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HomeMy WebLinkAbout12-4938FEDERMAN & 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 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 V. Plaintiff NO. la- 1141,39 04vill? CUMBERLAND COUNTY STEPHEN W. TAYLOR AWA STEPHEN TAYLOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 Defendant(s) -C co CIVIL ACTION - LAW (3.0 REAL PROPERTY) °y COMPLAINT IN MORTGAGE FORECLOSURE 3010 FORECLOSURE NOTICE = r _ 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) clays 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--- r /03.76 A7 C-f 29 33 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 NOTIFICACIbN. 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 DAPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE P.AGAR 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.,g_ov for Help for Homeowners Facing the Loss of Their Homes 4) Call Plaintiff (your lender) at (800) 306-6062 and ask to speak to someone about Loss Mitigation or Home Retention options. 5) Call or coitact 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@federTnanlegal.com. 'Para informacion en epanol, si puede comunicarr con Tomas al (215) 572-5095 *** This Action ofMortgage Foreclosure will continue unless you take action tostop it. Plaintiff is: 2. 4. 6. U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 The name(s) and last known address(es) of the Defendant(s) are: STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 who is/are the "Mortgagor(s)" and/or "Real Owner(s)" of the Property hereinafter described. On or about 11/03/06 Mortgagor(s) made, executed and delivered a Mortgage upon the Property hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee for Fulton Bank, which Mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Book 1972, Page 2138 (the "Mortgage"). The Mortgage was last assigned to Plaintiff by Assignment of Mortgage, which was recorded on 04/11/12 as Document #105866. 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. 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 12/01/10 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. The following amounts are due to Plaintiff on the Mortgage: Principal Balance 630,023.58 Interest accrued at a variable rate 55,278.13 11/01/10 to 06/26/12 Attorney's Fees (to date) 725.00 Cumulative Late Charges 888.66 11/03/06 to 06/26/12 Property Inspection(s) 49.50 Property Preservation 335.00 Escrow Advance 2,610.66 TOTAL 689,910.53 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. 9. 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." 10. This action does not come under Act 6 because the original principal balance of the Mortgage exceeds the dollar amount provided in the statute. WHEREFORE,, PLAINTIFF demands an in rem judgment in mortgage foreclosure in the sum of $689,910.53, together with interest from 06/27,112 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. Date: / Z FEDERMAN & ASSOCIATES, LLC By: -Thomas M. Federman, Esq. ? Danielle Boyle-Ebersole, Esq. Attorney(s) for Plaintiff EXHIBIT "All United General Title Insurance Company Commitment SCHEDULE C Legal Description ALL THAT CERTAIN tract of land, situate in the Township of Monroe, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern right-of-way line of Lucinda Lane at the corner of Lot No. 32 and Lot No. 19, Phase II as shown on the hereinafter mentioned plan of lots; thence along said right-of-way line by a curve to the left having a radius of 225.00 feet and an arc length of 20.403 feet to a point; thence continuing along said right-of-way line of Lucinda Lane North 76 degrees 19 minutes 51 seconds East, a distance of 181.078 feet to a point at the dividing line between Lot No. 31 and Lot No. 32; thence along said dividing line South 12 degrees 22 minutes 31 seconds East, a distance of 259.629 feet to a point; thence continuing South 11 degrees 10 minutes 50 seconds West, a distance of 143.347 feet to a point; thence North 86 degrees 40 minutes 24 seconds West, a distance of 340.503 feet to a point at the dividing line between Lot No. 32 and Lot No. 19, Phase 11; thence along said dividing line North 17 degrees 32 minutes 41 seconds East, a distance of 385.192 feet to a point, said point being the Place of BEGINNING. BEING Lot No. 32 on Subdivision Plan of Duffield Crossing, Phase III recorded December 14, 2001 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 84, Page 78. UNDER AND SUBJECT to Declaration of Restrictive Covenants recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 683, Page 461, amended in Miscellaneous Book 696, Page 4280. UNDER AND SUBJECT to setbacks, easements, rights-of-way, conditions and restrictions as shown on the above plan of record. ALSO UNDER AND SUBJECT to existing storm drains along the western lot line as shown on the above referenced plan. BEING THE SAME premises which McCormick Crossing, a Pennsylvania General Partnership, record owner and Wheatland Custom Homes, Inc., a