HomeMy WebLinkAbout12-4337
PHELAN HALLINAN & SCHMIEG, LLP
Melissa J. Cantwell, Esq., Id. No. 308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
Plaintiff
V.
ERIC R. CONRAD
VONNIE K. CONRAD
I MEMORY LANE
ENOLA, PA 17025-1569
Defendants
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ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. I a (-?3?1 ??<<
CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 302491
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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 ?f
you fail to do so, the case may proceed without you, and a judgment may be entered against
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 LA
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE
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 #: 302491
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Plaintiff is
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
2. The name(s) and last known address(es) of the Defendant(s) are:
ERIC R. CONRAD
VONNIE K. CONRAD
1 MEMORY LANE
ENOLA, PA 17025-1569
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described
3. On 04/22/2004 ERIC R. CONRAD and VONNIE K. CONRAD made, executed and
delivered a mortgage upon the premises hereinafter described to THE WASHINGTON
SAVINGS BANK, FSB which mortgage is recorded in the Office of the Recorder of
Deeds of CUMBERLAND County, in Mortgage Book 1862, Page 3355. By Assignme
of Mortgage recorded 03/05/2007 the mortgage was assigned to PLAINTIFF which
Assignment is recorded in Assignment of Mortgage Book 0734, Page 3914. 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 03/01/2012 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 #: 302491
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6. The following amounts are due on the mortgage as of 06/27/2.012:
Principal Balance $198,678.08
Interest $5,224.59
02/01/2012 through 06/27/2012
Escrow Credit ($538.76)
Suspense Credit ($1,423.61)
TOTAL $201,940.30
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. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable, have been sent to the Defendant(s) oil
the date(s) set forth thereon.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$201,940.30, 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 HALLINAN & SCHMIEG, LLP
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Attorney for Plaintiff
Melissa J. Cantwell, Esq.
ID 308912
File #: 302491
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or tract of land situated in East Pennsboro Township,
Cumberland County, Pennsylvania known and designated as Lot #60 on the Final Subdivision
Plan for Westwood Hills Phase V as recorded in Cumberland County Courthouse in Plan Book
87, Page 9 in which it is more fully bounded and described as follows, to wit:
BEGINNING at an iron pin in the western fifty (50) foot right-of-way known as Memory Lane
the corner of Lot 61, as it appears on the aforesaid Subdivision Plan; South four degrees sixteei
minutes thirty-six seconds East (S 04° 16' 36" E), forty-seven and twelve hundredths (47.12) ff
to an iron pin; thence along aforesaid right-of-way line, a curve to the right having a radius of e
hundred twenty-five and zero hundredths (125.00) feet, an arc length of fifty-nine and thirty-sip
hundredths (59.36) feet, South nine degrees nineteen minutes thirty-seven seconds West (S 09°
19' 37" W), a chord of fifty-eight and eighty hundredths (58.80) feet to an iron pin on the
western line of a fifty (50) foot right-of-way known as Memory Lane; thence along aforesaid li:>e
a curve to the right having a radius of fifteen and zero hundredths (15.00) feet, an arc length of
twenty-three and thirty-four hundredths (23.34) feet, South sixty-seven degrees thirty minutes
seven seconds West (S 67° 30' 07" W), a chord of twenty-one and five hundredths (21.05) feet to
an iron pin along the northern fifty (50) foot right-of-way known as Brisbain Lane; thence along
aforesaid right-of-way line, a curve to the left having a radius of two hundred twenty-five and
zero hundredths (225.00) feet, an arc length of fifty-two and eighty-seven hundredths (52.87)
feet, North seventy-four degrees thirty-nine minutes thirty seconds West (N 74° 39' 30" W), a
chord of fifty-two and. seventy-five hundredths (52.75) feet to an iron pin along the aforesaid
right-of-way line; thence along aforesaid right-of-way line, a curve to the right having a radius 8f
one hundred eighty-two and zero hundredths (182.00) feet, and arc length of nine and seventy-
File #: 302491
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four hundredths (9.74) feet, North seventy-nine degrees fifty-one minutes twenty-eight seconds
West (N '79° 51' 28" W), a chord of nine and seventy-four hundredths (9.74) feet to an iron pin at
the corner of Lot 59; thence along Lot 59 North four degrees sixteen minutes thirty-six seconds
West (N 04° 16' 36" W), ninety-two and zero hundredths (92.00) feet to an iron pin at the corner
of Lot 61; thence along Lot 61 North eighty-five degrees forty-three minutes twenty-four seconds
East (N 85° 43' 24" E) to an iron pin, the place of BEGINNING.
