HomeMy WebLinkAbout12-2144FEDERMAN & ASSOCIATES, LLC
By: Thomas M. Federman, Esq., ID No. 64068
By: Danielle Boyle-Ebersole, Esq., ID No. 81747
305 York Road, Suite 300
Jenkintown, PA 19046
(215) 572-5095
WELLS FARGO BANK, N.A., AS CERTIFICATE TRUSTEE
(NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS
CERTIFICATE TRUSTEE), IN TRUST FOR REGISTERED
HOLDERS OF VNT TRUST SERIES 2010-2
101 HUDSON STREET
JERSEY CITY, NJ 07302
V.
Plaintiff
ATTORNEY FOR PLAINTIF?r w
COURT OF COMMON PLEA* s° 1
CIVIL DIVISION
NO. /01 - 021 y'/ V, r)
STACY BLOSSER A/K/A STACY J. BLOSSER CUMBERLAND COUNTY
730 HILLSIDE DRIVE
CARLISLE, PA 17013
Defendant(s)
CIVIL ACTION - LAW (3.0 REAL PROPERTY)
COMPLAINT IN MORTGAGE FORECLOSURE
3010 FORECLOSURE 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, OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
(SEE ATTACHED ESPANOL AVISO)
0
4103.?5 PA ATT1/
C* 13(oo
P,'- a73y1a
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS
DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,
BUT ONLY ENFORCEMENT OF A LIEN AGAINST REAL ESTATE.
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM
THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES
ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY
DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION
THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL
FOR PLAINTIFF WILL OBTAIN AND PROVIDE
DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED
TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF
DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE
END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST
CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR
ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS
ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL
THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND ADDRESS OF
THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY
PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS
COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO
COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED
INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS
AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A
DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT.
IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE CONTRA LAS
DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, ES ABSOLUTAMENTE NECESARIO QUE
USTED RESPONDA DENTRO DE VEINTE (20) DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA
Y AVISO. HACE FALTA ASENTAR UNA COMPARENCIA ESCRITA O EN PERSONA O CON UN
ABOGADO Y ENTREGAR A LA CORTE EN FORME ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS
DEMANDAS ON CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, SUYA SIN
PREVIO AVISO O NOTIFICACION. ADEMAS, LA CORTA PUEDE DECIDIR A FAVOR DEL
DEMANDANTE Y REQUIERE QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES Y OTROS DERECHOS
INTORTAN77ES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE
EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAY A EN PERSONA O LLAME POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Resources Available for Haneowners in Foreclosure
ACT NOW!
Even though your lender (our client) has filed an Action in Mortgage Foreclosure,
You may still be able to SAVE YOUR HOME FROM FORECLOSURE.
1) Call an attorney. For referrals to a qualified attorney call the following number(s):
(717) 249-3166 or (800) 990-9108.
2) Call the Consumer Credit Counseling Agency at (800) 989-2227 for free counseling.
3) Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their
Homes.
4) Call Plaintiff (your lender) at (800) 255-5897 and ask to speak to someone about Loss
Mitigation or Home Retention options.
5) Call or contact our office to request the amount to bring the account current or payoff the
mortgage, or request a Loan Workout / Home Retention Package. Call and ask for our
Homeowner Retention Department at (215) 572-5095 or via email at
homeretention(a)federmanle ag 1.
*** Para informacion en ePanol, si puede comunicarv con Tomas al 015) 572-5095 ***
This Action ofMortgage Foreclosure will continue unless you take action tostop it.
Plaintiff is:
WELLS FARGO BANK, N.A., AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY
BUT SOLELY AS CERTIFICATE TRUSTEE), IN TRUST FOR REGISTERED HOLDERS OF VNT
TRUST SERIES 2010-2
101 HUDSON STREET
JERSEY CITY, NJ 07302
2. The name(s) and last known address(es) of the Defendant(s) are:
STACY BLOSSER A/K/A STACY J. BLOSSER
730 HILLSIDE DRIVE
CARLISLE, PA 17013
who is/are the "Mortgagor(s)" and/or "Real Owner(s)" of the Property hereinafter described.
On or about 1/9/07 Mortgagor(s) made, executed and delivered a Mortgage upon the Property hereinafter
described to Mortgage Electronic Registration Systems, Inc. as Nominee for Madison Equity Corporation,
which Mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Book 1984,
Page 4108 (the "Mortgage"). The Mortgage was last assigned to Plaintiff by Assignment of Mortgage,
which was recorded on 3/7/12 as Document #201206805. The Mortgage and Assignment(s), if any, are
matters of public record and incorporated herein by reference, in accordance with Pa.R.C.P. 1019(g), which
Rule relieves Plaintiff from the obligation to attach to pleadings any document that is of public record.
4. The Property subject to the Mortgage is more fully described in the legal description attached hereto as
Exhibit "A" (the "Property").