Pennsylvania Corporation, equitable owner, by their deed dated the 24th day of October, 2006 and to be recorded simultaneously herewith, granted and conveyed unto Stephen W. Taylor and Dana L. Minor, husband and wife, MORTGAGORS herein. BK 1 972PG2 15 8 EXHIBIT «B„ June 29, 2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached napes The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with You when you meet with the Counseling Agency The name, address and .phone number of Consumer Credit Counseling Agencies serving Your county are listed at the end of this Notice. If You have any uuestions you may call the Pennsylvania Housing Finance Agency toll free at 1(800) 342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you 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 A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO (1-800- 342-2397). PUEDES SER ELEGIBLE PARA UN PRASTAMO 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. Page 3 of 7 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Stephen W Taylor Dana L Minor 548 Lucinda Dr Mechanicsburg, PA 17055 FL-5700549000 Fulton Bank, NA Fulton Bank, NA 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. 1F 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 leader 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 HE" APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS FO THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THATMEETINCs THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE " YOU HAVE THE RIGHT TO FILE A HEMe 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. Page 4 of 7 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: IV YOU ARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLYAND 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: 548 Lucinda Dr, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS FROM 12/01/10 THROUGH 06/01/11 and are currently past due for the following amounts: Total Payment Amount: $27,909.07 Late/Other Charges: $1,794.15 Attorney Fees: $580.00 TOTALAMOUNT PAST DUE: $30,283.22 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 $30,283.22, 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 chec4 certified check or money order made payable and sent to: ATTN: Melinda Zellers Fulton Bank, NA PO Box 4887 Lancaster, PA 17604-4887 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender Intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon. your mortgaged Property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified to writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. Page 5 of 7 EARLIEST POSSIBLE SHERIF'F'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 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER.: Name of Lender: )Fulton Bank, NA .Address: PO Box 4887 Lancaster. PA 176044887 Phone Number: (800) 521-8617 x8584 Fax Number: (717) 391-2908 Contact Person: Melinda Zellers Residential Morteare Collector EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and you 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 - If permitted by your mortgage documents, you may be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BYANY THIRD PARTYACTING 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. Sincerely, 6ghMd-J A4,?o Melinda Zellers Authorized Representative Fulton Bank, NA Certified and Regular Mail Consumer Credit Counseling Agencies CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1515 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Page 6 of 7 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 The Pennsylvania housing Finance Agency can be reached TOLL FREE at 1-800-342-2397 Page 7 of 7 ACT 91 LETTER - 06/28/2011 70110110 00017199 9067 CERTIFIED RECEIPT MINOR, DANA L. / #57b0549000(1057) a s 9gg$_ r Post"o f`- CermW Fee 4? b ??Fboerat ti h°Ac Hem r (mod ".q,= rj p Q. Total Pow ? f O DANA L MINOR ,q ag5w 548 LUCINDA DR j f°? . orAO MECHANICSBURG, PA 17055 .sale. in cw4* 6e um 1„ 2. end & Afao is tam 4 r d Ddvwy is d wWL ? . ?.. ' ite1r10 and address on the reverse ?P cw'mWM the cud to you. card m the beck of?the malkMM, . _ front V space pemd6L 1. Mr-9 'Ad*emd fm } .. - :.. DANA L?IINQRS 548 LU*DA SR MECHANI`(SB&G, PA 1.7055 2. Ar" Number 0 7011 A. f lPA 13 Agent D A.eiesee EL Rwdod by (Pt>hfad Mwo a. Oda-of Denary 1 "L D. ft m 1 Cl Yes H Yom, enterd*M eddresabefow: 0 No t 3. IWO f owdded Med 13 egmess hW ? Re*WW ES Return fboe%2 for Merabandlse ? hand Mad C] 041 a Restck W fJelaery? Oft Fee) 0 Yes i 117.0 0001 7199 9067 --- -- C Pokrn Reoefpt ;7--)J 1057.FL-5700549000 STEPHEN W TAYLOR 548 LUCINDA DR MECHANICSBURC; PA 17055 Page I of 7 (This page intentionally left blank) Page 2 of 7 June 29, 2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home This Notice explains how the program woirks To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any auestionsyou may call the Pennsylvania Housing Rnance Aeencv 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO (1-800- 342-2397). PUEDES 