PROPERTY ADDRESS: 1 MEMORY LANE, ENOLA, PA 17025-1569
PARCEL. # 09-12-2992-301.
File #: 302491
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VERIFICATION
Damaris Stephanie Beltran, hereby states that h C/sh)eis Vice President Loan
Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent
for plaintiff in this matter, that he(she s 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 hi /her 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.
Name: Damaris Stephanie Beltran
DATE: `hint Zq , -Ul-L
Title: Vice President Loan Documentation
032-PA-V3 File #: 302491
FORM 1
IN THE COURT OF COMMON PLE?@
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WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENNSY-bMNX --4
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Plaintiff(s)
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ERIC R. CONRAD >n
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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) 243-9,10(
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 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 hav 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
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conferenc is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reason ble
arguments 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:
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Date
Melissa J. Cantwell, Esq., Id. No. 308912
Attorney 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
possible options while working with your counseling agency. Please provide the following inform
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:
Emai 1:
# of people in household:
Mailing Address
State: _ Zip:
Yes ? No ? Listing date: Price: $
Realtor Phone:
Yes ? No ?
Home:
Cell:
How long?
City: _ State: Zip:
Phone Numbers: HorrI Office:
Cell: Other:
Email: - -
# of people in household: How long?
First Mortgage Lender:
Type of Loan:
Loan Number: _ Date You Closed Your Loan.:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
State: Zip:
Office:
Other:
•mine
to
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:
I . _ Monthly Gross
2. Monthly Gross
3. Monthly Gross
Additional Income Description (not wages):
I . monthly amount:
2. monthly amount:
Monthly Net.
Monthly Net:
Monthly Net.
Borrower Pay Days:_ Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE ; AMOUNT EXPENSE AMOUNT
Mortgage _ Food
2°d Mortgage
_
Utilities _
Car Pa ment(s) Condo/Nei h. Fees
Auto Insurance
_
Med. (not covered) _
Auto fuel/repairs
_
Other pro payment _
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care/Tuft. 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 F-1 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 O No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and 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 evaluatii
financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation
use the counseling 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:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hard
letter)
6. Listing agreement (if property is currently on the market)
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
E t1E PR r t,0 it?st tl
2012 JUL 23 AM 8: 36
_ `UMBEELANG G Ufi
PENNSYLYANIA
u9?tlt?r of t':?t,u??flfar
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Wells Fargo Bank, N.A.
vs.
Eric Reigle Conrad (et al.)
Case Numb
2012-4337
SHERIFF'S RETURN OF SERVICE
07/16/2012 09:17 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 16,
2012 at 2117 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of
Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Vonni
Kay Conrad, by making known unto Eric Conrad, Husband of Defendant at 1 Memory Lane, Enola,
Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the
said true and correct copy of the same.
DENNI S---f R___YA6 DE
07/16/2012 09:17 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 16,
2012 at 2117 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of
Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Eric
Reigle Conrad, by making known unto himself personally, at 1 Memory Lane, Enola, Cumberland Cou ty,
Pennsylvania 17025 its contents and at the same time handing to him personally the said true and corr ct
copy of the same.
