ND FLOOR,SUITE 201
TRUE COPY FROM RECORD
SOUTHAMPTON,PA 18966 In Testimony v4hereof,l here unto set my hand
Attorney for: PLAINTIFF and the seal of said Court at Carlisle,Pa.
This—/�—day of h&.Y20-.I A
Telephone: 215-942-2090 Prothonotary
Supreme Supreme Court ID No. 55669 ;t\ S �
On October 25, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA,
Known and numbered as, 1363 Kiner Boulevard,
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated
herein.
Date: October 25, 2012
By:
YL-) y
Real Estate Coordinator
80 :b V Z- 1001101
r
CUMBERLAND LAW JOURNAL
Writ No. 2011-8505 Civil
Suntrust Mortgage,Inc.
vs.
Robert W. Kohut,
Janice M. Kunkle
Atty.: Gregory Javardian
ALL THAT CERTAIN tract of with
the improvements thereon situate
in Monroe Township, Cumberland
County,Pennsylvania,bounded and
described as follows:
BEGINNING at a nail in the cen-
terline of Township Road No. 564
(Kiner Boulevard), on the Western
line of a private right-of-way;thence
along the latter,South 1135 55 East,
a distance of 590.33 feet to an iron
pin on the line of land now or formerly
of Dennis B. Gotthard;thence along
the latter, South 80010'00"West,a
distance of 180.00 feet to an iron pin
on the line of land now or formerly
of Elmer R. Reed; thence along the
latter, North 11 33 58 West, a dis-
tance of 597.13 feet to a nail in the
centerline of said Township Road;
thence along the latter,North 82 20
02 East,a distance of 180.00 feet to
a nail,the place of BEGINNING.
CONTAINING 2.4500 acres and
being described according to a survey
for Lester E.Smith,et ux,by Eugene
A.Hockensmith,R.S.,dated Decem-
ber 8, 1978.
BEING THE SAME PREMISES
which Harold S.Davis,Jr.and Linda
L.Davis,husband and wife,by Deed
dated May 8, 1997 and recorded May
15,1997 in the Office of the Recorder
of Deeds in and for Cumberland
County in Deed Book Volume 157,
Page 669, granted and conveyed
unto Robert W.Kohut and Janice M.
Kunkle,joint tenants with the right
of survivorship.
BEING KNOWN AS: 1363 Kiner
Boulevard,Carlisle,PA 17013.
PARCEL#22-25-0047-014.
74
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:
January 25, February 1, and February 8,2013
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.
Li a Marie Coyne, itor
SWORN TO AND SUBSCRIBED before me this
L=Notary 2013
NOTARIAL SEAL
D EBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
I
i
g11R�
cw
Robe�tWr Kohut
JOT&O tA,Ku4w
Attr. Gir�9°111
ALL nw CERAIN 4wM& it
the
t10l,
MA
E17)�G at a nark in the centedin eof
1bwuship Road NO.564 r evmd)'
on the Western lime of a pm'ate'0
thencx ai8 the lgtter,South 11 35
war,SS East,a dtstance of 590.33 feet to an iron
pin on the line of land now or form ly
DennisB.a tthard thencealougtof
South 80010 OQ"West,a 180.00
feet to an von pu►on °�thence navy
or.for —I of ElnneIR.
Real thence along
the latter,North 1133 581kst,a distance
of 597.13 feet to a nark m the of
saidTownshil R — of 180.00
82 20 02 East,a d
North e a nail,the place of BEGINNd Being
• CONTAINING'245 for Lester
g pith;
mitb etua bS"Engepe A li+
RS.,dated December 8,1978.
BEIPIG THE SAM
Harold S.Davis,Jr-and Lima I» °
husband and Wife,by Deed dated May
May 15,1 9 and for
8 �oand he r of vie
Cumberland Covey in T�Boo'- unto
157,Page 569,granted and curve
Robert W Kohut and 7an�e M.Kunkle,
joint ton the t of 136 Kmer
BEING KNOWN
Boulevard,Carlisle,PA 17013
PARCEL-#2215.0047.014
The Patriot-News Co.
2020 Technology Pkwy the atr1*otwXews
Suite 300
Mechanics4urg, PA 17050 NOW you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATIO COPY This ad ran on the date(s)shown below:
01/22/13
01/29/13
02/05/13
Sworn to a d u scribed before me this 14 day of February, 2013 A.D.
N Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal Public
Holly Lynn Warfel,Notary
Washington Twp.,Dauphin County
My Commission Expires Dec.12,2016
c � MEMBER,PENNSYLVANIA ASSOaATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
1,Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Home Loan Mortgage Corporation is the grantee the same having
been sold to said grantee on the 6th day of March A.D.,2013,under and by virtue of a writ Execution
issued on the 1 st day of October, A.D., 2012,out of the Court of Common Pleas of said County as of
Civil Term, 2011 Number 8505, at the suit of Suntrust Mortgage Inc. F/K/A Crestar Mortgage
Corporation against Robert W. Kohut and Janice M. Kunkle is duly recorded as Instrument Number
201314817.
IN TESTIMONY WHEREOF,I have�ereunto set my hand
and seal of said office this day of
A.D.
Recorder of Deeds
?'ecorder of Deeds, Caurdy,Cart�sle,PA
qty Commission W the Fist Monday of Jan.2014