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. Page 3 of 7 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT NO.: ORIGINAL LENDER: CURRENT LENDERISERVICER: Stephen W Taylor Dana L Minor 548 Lucinda Dr Mechanicsburg, PA 17055 FL-5700549000 Fulton Bank, NA Fulton Bank, NA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELPYOU 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 FO THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE " YOU HAVE THE RIGHT TO FILE A HEMP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Page 4 of 7 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 INFORMATIONAL PURPOSES ONLYAND 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 Brine it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 548 Lucinda Dr, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS FROM 12/01/10 THROUGH 06101111 and are currently past due for the following amounts: Total Payment Amount: $27,909.07 Late/Other Charges: $1,794.15 Attorney Fees: $580.00 TOTAL AMOUNT PAST DUE: $30,283.22 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 $30,283.22, 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: ATTN: Melinda Zellers Fulton Bank, NA PO Box 4887 Lancaster, PA 176044887 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon Your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you,. you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the tender 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 (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time un 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 attomev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortga 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. Page 5 of 7 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 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Fulton Bank. NA Address: PO Box 4887 Lancaster, PA 176044887 Phone Number: (800) 521-8617 x8584 Fax Number: (717) 391-2908 Contact Person: Melinda Zellers Residential Morteaee Collector EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and you 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. ASSUMPTION OF MORTGAGE - If permitted by your mortgage documents, you may be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBTOR 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 CALENDARYEAR) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENM YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Melinda Zellers Authorized Representative Fulton Bank, NA Certified and Regular Mail Consumer Credit Counseling.Agencies CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Page 6 of 7 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 The Pennsylvania housing Finance Agency can be reached TOLL FREE at 1400-342-2397 Page 7 of 7 ACT 91 LETTER - 06/28/2011 7011 0110 0001 7199 9319 CERTIFIED RECEIPT , TAYLOR, STEPHEN W.. / #5700(10571 cr M FIc! ? Er PO~ 5 +30Fi ? r`q- coMeaFvG 1 a p F- a ? ?? °u ( 5.79 c? y ? ?5a , M rA Tow Posts- Q o STEPHEN W TAYLOR _ 0 548 LUCINDA DR d • Oa or POBoxr - MECHANICSBURG, PA 17055 ? .. -- - _._.-.-... -. MW & Also 0mvMv OOMPIOW bm *W Restdc?d?ty des ¦ Prlrtt Y0 Pam and address an the reverse so Met.Y an rtum the card W YOLL ¦ Attach th w wd m the back of the rraWem ?r:orl t rrur>t if space parmrm I, ARko Is A sd to: i i EWEN W TAYLOR 54$ LUCINDA DR MECHANICSBUp pp, 17055 2 Node NVumbw PS F6rni 3811; Fib - i A. taa X O'•AMa D Afto EL by(ftiteaiMwnW C, D4atVA D. tsdeYMaddMwdfiewttia RYES„ ddvayaddress O" W Md 0 a pm Mai I Cl Re Mend 0 Rettan PMMV for Mw*mdse 0 kvied Md [] CAD. 4. PasEticmd Degvertlt (Extra Feel 0 Yes f 99 9319 ta¢nn.?sao r: t0t?`1ttDy'r0 0001 71 4 Domestic Setum 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 U.S. BANK NATIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 Plaintiff NO. STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR CUMBERLAND COUNTY 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 Defendant(s) VERIFICATION I, Rose Lara, as representative of the Plaintiff corporation within named do hereby verify that 1 am authorized to make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. U.S. BANK NATIONAL ASSOCIATIO OT IN ITS INDIVIDUAL CAPACITY, BUT SO LY S TRUSTEE FOR THE AC TRUS , SE ES 2011-2T BLC IITS APO ?L OA MAONE - E FAC SERVICES 1 Name: Rose Iva' Title: Vice President Client Verification ? 12.21.10 FORM I Plaintiff(s) vs. Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA /a- IW35' ;V<< <err i Civil -?' yC` V NOTICE OF RESIDENTIAL MORTGAGE FORECW-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 tender 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 attsched 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: State: Zip: Is the property for sale? Yes ? No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ? No ? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: Phone Numbers: State: Zip: Home: Office: Cell: Other: Email: # of people in household: How long? First Mortgage Lender: _ Type of Loan: Loan Number: _ Second Mortgage Lender: Type of Loan: _ Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primar Reason for Default: Date You Closed Your Loan: Included Taxes & Insurance: 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: Amount owed: Value: Automobile #2: Model: 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): I . 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/re airs Other prop. payment Install. Loan Payment Cable TV Child Su rt/Alim. Spending Money DayXhild CareJTuit. 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:_ Year: Year: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We, , authorize the above named _ to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Y Past 2 bank statements Proof of any expected income for the last 45 days Yr Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation f (hardship letter) Y Listing agreement (if property is currently on the market) 3 SHERI'FF'S OFFICE OF CUMBERLAND C±~~1!~ Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~o~~titr of ~ernbrr~r~~@ ~r~.s ,, -7s. ~~ ~ I~~~ ~'.t~`~i~Pi'OT,~.t~,Y ~!' 2 Al~~' 17 AM 9~ (I I Richard W Stewart Solicitor Q~fl~@ QF "~E $M~RIFF E '.J~ 1~RLAN~ CE~~f~d Y ~'EP~~iS`tL~'ANiA US Bank National Association vs. Case Number Stephen W. Taylor (et al.) 2012-4938 SHERIFF'S RETURN OF SERVICE 08/10/2012 03:20 PM -Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on Augu 10, 2012 at 1520 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 v Stephen W. Taylor, by making known unto Dana L. Minor, adult in charge at 1260 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same tune handing t her personally the said true and correct copy of the same. 08/10/2012 03:20 PM -Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on Aug 10, 2012 at 1520 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 t Dana L. Minor, by making known unto herself personally, at 1260 Windsor Road, Mechanicsburg, Cumberland County Pennsylvania 17050 its contents and at the same time handing to her personally said true and correct copy of the same. Dana L. Minor confirmed to Deputies the residence of 548 Lucinda Drive, Mechanicsburg, Pennsylvania remains vacant. TIM LA K, DEPUTY SHERIFF COST: $86.00 SO ANSWERS, ~Q~ August 13, 2012 R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. FEDERMAN & 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 X215) 572-5095 U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 v. Plaintiff STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 Defendant(s) .(. ._ rt .~ .~__ ATTORNEY FOR PLAINTIFF-~: ~,~ -- - -- ~ COURT OF COMMON PLEAS ~ ~_~ ~~ - ~__~ CIVIL DIVISION ~=~ '`= t.... c.:a ~'}. .. -. ~.;..? NO. 12-4938-Civil CUMBERLAND COUNTY ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Balance $689,910.53 Interest From: 6/2712 to 11/8/12 $9,320.40 (Per Diem $69.04) TOTAL $699,230.93 FEDERMAN & ASSOCIATES, LLC . „(~ s Thomas M. Federman, Esq. xDanielle Boyle-Ebersole, Esq. Attorney for Plaintiff Cl~~ 2,7 39°r~~~t ~ ~~$ 3 ~~e ~\~~ AND NOW, this day of ~~ . ,201 !Z, Judgment is entered in favor of Plaintiff, U.S. BANK NATIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T, and against Defendant(s), STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR AND DANA L. MINOR, and damages are assessed in the amount of $699,230.93, plus interest and costs. BY TH ROT ON Y: =. ~r ~... FEDERMAN & ASSOCIATES, LLC By: Thomas M. Federman, Esq., ID No. 64068 By: Danielle Boyle-Ebersole, Esq., ID No. 81747 305 York Road, Suite 300 Jenkintown, PA 19046 (215) 572-5095 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 v. Plaintiff NO. 12-4938-Civil STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 CUMBERLAND COUNTY Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF MONTGOMERY SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant(s), STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR AND DANA L. MINOR is/are over eighteen (18) years of age and reside/s at 548 LUCINDA DRIVE, MECHANICSBURG, PA 17055. Copies of the Military Reports are attached hereto and marked as Exhibit "A." SWORN TO ANDS CRIBED BEF ME THIS ~~~ DAY OF ;~ ~Y1 ~,~~~~ , 2012. FEDERM~A/N~ & ASSOCIATES, LLC NOTARY PId$LIC ~~ Thomas M. Federman, Esq. >C Danielle Boyle-Ebersole, Esq Attorney for Plaintiff TIFFANY ANN McGMM1Y, C~onnilli~oe ! ~ ffi1 ~sR64 r t ..~ _.. ~.-.r~.+.., w~. ,... .. tA:~.. ~ ..r . 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 (2151572-5095 COURT OF COMMON PLEAS CIVIL DIVISION U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 Plaintiff NO. 12-4938-Civil STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR CUMBERLAND COUNTY 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 Defendant(s) CERTIFICATION I, the undersigned attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFO ME THIS ~`T~bAY OF 1JU 20~. FEDERMAN & ASSOCIATES, LLC Thomas M. Federman, Esq. ;X Danielle Boyle-Ebersole, Esq. Attorney for Plaintiff COMMONWEALTH OF pl;HNfYLVANII- NOTARIAL SEAL TIFFANY ANN Mc:GINTY, PubYc ~ 8oro., Monpom~t :_ 1(~ff3Y` ~ ' . 