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DENNI RY, DEPUTY
SHERIFF COST: $59.00
July 17, 2012
SO ANSWERS,
R ANDERSON, SHERIFF
C ou ?vSu e Sce',Jf le _ cti. IE,.,
LEON P. HALLER, ESQUIRE
PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102-2392
(717)234-4178
ATTORNEY FOR DEFENDANT
WELLS FARGO BANK, N.A.
Plaintiff
VS.
ERIC R. CONRAD and
VONNIE K. CONRAD
Defendants
TO THE PROTHONOTARY:
MELISSA J. CONTWELL, ESQUIRE
PHELAN HALLINON & SCHMEIG, LLP
SUITE 1400 - ONE PENN CENTER PLAZA
1617 JFK BOULEVARD
PHILADELPHIA, PA 19103
(215)563-7000
ATTORNEY FOR PLAINTIFF :..o
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CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL DIVISION
NO. 12-4337 CIVIL
ENTRY OF APPEARANCE
Please enter the appearance of Purcell, Krug & Haller as
attorneys for Defendants, Eric R. Conrad and Vonnie K. Conrlad, in
the above captioned action.
PURCEL
LER
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By:
Leon P. Hal er
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Defendants
Dated: August 6, 2012
WELLS FARGO BANK, N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA,
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CIVIL ACTION
vs. 4337 :''
NO. 12-437 CIVIL ~ ~_
ERIC R. CONRAD and '"~~b `~''
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VONNIE K. CONRAD, y~ `_.
Defendants ~-
CASE MANAGEMENT ORDER
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AND NOW, this ~~~ day of August, 2012, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in acourt-supervised
conciliation Conference on (S~i~~FiL. 3 ~6/a , at ~~m. in Chambers
No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiffllender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetzry payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
Melissa J. Cantwell, Esquire
Phelan Hallinan & Schmieg, LLP
Suite 1400
One Penn Center Plaza
1617 JFK Boulevard
Philadelphia, PA 19103
For the Plaintiff
~ Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102
For the Defendants
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Leon P. Haller, Esquire
Attorney ID No. 15700
Attorney for Defendants
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
717.234.4178
lph@pkh.com
WELLS FARGO BANK, N.A. : IN THE COURT OF COMMON PLEAS
3476 Stateview Boulevard
Fort Mill, PA 29715
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
NO. 12-4337 CIVIL
ERIC R. CONRAD
VONNIE K. CONRAD :CIVIL ACTION -LAW
1 Memory Lane
Enola, PA 17025-1569
Defendants : IN MORTGAGE FORECLOSURE
TO: Melissa J. Cantwell, Esquire
Attorneys for Plaintiff
Phelan Hallinan & Schmieg, LLP
Suite 1400
One Penn Center Plaza
1617 JFK Boulevard
Philadelphia, PA 19103
NOTICE
You are hereby notified to file a written response to the within Defendant's
New Matter within twenty (20) days from service hereof or a judgment may be
entered against you.
Dated: August 23, 2012
Respectfully submitted,
Leon P. Haller; Esquire
Attorney ID # 15700
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorney for Defendants
Melissa J. Cantwell, Esquire
Attorney ID No. 308912
Attorneys for Plaintiff
Phelan Hallinan & Schmieg,LLP
Suite 1400
One Penn Center Plaza
1617 JFK Boulevard
Philadelphia, PA 19103
(215)563-7000
Leon P. Haller, Esquire
Attorney ID No. 15700
Attorney for Defendants
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
717.234.4178
Iph@pkh. com
WELLS FARGO BANK, N.A.
3476 Stateview Boulevard
Fort Mill, PA 29715
Plaintiff
vs.
ERIC R. CONRAD
VONNIE K. CONRAD
1 Memory Lane
Enola, PA 17025-1569
Defendants
~? AUG 24 AM 9~ 4 I
~~AiH# TY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. I2-4337 CIVIL
CIVIL ACTION -LAW
IN MORTGAGE FORECLOSURE
DEFENDANTS' ANSWER TO COMPLAINT IN MORTGAGE FORECLOSURE.