The Mortgage is in default because monthly payments of principal and interest are due and unpaid for
8/1A l and each month thereafter. By the terms of the Mortgage, upon failure of Mortgagor(s) to make
such payments after a date specified in written notice sent to Mortgagor(s), the entire principal balance and
all interest due and other charges due thereon are collectible forthwith.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance 105,714.98
Interest accrued at a variable rate 12,922.52
7/1/11 to 3/13/12
Attorney's Fees (to date) 725.00
Cumulative Late Charges 139.80
1/9/07 to 3/13/12
Suspense Balance (105.78)
Escrow Advance 22,526.88
TOTAL 141,923.40
The attorney's fees set forth above is based on work actually performed to date. The attorney's fees
requested are in conformity with the Mortgage documents and Pennsylvania Law. Plaintiff reserves its right
to collect attorney's fees up to 5% of the remaining principal balance in the event the Property is sold to a
third party purchaser at Sheriff's Sale, or if the complexity of the action requires additional fees in excess of
the attorney's fees accrued to date.
Plaintiff does not seek a judgment of personal liability (or an in personam judgment) against Defendant(s)
in the Action. Plaintiff, however, does reserve the 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 the personal liability
discharged in bankruptcy, but is intended only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania Law.
Notice of Intention to Foreclose as set forth in Act 6 of 1974 ("Act 6") and/or Notice of Default as required
by the Mortgage document, as applicable, have been sent by regular and certified mail to the Defendant(s) on
the date(s) set forth in the true and correct copies attached hereto as Exhibit "B."
WHEREFORE, PLAINTIFF demands an in rem judgment in mortgage foreclosure in the sum of $141,923.40,
together with interest from 3/14/12 at the adjustable rate in effect from time to time to the date of Judgment, and
other costs and charges incurred by Plaintiff that are properly chargeable in accordance with the terms of the
Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and
Sheriff's Sale of the Property.
FEDERMAN & ASSOCIATES, LLC
Date: _ d By:
Al-
0-1110mas M. Federman, Esq.
? Danielle Boyle-Ebersole, Esq.
Attorney(s) for Plaintiff
EXHIBIT
«A„
m9wwLC
L XldDmaipfiom
ALL THAT CERTAIN LOT OF GROUND LOCATED ON THE SOUTH SIDE OF
l3IILSIDB DRIVE IN THE BOROUGH OF CARLISLE, CUMBERLAND C"ZIT
PENNSYLVANIA,, MORE PARTICULARLY HOUNDED AND DEKMED AS
FOLLOWS: BWR4NM AT A POINT ON THE SOUTH SIDE OF HIL.ISIDE
DRIM WHICH POINT 1 S IN THE LINE DIVII)M LOT NOS. 128 AND 129 ON
THE EMMAPM REFERRED TO PLAN OF LOTS; T W4CE ALONG
HILLSIDE DRIVE SOUTH 87 DEGREES 56 MINUTES BAST 110 FEET TO A
POINT IN THE LINE DIVIDING LOT NOS. 129 AND 134 ON SAID FLAN;
TM4CB ALONG SAID DNIDING LINE SOUTH 13 DEGREES 41 MIIWTBB 20
SECONDS WEST 156.82 FEW TO A POINT COMMON TO LOT NO. 125,126.129
AND 134; THENCE ALONG THE LM MIJI)I IG LOT NOS. 126 AND L29 SOH
76 DEGREES 23 MINUTES WEST 83.53 FEET TO A POINT; THMCE, BY TIM
LINE DNWM LOT NOS. 128 AND 129 NORTH 02 DP.CRIIES 51 MINUTES
EAST 175.78 FEET TO THL PLACE OF BEGINNING.
TAX E* 0421.0322-367
1 Certify ti3? !)ts recorded .
In CLImbcridn! -QUIlty PA
Recorder of Dee&
AU%4127-
EXHIBIT
«B„
Law Offices of
FEDERMAN & ASSOCIATES, LLC
305 Old York Road, Suite 300
Jenkintown, PA 19046
(215) 572-5095
Fax: (215) 572-5099
info@federmanlegal.com
Stacy Blosser
730 Hillside Drive
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE
IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT
OF A LIEN AGAINST REAL ESTATE.
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.