't . +j1ft~~l1 ~?'1AE! fTIN06tM1~': VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. § 4909 relating to unsworn falsification to authorities. FEDERMAN & ASSOCIATES, LLC Thomas M. Federman, Esq. Danielle Boyle-Ebersole, Esq. Attorney for Plaintiff -Department of Defense Manpower Data Center a7 W 4ia ~ 11i.i~ l~u~nt t4 51~rvicernc~nb~rs Civil. Relief Act Last Name: MINOR First Name: DANA Middle Name: Active Duty Status As Of: Nov-08-2012 Results as of :Nov-08-2072 10:20:04 SCRA 2.3 .On Active Duty On ActlveDury Status Date Active Duty ^,stert Date :Active Duty End Date 6latus Service Corponent NA NA No NA This response reflects the individuals' active duty status based on the Active DutyStatus Date t.ett Active Duty within 387 Days of Active Duty Status Date Active Otdy Start Date Alive Duty Fsd Date Status Service Component NA NA No NA This response reflects vAiero fife individual left active duty status wlUim 387 days precedNpi the Atitiva Duty Status Date The Member w His/Her Urtif was Notiltad Of a Future CalWploActiwe Duly drt Actlve Duty Stelua.Dem Order Notificatbn Start Date Older NotaficaUor+ Ertl Date Biafra SeMee Component NA NA No NA This response reflects whetlter the {itdivldual or hislhe; and has receivrd aedy rw8ficaAion to report for active duty Upon searching the data banks of the Department of Detense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~ ~-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Wlanpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.millfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: C5J66UC88G .Department of Defense Manpower Data Center • Jt~t~ ~~~ ]pursuant to S~vicernemt ~iv1 lliwvi'Aet Last Name: TAYLOR First Name: STEPHEN Middle Name: Active Duty Status As Of: Nov-08-2012 Results as of : Nov-0&2012 10:16:37 SCRA 2.3 On Aetive.Duty On ACWa Duty Status Date Active Duty Start Dete Active Duty EM Date $taWS Service Camportertt" NA NA No NA This response reflects Cte individuals' active duty status based on 1ha Active Duty Status Date L.efl Active Duty Wfthin 367 Days dAdMDuty Stable Date Active Duly 3tert Date Active Duty End Date Status Service Component NA NA No NA This response retfacts vrttere the kM{vkual left active duty stelae wlatiA 367 days preceding tine AraiveDuty Status Date The fvbmber or H'tsJHer Unit Was Notirted of a Puttee CaLLI/p to Active Duty on At We Duly Status Date Order Notification StaA Date Order Notificatbn End Date Status S6rv&aCorrtptuterd NA NA 1Jo NA This response reflects whether the trwnaud or trfrher unit has received eevty notiflcatSon to repoA fa active duty Upon searching the data banks of the Department of Defense Manpower Rata Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~ ~ ~' Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 ThA Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http:!lwww.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inGusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 8DT80546A9 EXHIBIT «R~~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Prothonotary Date: November 5, 2012 To: Stephen W. Taylor a/k/a Stephen Taylor Dana L. Minor 548 Lucinda Drive and 1260 Windsor Road Mechanicsburg, PA 17055 Mechanicsburg, PA 17050 U.S. Bank National Association, et al Plaintiff v NO. 12-4938 Civil Stephen W. Taylor a/k/a Stephen Taylor, et al. Defendant(s) NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (I O) DAYS FROM THE DATE OF THIS NOTICE, A IUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. C~Jmberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRrrO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (1 O) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y LISTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORC[ONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800)990-9108 FEDERMAN & ASSOCIATES, LLC ..-~ _.~__-~ By:~~~ ~--- ,, ,'~~'_ _ °~ Thomas M. Federman, Esq., ID No. 64068 ~'C.Danielle Boyle-Ebersole, Esq., ID No. 81747 Attorney(s) for Plaintiff ~ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA David D. Buell Prothonotary To: STEPHEN W. TAYLOR AND STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR A/K/A STEPHEN TAYLOR DANA L. MINOR DANA L. MINOR 548 LUCINDA DRIVE 1260 WINDSOR ROAD MECHANICSBURG, PA 17055 MECHANICSBURG, PA 17050 U.S. BANK NATIONAL ASSOCIATION., NOT IN ITS INDIVIDUAL CAPACITY, BUT SOLELY AS TRUSTEE FOR THE RMAC TRUST, SERIES 2011-2T C/O RUSHMORE LOAN MANAGEMENT SERVICES, LLC 15480 LAGUNA CANYON ROAD, SUITE 100 IRVINE, CA 92618 v. Plaintiff N0.12-4938-Civil STEPHEN W. TAYLOR A/K/A STEPHEN TAYLOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 DANA L. MINOR 548 LUCINDA DRIVE MECHANICSBURG, PA 17055 Defendant(s) NOTICE CUMBERLAND COUNTY Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession David D. Buell Prothonotary n1a~~~a I ::~ w ,. ~+.. ~ ~.. If you have any questions concerning this Judgment, please call: FEDERMAN & ASSOCIATES, LLC at (215) 572-5095.