AND NEW MATTER
AND NOW comes Defendants, Eric R. Conrad and Vonnie K. Conrad, by their
attorneys, Purcell, Krug & Haller, and answer the Complaint in Mortgage Foreclosure as
follows:
1. - 4. Admitted.
5. Admitted in part and denied in part. It is admitted that certain payments
have not been paid. It is denied that Defendants are not able to make
mortgage payments that would be required pursuant to a loan modification
plan..
6. Admitted in part and denied in part. It is admitted that the amounts set
forth are generally due and owing. It is denied that these are the exact
figures without opportunity of reviewing the loan history.
7. Denied. This is a legal conclusion to which no responsive averment is
required.
8. Denied. This averment lacks in specificity. It is denied that Notice of
Intention to Foreclose is attached or was sent. In further answer thereto, it
is denied that this averment accurately sets forth whether or not Notice of
Intention to Foreclose was required.
NEW MATTER
9. Defendants incorporate herein by reference the Answers to Paragraphs 1
through 8.
10. Defendants had applied for loan modification following a serious medical
condition of Eric R. Conrad in December of 2011.
11. Defendants believe they are qualified for a loan modification or other
relief under federal guidelines.
12. Defendants have sufficient income to maintain future mortgage payments.
WHEREFORE, Defendants request the Complaint be dismissed..
PURCELL, KRUG & HALLER
By: /
Leon P. caller
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attomey ID #15700
Attorney for Plaintiffs
Dated: August 23, 2012
VERIFICATION
I, Eric R. Conrad, verify that the statements made
the foregoing Answer and New Matter are true and correct
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
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Dated:
CERTIFICATE OF SERVICE
I, Leon P. Haller, Attorney for Plaintiffs, hereby certify that a true and
correct copy of the foregoing Defendants' Answer to Complaint in Mortgage Foreclosure,
New Matter was forwarded to the following individuals by regular U. S. Mail, first class
service, postage prepaid, on August 23, 2012 addressed as follows:
Melissa J. Cantwell, Esquire.
Phelan Hallinan & Schmieg,LLP
Suite 1400
One Penn Center Plaza
1617 JFK Boulevard
Philadelphia, PA 19103
__~-
Leon P. Haller
Attorney for Defendants
Dated: August 23, 2012
WELLS FARGO BANK N.A.,
Plaintiff
vs.
ERIC R. CONRAD and
VONNIE K. CONRAD,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 12-4337 CVIIL
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this ~ day of November, 2012, because of a scheduling conflict in this
office, the conciliation conference in this matter-set for November 16, 2012, is continued to
Friday, December 14, 2012, at 2:30 p.m. in Chambers of the undersigned.
BY THE COURT,
V Brian Yoder, Esquire
For the Plaintiff
/ Leon T. Haller, Esquire
For the Defendants
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WELLS FARGO BANK N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION—LAW
NO. 12-4337 CVIIL
ERIC R. CONRAD and
VONNIE K. CONRAD,
Defendants
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this lG ` day of April, 2013, at the request of counsel for the parties, the
conciliation conference in this matter set for April 17, 2013, is continued to Friday, July 19,
2013, at 3:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin . Hess, P. J.
Joseph Schalk, Esquire
For he Plaintiff
Leon T. Haller, Esquire
For the Defendants
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WELLS FARGO BANK N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION—LAW
NO. 12-4337 CVIIL
ERIC R. CONRAD and
VONNIE K. CONRAD,
Defendants
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW,this e G' day of July, 2013, at the request of counsel for the parties, the
conciliation conference in this matter set for July 19, 2013, is continued generally.
BY THE COURT,
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Kevin . Hess, P. J.
,/Joseph Schalk, Esquire
For the Plaintiff
,/Leon T. Haller, Esquire
For the Defendants
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