NOTICE OF INTENT TO FORECLOSE MORTGAGE
DATE: November 22, 2011
HOMEOWNER'S NAME(S): Stacy Blosser
PROPERTY ADDRESS: 703 Hillside Drive, Carlisle, PA 17013
LOAN ACCT. NO: 0002443011
ORIGINAL LENDER: Mortgage Electronic Registration Systems, Inc. as
Nominee for Madison Equity Corporation
CURRENT LENDER/SERVICER: Wells Fargo Bank, N.A., as certificate trustee (not in its
individual capacity but solely as certificate trustee), in
trust for registered Holders of VNT Trust Series 2010-2
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: 703 Hillside Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT
because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are past due:
(1) Monthly Payments from 8/1/11 to 8/1/11 @ $760.36/month
(3) Monthly Payments from 9/1/11 to 11/1/11 @
$2,960.08/month
Other charges; Escrow, Inspection, NSF Checks
Unapplied Funds
TOTAL AMOUNT PAST DUE
760.36
8,880.24
20,955.88
105.78
30,702.26
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 $30,702.26 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:
SERVICER NAME: Franklin Credit Management Corporation
ATTN: Loan Servicing Department
ADDRESS: 101 Hudson Street
Jersey City, NJ 07302
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to
accelerate the mortgage debt. This means that the entire outstanding balance of this debt will
be considered due immediately and you may lose the chance to pay the mortgage in monthly
installments. If full payment of the total amount past due is not made within THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon
your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold
by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but
you cure the delinquency before the lender begins legal proceedings against you, you will still
be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
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 t30) DAY period, will not be required to nav
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 paving the total amount then past due
plus any late or other charges then due, reasonable attorneys 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 perforniing 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 FIVE 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:
SERVICER NAME: Franklin Credit Management Corporation
ATTN: Loan Servicing Department
ADDRESS: 101 Hudson Street
Jersey City, NJ 07302
PHONE NUMBER: 1-800-255-5897
FAX NUMBER: 1-201-839-4512
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's 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 Sheriff s Sale, a lawsuit to remove you and your furnishings and
other belongings could be started by the lender at any time.
YOU HAVE ADDITIONAL RIGHTS TO HELP PROTECT YOUR INTEREST IN THE
PROPERTY -- YOU 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. [YOU MAY HAVE THE RIGHT TO
SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE
MORTGAGE, ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS
DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
YOU MAY ALSO HAVE THE RIGHT TO ASSERT THE NONEXISTENCE OF A DEFAULT
IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED
UNDER THE MORTGAGE DOCUMENTS; ASSERT ANY OTHER DEFENSE YOU
BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER; OR SEEK
PROTECTION UNDER FEDERAL BANKRUPTCY LAW.
If you cure the default, the mortgage will be restored to the same position as if no default had
occurred. However, you are not entitled to this right to cure your default more than three times in
any calendar year.
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq.
(1977). you may dispute the validity of the debt or any portion thereof. If you do so in writing
within thirty (30) days of 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
2
thirty (30) days of receipt of this letter, this firm will send you the name and address of the original
creditor if different from above.
SENT VIA REGULAR AND CERTIFIED MAIL NUMBER(S)
7010 3090 0002 8193 6913
RETURN RECEIPT REQUESTED
3
FEDERMAN & ASSOCIATES, LLC
By: Thomas M. Federman, Esq., ID No. 64068
By: Danielle Boyle-Ebersole, Esq., ID No. 81747
305 York Road, Suite 300 ATTORNEY FOR PLAINTIFF
Jenkintown, PA 19046
(215) 572-5095 COURT OF COMMON PLEAS
CIVIL DIVISION
WELLS FARGO BANK, N.A., AS CERTIFICATE TRUSTEE
(NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS
CERTIFICATE TRUSTEE), IN TRUST FOR REGISTERED
HOLDERS OF VNT TRUST SERIES 2010-2
101 HUDSON STREET
JERSEY CITY, NJ 07302
Plaintiff
V. NO.
STACY BLOSSER A/K/A STACY J. BLOSSER CUMBERLAND COUNTY
730 HILLSIDE DRIVE
CARLISLE, PA 17013
Defendant(s)
VERIFICATION
I hereby state that I am the attorney for 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.
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: 2-)9_/-2,1
By: _ _ _, ;" X2 , '1-, /7' ?_ -
PC-Thomas M. Federman, Esq.
? Danielle Boyle-Ebersole, Esq.
Attorney(s) for Plaintiff
FORM I a I q 0iVil ter? IN THE COURT OF COMMON PLEAS OF
1?_c"t?) N P_)6.1y1L1 A CUMBERLAND COUNTY, PENNSYLVANIA
} J
Plaintiff(s)
vs.
*C"S
Defendant(s) Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
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 may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
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 Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
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 complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
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:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers:
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:
Date You Closed Your Loan:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
State: Zip:
Yes ? No ? Listing date: Price: $
Realtor Phone:
Yes ? No ?
Home:
Cell:
Office:
Other:
State: Zip:
How long?
Home:
Cell:
Office:
Other:
State: Zip:
How long?
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ? No ?
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 #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
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 Morta e Utilities
Car Payment(s) Condo/Nei . Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other pro .
payment
Install. Loan Payment -
Cable TV
Child Su rt/Alim. Spending Money
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 ? 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): Phone:
Servicing Company (Name):
Contact:
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
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Y Proof of income
Past 2 bank statements
V Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
- r (hardship letter)
V Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNT-
Ronny R Anderson ,
Sheriff .? -
Jody S Smith
Chief Deputy
a -
Richard W Stewart
"
Solicitor
Wells Fargo Bank, N.A.
vs.
Stacy J. Blosser Case Number
2012-2144
SHERIFF'S RETURN OF SERVICE
04/09/2012 09:03 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 8,
2012 at 2103 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Stacy J. Blosser, by making known unto William Blosser, Son of
Defendant at 730 Hillside Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the
same time handing to him personally the said true and correct copy of the same.
N SHALL, PUTY
SHERIFF COST: $34.00
April 12, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF