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HomeMy WebLinkAbout12-5232 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - IIl#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - II3#90675 s__ SALVATORE CAROLLO, ESQUIRE - lD#311050 ~ PAIGE M. BELLING, ESQUIRE - II3#309091 ~ 3 ~ HARRY B. REESE, ESQUIRE - ID#310501 ~rn c KASSIA FIALKOFF, ESQUIRE - ID#310530 ~ rte- rv ELIZABETH L. WASSALL, ESQUIRE - ID#77788 -cz AGNES MOMBRUN, ESQUIRE - ID#309356 s¦ ELANA B. FLEHINGER, ESQUIRE - II}#209197 z~ ~ o c-: KATHERINE E. KNOWLTON, ESQUIRE - lD#311713 ~a°•--+,,,~ WOODCREST CORPORATE CENTER~~ ~ 111 WOODCREST ROAD, SUITE 200 , CHERRY HII.L, NJ 08003-3620 856-669-5400 pleadings@udren.com MTG Finance, LLC COURT OF COMMON PLEAS C/O Quantum Servicing C1VII. DIVISION 6302 E. MLK Blvd., Suite 300 CUMBERLAND County Tampa, FL 33619 Plaintiff nn - 3 ~ v. NO. ' pC MARGARET K. DRIVER 833 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in th following pages, you must take action within twenty (20) days after this Complaint and Notic are served, by entering a written appearance personally or by attorney and filing in writing wi the Court your defenses or objections to the claims set forth against you. You are warned that i you fail to do so the case may proceed without you and a judgment may be entered against yo by the Court without further notice for any money claimed in the Complaint or for any othe claim or relief requested by the Plaintiff. You may lose money or property or other right important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW_ THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIiING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE O NO FEE. ~ 3. ~ std a d # ~f Sal S C X9(08/ 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION MTG Finance,LLC Plaintiff v. Margaret K. Driver NO. 12-5232-CIVIL Defendant(s) ORDER AND NOW, thisec day of 0 G ZeA, 2013, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Margaret K. Driver, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 833 OLD SILVER SPRING ROAD MECHANICSBURG PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MARGARET K. DRIVER 833 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 BY T- ' OURT• J. r•n r • 6 : s. n LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuesta en las paginas siguientes, usted tiene veinte (20) dies de plazo al partir de la fecha de la demand y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado entregar a la cone en forma escrita sus defenses o sus objeciones a las demandas en contra de s persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuer 1 demanda en contra suya sin previo aviso o notificacion. Ademas, la cone puede decidir a favo del demandante y requiere que usted cumpla con todas las provisiones de esta demands. Uste puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA 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 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 i i i _ _ _ NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notif~ us within 30 days after receipt of this Notice and the attached document that the validity o the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. you do notify us in writing of a dispute within the 30 day period, we will obtain verificatio of the debt or a copy of a judgment against you, and mail it to you. If you do not disput the debt, it is not an admission of liability on your part. Also, upon your written reques within the 30 day period, we will provide you with the name and address of the origina creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will ceas collection of your debt, or any disputed portion of it, until we obtain the information tha is required and mail it to you. Once we have mailed to you the required information, w will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached documen is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 - _ _ 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of th~ Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of th Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments o Mortgage, all of which have either been recorded or Plaintiff is in the process o~ formalizing the actual Assignment of Mortgage in Plaintiff s favor: I Assignor: Mortgage Electronic Registration Systems, Inc., acting solely as nominee for First NLC Financial Services, LLC, DBA The Lending Center Assignee: MTG Finance, LLC Date of Assignment: 09/30/2009 Recorded Date: 10/09/2009 Bookllnstrument Instrument # 200934716 Page: NA . ' 2. Upon information and belief Defendant(s) and/or their predecessor: Margaret K. Driver (hereinafter "Defendants"), are the owners of property located at 833 Old Silver Spring Road, Mechanicsburg, PA 17055 , by virtue of Deed dated 08/12/1997 and recorded 08/13/1997 in Official Records Book 162 at Page 794 of the Public Records of i Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 07/19/2007 ,Defendant(s) and/or their predecessor: MARGARET K. DRIVER promised to pay to the order of First NLC Financial Services, LLC, DBA The Lending Center ,the principal sum of $ 74,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 07/20/2007 ,Defendant(s) and/or their predecessor: I 1 The interest rate is subject to adjustment if more fully described as such in the note andI mortgage. The interest rate on the subject note is at 3.95000 The per diem interest accruing on this debt is $8.56 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late chazge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $20.81. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached ' hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $85,392.41 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES .C. BY: Katherine E. Knowlton, Esq PA IO 311713 VERIFICATION The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading aze true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ c t ~ c to Name: D c~ ~ S o ~ Title: ~ Q~ L-., CT Company: MTG Finance, LLC MJU 12051077 CASE 12051077-1 _ l n p ---title guaranty company SCHEDULE A (corltrnueB) Fi{e No. PA-tf7-24260 Commitment No. PA-07-24260 LEGAL DESCRiPT1UN ALL THAT CERTAIN Unit in the property known, named and itlentified in the Declaration referenced to below as '1lValnuk Villas Condominium" located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretafare been submitted pursuant to the provisions of the Pennsylvania Uniform Condominium Act, 68 PA.Cons. Stat.Ann. SS3101 et seq. (Purdort Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Voi. 308, page 147, which Dedaration of Condominium dated December 31, 1985, and recorded on December 31, 1985, in the aforesaid office at Miscellaneous Book 313, page 133, and further amended by a second Amendment to Declaration of Condominium dated March 23, 1987 antf recorded an March 27, 1987, in the aforesaid Offrce at Miscellaneous Book 331, page 833, and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Baok 335, page 283, being and designated in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment as Unit No. 833 as more fully described in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment together with a proportionate undivided interest in the Common Elements of such Condominium as set Earth in such Declaration as amended by the First Amendment and Second Amendment and Third Amendment and any further amendments thereto hereafter recorded in the aforesaid office. Being the same premises which Roy W. Driver and Alice M. Driver, husband and wife, by deed dated 8/12/1997 and recorded 8/13/'1997 in Cumberland County in deed book 162 and page 794, then granted and conveyed to Margarek K. Driver. ParceL• 1$-22-0519-01.-u-pi333 ALTA Commitment , Schedule A (oarstinuttd} i O C W E N V1 .~JC~\A'L:I~.CG~lV1 February 15, 2012 VIA First Clas Mail VIA Certified Mail (return receipt req ested) Certified Number: 71069017515152 59725 Reference Code 1108 Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055-0000 Loan Number: 6365084 Property Address: 833 Old Silver Spring Road ,Mechanicsburg, PA 17055-0000 NOTICE OF DEFAULT A SO MPORTA_NTR P RA pE SON S D . AB .A I P NA: Esta notificaci6n es de suma importancia. Puede afectaz su derecho a continuar viviendo en su casa. Si no entiende su contenido, btenga una traduccion inmediatamente o contactenos ya que tenemos representantes que hablan espaiiol y estan disponibles pars asistir. Deaz Borrower (s): $PEC Ai. NOTI N T F. .VENT YO i A i.F.D B N R PT Y If you have received a Chapter 7 discharge under the Bankruptcy Code of the United States or if your mortgage is the type which h s been discharged pursuant to a completed Chapter 13 plan, this notice is not intended and does not constitute an attempt to collect a debt gainst you personally..If the foregoing applies to you, this notice is sent to you only as a preliminary step to a foreclosure on your m rtgage against the above-referenced property. Provisions may be contained within your mortgage/deed of trust that require notice rior to foreclosure. As such, this is not an attempt to assert that you have any personal liability for this debt. In addition, if you have recently filed a petition under the BartlQUptcy Code, this notice has been sent to you because OCWEN as not been notified of your bankruptcy case. If the foregoing applies to you, it is IMPORTANT that you or your bankruptcy attorney co tact us immediately and provide us with the following information: date and jurisdiction of your filing, your, case number and the b ptcy chapter number under which you have filed. If you have not recently filed bankruptcy or received a bankruptcy discharge, you are hereby notified that this letter is an att mpt to collect a debt. All information obtained will be used for that purpose. The debt is owed to OCWEN as the owner or servicer f your home loan and mortgage. Unless you dispute the validity of the debt, or any portion thereof, within thirty (30} days after receipt of this letter, the debt il] be assumed to be valid by OCWEN. If you notify OCWEN in writing within thirty (30) days that the debt or a portion of the ebt is disputed, OCWEN will send you verification of the debt. If you would like such verification, please make your request in wriin to the Loan Resolution Consultant within thirty (30) days. The failure to dispute the validity of the debt may not be construed by any ourt as an admission of liability by you. Your mortgage payments are past due, which puts you in default of your loan agreement. As of February 15, 2012, you a the following: Principal and Interest $ 832.26 Interest Arreazage $ 0.00 Escrow $ 355.56 Late Charges $ 20.81 Insufficient Funds Charges $ 0.00 Fees /Expenses $ 17.58 Suspense Balance (CREDIT) $ 0.00 Interest Reserve Balance (CREDIT) $ 0.00 TOTAL DUE $ 1,176.21 DE DPAZS This communication is from a debt collector attempting to collect a debt; any information obtained will be used for hat purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt. Exhibit A NA•1I.S # 1851 O. O C W E N u'u'l\ .OC'Vl'EN.C'QM On or before March 15, 2012, you must submit payment by Money Crram, Bank Check, Money Order or Certified Funds forth entire total due amount stated above to the appropriate address listed at the bottom of page two of this notice. Any payment(s) that come due in the interim must also be included. ~ Failure to bring your account current may result in our election to exercise our right to foreclose on your property. Upon accel ation, your total obligation will be immediately due and payable without further demand. In foreclosure proceedings, we are entitled to collect your total azrearage in addition to any expenses of foreclosure, including but not limited to reasonable attorney's fees and costs. f your loan has already been accelerated and foreclosure proceedings already begun, we will continue the foreclosure action (if possibl You have the right to assert in court the non-existence of a default or any other defense to acceleration and foreclosure. OCWEN will work with bankruptcy lawyers, foreclosure defense lawyers, housing counselors, and other authorized representative of our customers. We will only release information once your written authorization is obtained, as required by law. After acceleration of the debt, but prior to foreclosure, you may have the right to reinstate the mortgage loan, depending on the t s of the note and mortgage. We encourage you to review the provisions of the note and mortgage. Please be aware that, after acceler ion of the debt, there may be expenses and attorney's fees and costs incurred by OCWEN to enforce the mortgage in addition to the erdue amount on the mortgage. Any payment to reinstate the mortgage loan after acceleration must therefore include an amount suffi Tent to cover such expenses and fees incurred. Payments received that aze less than the amount required to reinstate the mortgage loan 'll be returned and will not stop any foreclosure proceedings that have begun. PRIOR TO SUBMITTING PAYMENT, YOU MAY WISH TO CALL US TO VERIFY THE EXACT AMOUNT DUE. A HUD counseling agency may be able to provide you with assistance. To locate the HUD approved counseling agency in your ar a, call the HUD Housing Counseling Service at (800) 569-4287 or consult HUD's website at www.HUD.gov. If you are unable to bring your account current, I urge you to call us immediately to discuss possible alternatives to foreclosure. If you have the desire to remedy this situation we want to assist you in trying to reach that goal. OCWEN would. like to present y u with some of the alternatives that may be available regarding your delinquent mortgage loan. While our primary objective is the cone ion of past due amounts on your loan, we want to work with ,you to find the best available alternative for you to bring your mortga a loan obligation current. Sincerely, ADDRESS WR_iTTEN COR_RFSPONDENCE TO: Reseazch Department Ocwen Loan Servicing, LLC Ocwen Loan Servicing, LLC P.O. Box 24736 Toll Free Phone: 800-310-9229 West Palm Beach, FL 33416-4736 PAYMENT RF, iTT NCE INFO MATION (always include Losn # 6365084 with your Raymentl ooey Gram Overnight Address VIA Re~ilar Mail Receive Code: 2355 Ocwen Loan Servicing, LLC Ocwen Loan Servicing, LLC City: Orlando 1661 Worthington Road Suite 100 P.O. Box 6440 St: FL West Palm Beach, Florida 33409 Carol Stream, IL 60197-6440 Loan # 6365084 Attention: Cashiering Department DE DPA.25 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for hat purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt. NML # 1852 _ _ _ i . O . O C W E N V+'~'V4'.C~CVVEN.CGtiM Dear Customer, There is help available if you are having difficulty making your mortgage loan payments. You may be eligible for the Nome Affordable Modification program, part of the initiative announced by President Obama to help homeowners. As your mortgage loan servicer, we will work with you in an effort to try to make your mortgage payment affor able. You will not pay any fees to take advantage of this opportunity to modify your mortgage loan payment and kee your home. Now is the time to act. We are ready to help you. ~j~~ • We will first determine if you are eligible based on your situation • If you are eligible, we will look at your monthly income and housing costs, including any past due payments, an then determine an affordable mortgage payment • At first, you will make new, affordable monthly payments on your mortgage loan during a trial period • If you make those payments successfully and fulfill all trial period conditions, we will permanently modify your mortgag loan _~i , The modification may involve some or all of the following changes to your mortgage loan; • Bringing your account current; • Reducing the interest rate on your loan; • Extending the term of the loan, and/or • Delaying your repayment of a portion of the mortgage principal until the end of the loan term ~ ~ x.i??~ESS You can obtain the application via our website or if you do not have access to the web you can call us. • Download the application via the web at www.ocwencustomers.conz o Click on the President's Foreclosure Prevention Pian link o Once you confirm that you meet the requirements, you can download the package directly from the web • Call us for an application package at 1-800-74-OCWEN (1-800-746-2936) o Hours of Operation - ¦ ~ Monday to Friday 8:00 am to 9:00 pm ET ¦ Saturday 8:00 am to 5:00 pm ET ¦ Sunday 12:00 pm to 9:00 pm ET A complete application will be required and must also include a request for modification and affidavit form, a 4506T or 4506T- Z, and evidence of income. There may be other options available to you such as; o Ocwen's alternative modification programs o HAFA (Home Affordable Foreclosure Alternatives) program o Ocwen's Deed In Lieu of Foreclosure o Ocwen's Short Sale program - Selling your home and payoff your mortgage at an approved discounted payoff amount We want to make the resolution of your situation as easy as possible and helping homeowners is what we do! Sincerely, Ocwen Loan Servicing 1661 Worthington Rd. Ste. 100 West Palm Beach, FL 33409 DE DPA.ZS This communication is from a debt collector attempting to collect a debt; any information obtained will be used for hat purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt. NML # 185? _ _ .o O C W E N ~'u't~ .0i~'~'E?~.CG~M I ~"~lppnu eY~bIC##eireGlbS+~e'iC~nS FINANCIAL COUNSELING SERVICES When you are experiencing a financial hardship, counseling may be a way to help you manage your finances. We urge ou to contact HUD approved agencies to obtain assistance in keeping your home. This assistance is available at no char e. For specific guidance on this notice or information related to the Home Affordable Modification Program, ask the counse or for MHA HELP. HUD Approved Housing Counseling: 1-800-569-4287 «~~~~w.~IUD.~o~- HOPE Hotline Number: 1-888-995-4673 DE PA.25 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for hat purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt. NMLS # 1852 _ r _ _ FORM 1 _ i--: Ire THE. COURT OF COMMON PLEAS C~ ~ CUMBERLAND COUNTY. PENNSYLIA^~ Plaintiff(s)) ~ r' ~'S. N p~~V~~l Defendant(s) ~ ~ uJi~ivil ~ o t 2 NOTICE OF RESIDENTIAL MORTGAGE FORECL~L DIVERSION PROGRAM You have been served Gwith a foreclosure cornpiaint that could cause you to lose your home. 1f 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-super,~ised conciliation conference in an effort to resolve this matter with your lender. If you do not have a layer, you must take the following steps to be eligible for a conciliation conference. First, within twent<~ (20} days of youur receipt of this notice, you must contact MidPenn Legal Sen~ices at (7l 7) 24s-9400 extension 10 or (800) 822-5288 extension 2510 and request appoint~z~ent 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 represen#ative v<~ith 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 Conciliatio Conference with the Court.. which must be filed with the Court within sixt} (60) days of the service upon you o the foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an opportunit\~ 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 con€erence. 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 complet a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliatio Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you f the foreclosure complaint. if you do so a~~d 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 leader before the mortgage foreclosure suit proceeds forward. IF YOII WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s fitted: Date [signature of Counsel for Plaintiff] Katherine E. Knowlton, Esq PA ID 311713 i 4 FORM 2 Cumberland Coun y Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland Count~~ Court of Common Pleas Docket BORROWER REQUEST' FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider ti~our circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(sl: Property Address: Citti~: 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: State: Zip: Phone Numbers: Home: 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: ~ Priman~ 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: $ $ j Retirement Funds: $ $ l~ ' Lnvestments: $ $ ~ Checiting: $ $ Savings: $ $ Other: $ $ I .Automobile #1: A•Zodel: Year: ~ Arnount awed: Value: Automobile #2: Model: Year: ~ Arnount owed: Value: Other transportation (automobiles, boats, motorcvclesl: Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Additional Income Description (not wages): 1. monthly amount: ~ monthly amount: Borrower Pay Da~~s: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently payingl EXPENSE AMOUNT EXPENSE AMOUNT Mortsa e Food ' 2° Mort a ~e ~ Utilities j ~ CarPa~Rn.ent(s) Condo/Nei h. Fees Auto Insurance Med. (not covered) 'Auto fuel/re airs Other ro ayment ~ Install. Loan Payment Cable "I"V ~ Child Su art~Alim. S endin Money Dav/Child Care/Tuit. Other Ex erases I .Amount Available for Monthly Mortgage Payments Based on income & Expenses: I j Have you been working with a Housing Counseling Agenc}~? i i Yes ? No ? ~ If yes, please provide the following information: Counseling .Agency: Counselor: Phone (Office): Fax: _ Email. Hav: vet; made application for Homeo«me-rs Fmer~en~,~~ Mortgage Assistance Program (HEMAP) assistance? Y'es ? No If yes, please indicate the status of the application: Have you had any prior negotiations with your ].ender or lender's loan servicing company to resolve your delinquency? I Yes ? No ? If yes. please indicate the status of those negotiations: I! ~I I Please provide the follo~~~ing information, if know, regarding your lender or lender's loan ~ servicing company: - Lender's Contact (NTame): Phone: Servicing Company (Name): j Contact: Phone: ~ UWe, ,authorize the above named to use/refer this information to my lender~servicer for the sole purpose of evaluating my financial situation for possible mort~ase options. I/We ~ understand that I/we amJ'are under no obligation to use the services provided by the above ~ named. i Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof o€ incom-e _VI Past ?bank statements V Proof of any expected income for the last 4~ days r Copy of a current utiliri~ bill l Letter explaining reason for delinquency and any supporting documentation (hardship letter] ti~ Listing agreement (if properts~ is currently on the market) I _ - - I _ - _ 1 FORM 3 IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY. PENNSYI,`%AN1A 1 Plaintiffs} ' "lT G LLC vs. ~aro~ar*° p ~ ~ der . Defendant(s) C1V.I:L REQUEST FOK CONCILIATION CONFERENCE G Pursuant to the Administrative Order dated ~Q,b Z p , 2012 ~~overning the Cumberland Counn~ Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: ~ i . Defendant is the owner of the real property which is the Subject of this mortgage foreclosure action; ~ 2. Defendant lives in the subject real property, which is defendant's primary i residence: Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken al.l of the steps required in that Notice to be eligible. to participate in acourt-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I y I understand that false statements are made subject to the penalties of 18 Pa. C.S. X4904 relating tc unsworn falsification to authorities. i Signature of Defendant's CounseliAppointed Date Legg] Representative I~I I Signature of Defendant I1ate ~ Signature of Defendant Date I _ _ _ ~ ~ _ - I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 ~jJj~ ~U(; ~2 STUART WINNEG, ESQUIRE - ID#45362 ~(1: j LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ~r~~t~ERLA~dD Cat~NT SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 ~'~1~NSYLygNjA SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 BARRY B. REESE, ESQUIRE - ID#310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 AGNES MOMBRUN, ESQUIRE - ID#309356 ELANA B. FLEHINGER, ESQUIRE - ID#209197 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-3400 leadin$s(a~udren.com MTG Finance, LLC COURT OF COMMON PLEAS 6302 E. MLK Blvd., Suite 300, Tampa, FL CIVIL DIVISION 33619 CUMBERLAND County Plaintiff ~~~I MARGARET K. DRIVER NO. ~ a . ~ 3 833 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Kassia Fialkoff, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassail, Esquire; Agnes Mombrun, Esquire; Elana B. Flehinger, Esquire; Katherine E. Knowlton, Esquire; on behalf of the Plaintiff, in the above- captioned matter. UDREN LAW OFFICES, P.C. ~f BY: Katfierine E. Knowlton, Esq PA ID 311713 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 MTG Finance, LLC Plaintiff v. Margaret K. Driver Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION ~ _ Cumberland County ~~ ~ ^' ~;~i rv~ !MORTGAGE FORECLOSURE ~ r- ~ -<~' w r- --- ~ ~ i,. ~~ ~ NO. 12-5232-CIVIL ~ -- p ~ ~, ~ ~ c.~ c~ PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 86,442.93 Interest From 11/30/2012 $ 1,138.48 to Date of Sale April 11, 2013 . Ongoing Per Diem of $8.56 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. _- BY: w -~'rJ At rney for aintiff Katherine E. Knowlton, Esq PA ID 311713 MJU#: 12051077 CASE#: 12051077-1 ~~~.5~ a~ (JL~ 3 g , oo a~ ~~~ ~, ~, ~ b t. ~- ~ . ~o << <, ~, so ~ ~. ~s f8 ~ ~~ ~~a ,..: `~- ~., .~, -., ~~. err: S ~,~ ~~ ~a ~- ~,~# yon ~~ ~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, N3 08003-3620 856-669-5400 pleadin s a udren.com __ _`_ MTG Finance, LLC ~ COURT OF COMMON PLEAS Plaintiff ~ CIVIL DIVISION v. ~~ Cumberland County Margaret K. Driver ~, MORTGAGE FORECLOSURE Defendant(s) NO. 12-5232-CIVIL CERTIFICATE OF ACT 91 ~:-~ c°s ~ - ~ r'S 1 f"t"1 ~ , c°° -t ~' °:~ w ` ; . r- ~~' z~ .~--~z ~+ ~' ~ Q -< °" :- I hereby state that as the attorney for the Plaintiff in the above-captioned matter: Act 91 procedures have been fulfilled Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4944 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: ~_. Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 r::a UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a,udren.com __ __ _ MTG Finance, LLC Plaintiff ~~~ v. Margaret K. Driver ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Defendant(s) ,~ MORTGAGE FORECLOSURE NO. 12-5232-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 f,:'~°+ _ C~ ...-t ~~ ~~ ' ~`} u~ r ~ L~ ~ ~ te w ~ r -- ~ ~~ ~ c~a ~ ~ i== c- v -: ---+ ;~: ~, ---~ .,~ ~ MTG Finance, LLC, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 833 Old Silver Spring Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Borough of Mechanicsburg Address to Follow Walnut Villas Condominium Association Address to Follow 4. Name and address of the last recorded holder of every mortgage of record: MTG Finance, LLC 7500 Old Georgetown Road Suite 1300 Bethesda, MD 20814 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 833 Old Silver Spring Road Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Federal Tax Lien Holders -None Walnut Villas Condominium Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. ~~ . ~/%'i BY: %~ -- ~- Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 MJU#: 12051077 CASE#: 12051077-1 UDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF .. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-bb9-5400 pleadingsnu,udren.com _ _ _ MTG Finance, LLC ~ COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION ~. ''i Cumberland County MARGARET K. DRIVER Defendant(s) MORTGAGE FORECLOSURE NO. 12-5232-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 ~°' r+ c~ C-7 . i r, r- s ~ r ~, ~~~" t i w .....~ r-,°a Jiyr ~ +' ~~ -"`S ~ --t ~. Your house (real estate) at 833 Old Silver Spring Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on April 11, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $86,442.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To fmd out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may ca11856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-5232 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MTG FINANCE, LLC Plaintiff (s) From MARGARET K. DRIVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $86,442.93 L.L.:.50 Interest FROM 11/30/2012 TO DATE OF SALE MARCH 6, 2013 -Ongoing Per Diem of $8.56 to actual date of sale including if sale is held at a later date - ~ ~ . ~ 3><y~ Atty's Comm: Due Prothy: $2.25 Atty Paid: $189.25 Other Costs: Plaintiff Paid: Date: 12/3/l 2 1)rl 1.i ~ 1J ~,lr? David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: ICATIIERINE E. I{NOWLTON, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 311713 SHERIFF'S OFFICE OF CUMBERLAND COUNTY M. C= Ronny R Anderson Sheriff -< ---iCD �ti.0Ip rilD CCU 3- x'7`4 Jody S Smith p n ..M. 'IlkChief Deputy c�) v ; Richard W Stewart ` ' ` Solicitor OFFICE OF THE 84ERIFF -< W -� MTG Finance, LLC vs. Case Number Margaret K. Driver 2012-5232 SHERIFF'S RETURN OF SERVICE 01/03/2013 06:17 PM - Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 833 Old Silver Spring Road, Mechanicsburg, PA 17055, Cumberland County. 01/17/2013 07:25 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Margaret K. Driver at 833 Old Silver Spring Road, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 03/04/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 04/01/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/1/2013 04/01/2013 Property sale removed from 5/1/2013 sale. 04/01/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/10/2013 07/03/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,281.95 SO ANSWERS, 6z July 03, 2013 RONtV R ANDERSON, SHERIFF s. 5-6 ,k,o I 9 ,�,�-yagz (C)CountySuite Sheriff,Teleosoft,Irc. On December 11, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 833 Old Silver Spring Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 11, 2012 By: Real Estate Coordinator .i: d WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-5232 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MTG FINANCE,LLC Plaintiff(s) From MARGARET K. DRIVER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $86,442.93 L.L.: .50 Interest FROM 11/30/2012 TO DATE OF SALE MARCH 6,2013-Ongoing Per Diem of$8.56 to actual date of sale including if sale is held at a later date 5), Atty's Comm: Due Prothy:$2.25 Atty Paid: $189.25 Other Costs: Plaintiff Paid: Date: 12/3/12 David D. Buell,Prothonotary (Seal) � Deputy REQUESTING PARTY: Name: KATHERINE E.KNOWLTON,ESQUIRE Address: UDREN LAW OFFICES,P.C. 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 ®i IRE,(.- ,= hand RD Attorney for: PLAINTIFF TRUE �� here unto set my In Testir::on - d C R Carlisle,Pa./� Telephone: 856-669-5400 20 end theme of�- ="'- h notary Supreme Court ID No.311713 This �-�'Qy r'rct. CUMBERLAND LAW JOURNAL Writ No. 2012-5232 Civil and Third Amendment and any fur- ther amendments thereto hereafter MTG Finance,LLC recorded in the aforesaid office. Being the same premises which vs. Roy W. Driver and Alice M. Driver, Margaret K. Driver husband and wife, by deed dated Atty.: Mark Udren 8/12/1997 and recorded 8/13/1997 ALL THAT CERTAIN Unit in the in Cumberland County in deed book property known named and identified 162 and page 794,then granted and in the Declaration referenced to below conveyed to Margaret K. Driver. as "Walnut Vilias Condominium" Parcel: 18-22-0519-001-up833. located in the Borough of Mechan- BEING KNOWN AS: 833 OLD icsburg, County of Cumberland, SILVER SPRING ROAD, MECHAN- Commonwealth of Pennsylvania. ICSBURG,PA 17055. which has heretofore been submit- PROPERTY ID NO.: 18-22-0519- ted pursuant to the provisions of the 001-UP833. Pennsylvania Uniform Condominium TITLE TO SAID PREMISES IS Act,68 PA,Cons.Stat.Ann,SS83101 VESTED IN MARGARET K. DRIVER et seq. (Purdon Supp 1987), by the BY DEED FROM ROY W. DRIVER recording in the Office of the Recorder AND ALICE M. DRIVER, HUSBAND of Deeds of Cumberland County, AND WIFE DATED 08/12/1997 Pennsylvania, of a Declaration of RECORDED 08/13/1997 IN DEED Condominium dated July 30, 1985, BOOK 162 PAGE 794. and recorded on August 14, 1985,in Miscellaneous Book Vol. 308, page 147,which Declaration of Condomin- ium dated December 31,1985, and recorded on December 31, 1985, in the aforesaid office at Miscellaneous Book 313, page 133, and further amended by a second Amendment to Declaration of Condominium dated March 23, 1987 and recorded on March 27,1987, in the aforesaid Office at Miscellaneous Book 331, page 933,and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Book 335, page 283, being and designated in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment as Unit No.833 as more fully described in such Declaration as amended by such First Amend- ment and Second Amendment and Third Amendment together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as amended by the First Amendment and Second Amendment 43 i PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ('/Xisa Marie Coy?", Editor SWORN TO AND SUBSCRIBED before me this da of February, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 *f The Patriot-News Co. 2020 Technology Pkwy the atr1*otwXews Suite 300 Mechanicsburg, PA 17050 NOW you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication' Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M",Volume 14, Page 317. 2012-5232 Civil iaS , MTG Finance,LLC yoaq This ad ran on the date(s)shown below: I,Zoi 01/22/13 Margaret K.Driver )9Z,( Atty Mark Udren cL ys a^s 01/29/13 ALL THAT CERTAIN Unit in the DIPS property known named and identified in uoisi 02/05/13 the Declaration referenced to below as;o r "Walnut Vilias Condominium" located in IN the Borough of Mechanicsburg, County t; of Cumberland, Commonwealth of ni Pennsylvania. which has heretofore been in- submitted pursuant to the provisions of 21 the Pennsylvania Uniform Condominium ,,, Sworn to and subscribed before me this 14 day of February, 2013 A.D. Act, 68 PA,Cons. Stat.Ann, SS83101 et ; seq.(Pardon Supp'1987),by the recording 1 in the Office of the Recorder of Deeds of ,1 Ah2ixa_ Cumberland County, Pennsylvania, of a f N tary Public Declaration of Condominium dated July I, 30,1985,and recorded on August 14,1985, i ! in Miscellaneous Book Vol. 308, page 147, which Declaration of Condominium r COMMONWEALTH OF PENNSYLVANIA f dated December 31,1985,and recorded on li December 31,1985,in the aforesaid office Notarial Seal t at Miscellaneous Book 313,page 133,and Holly Lynn Warfel,Notary Public 'I further amended by a second Amendment Washington Twp.,Dauphin County to Declaration of Condominium dated My commission Expires Dec.12,2016 March 23, 1987 and recorded on March MEMBER,PENNSYLVANIA ASSOaAnoN of NOTARIES 27,1987, in the afQlpsai¢ .Mice at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominium dated June 12,1987 and recorded on June 12,1987 in UDyREN LAW QFICES, P.C.. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE.•200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s ,udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Margaret K. Driver Defendant(s) MORTGAGE FORECLOSURE NO. 12-5232-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 MTG Finance,LLC,Plaintiff in the above action,by its undersigned attorney,upon information and belief, . Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 833 Old Silver Spring Road, Mechanicsburg, PA 17055 1.Name and address of Owner(s) or reputed Owner(s): Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 2.Name and address of Defendant(s) in the judgment: Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Borough of Mechanicsburg Address to Follow Walnut Villas Condominium Association Address to Follow 4. Name and address of the last recorded holder of every mortgage of record: MTG Finance,LLC 7500 Old Georgetown Road Suite 1300 Bethesda,MD 20814 Sr Mortgage Holders -None Jr Mortgage Holders-None _.__- 5. Name and address of every other person who has any record lien on the property: Sr lien Holders None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 833 Old Silver Spring Road Mechanicsburg,PA 17055 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Walnut Villas Condominium Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 - relating-to unsworn falsification to authorities. - DATED: UDREN LAW OFFICES,P.C. BY: Attorney for Plaintiff Katherine E. Knowlton, Esq PAID 311713 MJU#: 12051077 CASE#: 12051077-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s@udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County MARGARET K. DRIVER MORTGAGE FORECLOSURE Defendant(s) NO. 12-5232-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 Your house (real estate) at 833 Old Silver Spring Road,Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$86,442.93, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400, 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ALL THAT CERTAIN Unft in the property known, named and identified in the Declaration referenced to below as "Walnut Villas Condominium" located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Cnm m ,.sons. Stat.Ann, SS3iOl et seq. (Purdon Rupp. 1987), by the odoiniu Act, 68 PA.G I p recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Dectaratior of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, page 147, which Declaration of Condominium dated December 31, 10.85, and recorded an December 131, 19845, in the aforesaid office at Miscellaneous Book 313, page 133, and further amended by a second Amendment to Declaration of Condominium dated March 23, 1987 and recordad on March 27, 1987, in the aforesaid CAftce at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominlum dated ,tune'12, 1987 and recorded an June 12, 1987 in the aforesaid office at Miscellaneous Book 3 33115, page 283, being and designated in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment as Unit No. 833 as more fully described in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as amended by the First Amendment and Second Amendment and Third Amendment and any further amendments thereto hereafter recorded in the aforesaid office. Being the same premises which Roy W. Driver and Alice M. Driver, husband and wife, by deed -dated 8/3211997 and recorded 8/13/1991 in Cumberland County in deed book 162 and page 794, then granted and conveyed to Margaret K. Driver. Parcel- 18-22-0519-01..-u-p833 BEING KNOXNN AS: 833 OLD SILVER SPRING ROAD,MECHANICSBURG,PA 17055 PROPERTY ID NO.: 18-22-0519-001-UP833 TITLE TO SAID PREMISES IS VESTED IN MARGARET K. DRIVER BY DEED FROM ROY W. DRIVER AND ALICE M.DRIVER, HUSBAND AND WIFE DATED 08/12/1997 RECORDED 08/13/1997 IN DEED BOOK 162 PAGE 794. i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadinas@udren.com MTG Finance, LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Margaret K.Driver MORTGAGE FORECLOSURE Defendant(s) NO. 12-5232-CIVIL PRAECIPE TO ISSUE WRIT OF EXECUTION ` TO THE PROTHONOTARY: -<3> G° --' Issue Writ of Execution in the above matter: ri c� = :�n-Cr Amount due $ 86,442.93 " Interest From 11/30/2012 $ 3,167.20 to Date of Sale December 4,2013 Ongoing Per Diem of$8.56 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES,P.C. p 3C> . '1�—:' _ BY: Attorne or aintif 50 Nicole LaBlem, Esquire MJU#: 12051077 CASE#: 12051077_1 PA ID 202194 14 q'70AO A.;57 /e Cw' ,-3974' n'g IX�ri o� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2012-5232 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MTG Finance,LLC Plaintiff(s) From Margaret K.Driver (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $86,442.93 L.L.: Interest From 11/30/2012 to Date of Sale December 4,2013-Ongoing Per Diem of$8.56 to actual date of sale including if sale is held at a later date-$3,167.20 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,4,91,0 Other Costs: Plaintiff Paid: Date: 8/8/2013 • David D.&Bull, rothonotary (Seal) Deputy REQUESTING PARTY: Name:Nicole LaBletta,Esquire Address: Udren Law.Offices,P.C. Woodcrest Corporate Center 111 Woodcrest Road,Suite 200 Cherry Hill,NJ 08003-3620 Attorney for: Plaintiff Telephone: 856-669-5400 Supreme Court ID No.202194 i Order Dismissing(Form ordsmiss)(01113) UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA in re: Debtor(s)(name(s)used by the debtor(s)in the last 8 years,including married,maiden,and trade): Margaret K. Driver Chapter 13 aka Margaret Kay Driver Debtor(s) Case No. 1:13—bk-01103—RNO Order Upon consideration of the Motion to dismiss case and it having been determined after notice and opportunity for hearing,that the case should be dismissed,it is ORDERED that the above—named case of the debtor(s)be and is hereby dismissed. Dated: July 5,2013 By the Court, 9'A , Honorable Robert N.Opel United States Bankruptcy Judge Case 1:13-bk-01103-RNO Doc 24 Filed 07/05/13 Entered 07/05113 09:53:48 Desc Order Dismissing Page 1 of 1 Notice Recipients District/Of£0314-1 User:BComiskey Date Created:7/5/2013 Case: l:13—bk-0l 103—RNO Form ID:ordsmiss Total: 17 Recipients submitted to the BNC(Bankruptcy Noticing Center)without an address: cr Walnut Villas Condominium Association cr Bayview Loan Servicing,LLC,a Delaware Limited Liabiltiy Company cr Bayview Loan Servicing,LLC TOTAL:3 Recipients of Notice of Electronic Filing: ust United States Trustee ustpregion03.ha.ecf @usdoj.gov tr Charles J.DeHart,III(Trustee) dehartstaff @pamdl3trustee.com aty Gregory Javardian greg.javardian @pkjllc.com aty Stephen J Dzuranin szuranin @wwwpalaw.com aty Steven P.Miner sminer @dzmmglaw.com TOTAL:5 Recipients submitted to the BNC(Bankruptcy Noticing Center): db Margaret K.Driver 833 Old Silver Spring Road Mechanicsburg,PA 17055 4303811 Bayview Loan Servicing,LLC 4425 Ponce De Leon Boulevard,5th Floor Coral Gables,FL 33146 4272171 CUMBERLAND COUNTY TAX CLAIM ONE COURTHOUSE SQUARE CARLISLE,PA 17013 4272172 MTG FINANCE LLC C/O QUANTUM SERVICING 6302 E.MLK BLVD STE 300 TAMPA,FL 33619 4272173 PINNACLE HEALTH PO BOX 2353 HARRISBURG,PA 17105 4272174 PP 827 HAUSMAN ROAD ALLENTOWN,PA 18104-9395 4272175 PROPERTY MANAGEMENT INC PO BOX 622 LEMOYNE,PA 17043 4272176 UDREN LAW OFFICES WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 4276149 Walnut Villas Condominium Association c/o Stephen J.Dzuranin,Esq. Wix,Wenger&Weidner PO Box 845 Harrisburg,PA 17108-0845 TOTAL:9 Case 1:13-bk-01103-RNO Doc 24-1 Filed 07/05/13 Entered 07/05/13 09:53:48 Desc Order Dismissing: Notice Recipients Page 1 of 1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings* ,udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Margaret K.Driver MORTGAGE FORECLOSUR]g �10 co Defendant(s) 3_ a NO. 12-5232-CIVIL C� CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: EK Act 91 procedures have been fulfilled Fj Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES,.P.C. BY: Attorne for Plaintiff Nicole l aBlefa Esquire 11AA ID 202194 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadinp,skudren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Margaret K.Driver Defendant(s) MORTGAGE FORECLOSURE NO. 12-5232-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 MTG Finance,LLC,Plaintiff in the above action,by its undersigned attorney,upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at: 833 Old Silver Spring Road,Mechanicsburg,PA 17055 1.Name and address of Owner(s) or reputed Owner(s): Margaret K.Driver 833 Old Silver Spring Road CO CD Mechanicsburg,PA 17055 CD C--) 2.Name and address of Defendant(s) in the judgment: co Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg,PA 17055 3.Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Walnut Villas Condominium Association Address to Follow Borough of Mechanicsburg Address to Follow 4.Name and address of the last recorded holder of every mortgage of record: MTG Finance, LLC 4425 Ponce DeLeon Blvd,5th Floor Coral Gables, Fl,33146 Sr Mortgage Holders-None Jr Mortgage Holders -None 5.Name and address of every other person who has any record lien on the property: Sr lien Holders-None :rf 7 6.Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle,PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 833 Old Silver Spring Road Mechanicsburg, PA 17055 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Walnut Villas Condominium Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. BY: c�� Attorney for Plaintif MJU#: 12051077 CASE#: 12051077-1 Nicole LaBlefla, Esquire 11A IDS 292194 A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200. CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County MARGARET K.DRIVER MORTGAGE FORECLOSURE Defendants) NO. 12-5232-CIVIL '-`' `rte 1� a --•-i C�: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY r TO: Margaret K. Driver 833 Old Silver Spring Road Mechanicsburg, PA 17055 Your house (real estate) at 833 Old Silver Spring Road,Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on December 4,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$86,442.93, obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call:(856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 'r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 f ALL THAT CERTAIN Unit in the property known, named and identified in the Declaration referenced to below as 'Walnut Villas Condominium" located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Condominium Act, 68 PA.Cons. Sta.t.Ann. SS3101 et seq. (Purdon Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated duly 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, page 147, which Declaration of Condominium dated December 31, 1885, and recorded on December 31, 1985, in the aforesaid office at Miscellaneous Book 313, page 133, and further amended by a second Amendment to Declaration of Condominium dated March 23. 1987 and recorded on March 27, 1987, in the aforesaid Office at Miscellaneous Book 331, page 933, and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on .tune 12, 1987 in the aforesaid office at Miscellaneous Book. 335, page 283, being and designated in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment as Unit No. 833 as more fully described in such Declaration, as amended by such First Amendment and Second Amendment and Third Amendment together with a proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as amended by the First Amendment and Second Amendment and Third Amendment and any further amendments thereto hereafter recorded in the aforesaid office. Being the same premises which Roy W. Driver and Alice M. Driver, husband and wife, by deed dated 8/1211997 and recorded 8113/1997 in Cumberland County in deed book 162 and page 794,then granted and conveyed to Margaret K. Driver. Parcel: 18-22-0519-01.-u-p 833 BEING KNOWN AS: 833 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 PROPERTY ID NO.: 18-22-0519-001-UP833 TITLE TO SAID PREMISES IS VESTED IN MARGARET K.DRIVER BY DEED FROM ROY W. DRIVER AND ALICE M. DRIVER, HUSBAND AND WIFE DATED 08/12/1997 RECORDED 08/13/1997 IN DEED BOOK 162 PAGE 794 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance,LLC COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. .. MARGARET K. DRIVER; et al NO. 12-5232-CIVIL Defendant(s) _rn -r 7? _3 PRAECIPE TO FILE PROOF OF SERVICE �<% TO THE PROTHONOTARY: Z Q Kindly file the attached Proofs of Service with regard to the captioned matter. Date: I p_ e 13 UDREN LAW OFFICES,P.C. BY: � torney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 Service of Process by MTV Finance,LLC,et.al.,Plaintiff(s) /�' —''`, APS International, Ltd. vs. ` Margaret K.Driver,et.al.,Defendant(s) 1 1-800-328-7171 IN 1 ERN AT/OVAL APS international Plaza 7800 Glenroy Road "+",` Minneapolis,MN 55439-3122 APS File#: 125375-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES —Margaret K.Driver Ms.Henni Crommarty Court Case No.Cumberland Co 12-5232-CIVIL 111 Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 Customer File: N12051077-1 State of. 1A . 1 �.$i ss. County of:C d t�CC ) Name of Server: ,5 k is ch i ,undersigned,being duly sworn,deposes and says that at all times mentioned lterein,s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Margaret K. Driver and after due and diligent efforts,was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/rime/Address Attempted: 833 Old Silver Spring Road,Mechanicsburg,PA 17055 Reason for Non-Service:. A(� 9 / .ôfI 3 l 2: Yi Po► SP64 c wI R CC.S I �tA of Datcs/Timc/Address Attempted: / ^ Reason for Non-Service:, O ib t r S rY%+C S �� "rC G el. I' 1J_C er _h`4 c� fi .54x'0 Dates/Time/Add ress Attempted: `'r, I S ✓1 D i' C v ors, I l ' 1 t'VJ('t ss 1`' 7�^1 f G J d re fr Reason for Non-Service:, .SPeak t writ i1 t.s S Ce r Gl o re J!ore_ii'• p,7 S i__ Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subs --d and • to before me thi / that a foregoing is true and correc Mt; . of S, , Irr iu L, ,2, A/ ii Signature of Server Or P . ���� — g (Commi o Expires) APS International,Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Bon:),Cumberland County My Commission Expires July 9,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance,LLC COURT OF COMMON PLEAS F , Plaintiff CIVIL DIVISION `? CUMBERLAND County V. ti -t 1CF; Margaret K. Driver 17,1'� , NO. 12-5232-CIVIL -< . -T Defendant(s) y C, p - . MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant(s): MARGARET K. DRIVER, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: MARGARET K. DRIVER 833 OLD SILVER SPRING ROAD MECHANICSBURG, PA 17055 A copy of the Return of Service is attached hereto as Exhibit"A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit`B". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit"C". 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph 1,by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: -" �XQ/ Attorneys or Plaintiff Nicole LaBlefta, Esquire PAID 202194 • Service of Process by MTr Finance,LLC,et.al.,Plaintiff(s) f''—'�"• APS International, Ltd. VS. Margaret K.Driver,et.al.,Defendanl(s) 1-800-328-7171 IN 1:12tiAT1t>N1t APS International Plaza - 7800 Clenroy Road Minneapolis,MN 55439-3122 APS File#: 125375-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES —Margaret K.Driver Ms.Henri Crommariv Court Case No.Cumberland Co 12-5232-CIVIL 111 Woodcresl Rd.,Ste.200 Cherry Hill,NJ 08003-3620 Customer File: N12051077-1 State of. tt� ..110 I .. ss. County of:C - 1004 k) Name of Server: c1- 5/lt~K/�� , undersigned,being duly sworn,deposes and says that at all times mentioned bferein,s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriffs Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Margaret K. Driver and after due and diligent efforts,was unable to effect service. Attempts: The following is a list of the attempts made to effect service: patesffimdAddress Attempted: 833 Old Silver Spring Road,Mechanicsburg,PA 17055 Reason for Non-Service: / �-• f ` (� Oat esPrime/AddresAttempted. 7 / /1- I7-. �Q P J f66L c w I- /1 e c , cJ Qn p2s Reason for Non-Service: 0 ID •�1 (�' . eV^S S IM r5 4r( b O r r 4A G ..54-roile Datesrnme/AddressAttempted: �''� /I S 1�0 C-u„c" J S 1 L )(IJ +41, G J4 fr rf� Reason for Non-Service: SPede{ +-•.* t all r3 s c.o.e D o 1i.;a" }`f yI 616,11— k 2 Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subs d and • to before me th that a foregoing is true and correc _- /a1f Si ,2 E/ Signature of Server .•el P •�W��� (Commi oor-Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M.Michelle Guyton,Notary Public Carlisle Boro,Cumberland County My Commission Expires Illy 9,2016 MEMBER,Pf$NSYLVANtA ASSOQATIOtt OF NOTARIES EXHIBIT A • Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiff(s) MTG Finance, LLC, et al. vs Defendant(s) Margaret K. Drive AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I, Randy Sheppard II, do hereby swear and affirm that I made the following diligent search and inquiry on defendant, Margaret K. Drive: 1. On October o3, 2013, I conducted a Skip Trace,the results of which indicated the defendants current residence is 833 Old Silver Spring Road, Mechanicsburg, PA, 17055. 2. On October o3, 2013, I conducted an Internet search for the Death Records of the Defendant,the results of which indicated that the defendant is not deceased. 3. On October 03, 2013, I conducted an Internet search for the Voter Registration Records of the Defendant,the results of which indicated that the defendant is a registered voter at the address of 833 Old Silver Spring Road, Mechanicsburg, PA, 17055. 4. On October o3, 2013, I conducted an Internet search for the Motor Vehicle Records of the Defendant,with no results obtained from the search. 5. On October 03, 2013, I conducted an Internet search of Facebook,Twitter, Yahoo!,Google and Bing with no results obtained from the search. 6. On October 03, 2013 at 6:o8pm I placed a phone call to defendant's neighbor, Jason Bono(717-697-7618), of 829 Old Silver Spring Road, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. The number was not in service. 7. On October 03, 2013 at 6:09pm I placed a phone call to defendant's neighbor, Brandy Cole (717-766-3507), of 827 Old Silver Spring Road, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. There was no answer. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge,information, and belief. 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. 10/03/2013 /Awl" Date Randy Sheppard II Skip Trace Manager De Novo Attorney Services,Inc. P.O. Box 20215 Baltimore,MD 21284 Our Job Serial Number: NOV-2013006627 Ref: 12051077-1 EXHIBIT B Udren Law Offices, PC. Woodcrest Corporate Center 111 Woodcrest Road Cherry Hill, New Jersey 08003 TO:POST''ASTER DATE: October 9,2013 Mechanicsburg,PA,17055 CASE No.: 12051077-1 Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special note that this request deals with a matter pending in Court and,therefore,any information available would be greatly appreciated,even if any existing forwarding order has expired. NAME: Margaret K.Driver LAST KNOWN ADDRESS: 833 Old Silver Spring Road,Mechanicsburg,PA 17055 NOTE: The name and last known address are required for change of address information. The name, if known,and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1) and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester. Attorney at Law 2. Statute/regulation that empowers me to serve process(not required if requester is an attorney) 3. The names of known parties to the litigation:(FIS for Bayview Loan Servicing) vs.NAME:Margaret K.Driver: 4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania 5. The docket or other identifying number if one has been issued: 12-5232-CIVIL -,. 6. The capacity in which this individual is to be served(defendant,witness): Defendant(s) 4 WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAINAND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN TIC SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THANFIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices,PC. W. .crest Corporate Center , Woodcrest Road Hill,New ,.. +,f 3 BY: I A l !/ _di! // ,�/,I. ************************************************ ***********+k*******4'***************** POST OFFICE USE ONLY NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS Not known at address given _No such number AFFIX POSTMARK HERE _Left no forwarding No change of address on file No such street 1-GOOD AS ADDRESSED w -o lisps 4y°. EXHIBIT C UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Margaret K. Driver NO. 12-5232-CIVIL Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of"not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A", the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit"C". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. P BY: `' \A,V\� Attorneys for Plaintiff NcoIe L Esquire PA ID 202194 VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C. S . Sec 4904 relating to unsworn falsification to authorities . Date : ' \ d ) 11) UDREN LAW OFFICES, P .C . BY: Attorne s for Plaintiff Nco1e Iea' EsqU1'e L pMD 202194 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance, LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County v. Margaret K. Driver NO. 12-5232-CIVIL Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 23RD day of October, 2013. Udren Law Offices, P.C. Attorney for Plaintiff By: °C1 vA 1 ! ode La \ a, ire PA 1 2294 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP. No. Docket Number: 12-5232-CIVIL NAME: MARGARET K. DRIVER MAILING ADDRESS: 833 OLD SILVER SPRING ROAD MECHANICSBURG,PA 17055 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance,LLC COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. MARGARET K. DRIVER; et al NO. 12-5232-CIVIL Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: UDREN LAW OFFICES,P.C. c i BY: I / �. I' Attorney or Plaintiff Nicole LaBlefta, Esquire Fez !D 202194 o _o czr f-17 51 -c -.` CA) >r .' ` . - Service of Process by if MTG finance,LLC,et.al.,Plaintiffs) /',,,V ACT��. APS International, Ltd. vs. ^►• �� \ Margaret K.Drive.et.al.,Defendants) r "� _\l �� 1-800-328-7171 APS t.iERN.%TtONtL APS International Plaza 7800 Glenroy Rd. Minneapolis,MN 55439-3122 AI'S File#: 126344-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: Drive --Margaret K. posting UDREN LAW OFFICES g Drive,b Y P g Ms.1lenni Crommarty Court Case No.Cumberland Co 12-5232-Civil 1 I 1 Woodcrest Rd..Ste.200 Cherry Hill.NJ 08003-3620 State of:�Lr .. \J �1 a ss — — — _ County of: y__►dk A- 0 1I -` Name of Server: • I is 1Q l' 1'e._ Cl 4-01( , undersigned. being duly sworn,deposes and says that at the time of service, s/he was of legal age and was not a party to this action: Date/Time of Service: that on the I t� day of IK\D l!"" ( ,20 1.3._. at ` `3clo'clock P M Place of Service: at 833 Old Silver Spring Road _ . in Mechanicsbur PA 17055 Documents Served: the undersigned served the documents described as: Order of Notice and Limited Assistance Representation Information Sheet Cover Letter Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Margaret K. Drive, by posting Person Served,and — — -- — -- Method of Service: By personally delivering them into the hands of the person to be served. '(By delivering them into the hands of GAS\-t (1c ,a person of suitable age. who verified,or who upon questioning stated-drat he/she resides with Margaret K. Drive,by posting at the place of service,and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ; Skin Color ; 1-lair Color : Facial Hair Approx. Age : Approx. Height : Approx. Weight To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Un. .lb ed •- es under penalty of perjury Subscribed and s% •rn to before me this tali. the fir going s true and correct. / / 11-1A1 day •f 4 i T gat1 V p ,20 0. / % i i7 Signature of Server Public (Commission Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal • Tammie L Peters,Notary Public Carlisle Boro,Cumberland County My Commission Expires Sept.9,2015 MEMBER,PFNNSYLVANT4 F,? . I tON OF A1OTAT1ES UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 I leadin•s • udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County MARGARET K.DRIVER, MORTGAGE FORECLOSURE --+ Defendant(s) -try rn c rrs NO. 12-5232-CIVIL x 70 cam-) -t7c r- ra a. AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 r ; E C7 "�► cp y,C, °_ Plaintiff,by its/his/her Attorney hereby verifies that: xc::, c;. , 1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached herets cr. Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt,which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit"B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec.4904 relating to unsworn falsification to authorities. Dated: 1 a J 7 '/ 3 UDREN LAW OFFICES, P.C. BY: 2 L � cte Attorne s or P am i f Nicole LaBIea, d PAID 202194 • MJU#: 12051077 CASE#: 12051077-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 finance, COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County MARGARET K.DRIVER; Defendant(s) MORTGAGE FORECLOSURE NO. 12-5232-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): MARGARET K. DRIVER; PROPERTY: 833 Old Silver Spring Road,Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/04/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 12051077 CASE#: 12051077-1 ib .. 0— ,,,9 n ,.., ,--\---- r I rn r r ■ H� I r� r� r o v 1 1 1 o V 1 ■ r o N a E \ i 1 i \ 1 w� r��C? 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ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s ' udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CUMBERLAND County MARGARET K.DRIVER, MORTGAGE FORECLOSURE Defendant(s) NO. 12-5232-CIVIL VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: MARGARET K. DRIVER 833 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 DATE MAILED: November 13,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Dated: December 1(0 ,2013 UDREN LAW OFFICES,P.C. BY. , Attorn r Plaints MJU#: 12051077 CASE#: 12051077-1 Nicole LaBlefta, Esquire PAID 202194 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION MTG Finance,LLC Plaintiff v. Margaret K.Driver NO. 12-5232-CIVIL Defendant(s) ����' ORDER AND NOW,this/ day of 0 G���J"'`,2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Margaret K.Driver,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at 833 OLD SILVER SPRING ROAD MECHANICSBURG,PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MARGARET K.DRIVER 833 OLD SILVER SPRING ROAD MECHANICSBURG,PA 17055 BY T MIT- J. 1:) ■ w ti.. ZC.7 m Cam', --4 - r.. LF.2741,13 ft f"" -{ r) 7 . . . F . 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A 2 R 00,0 I i r- I 11111 4.- • U.S.POSTAGE>>PITNEY BOWES ° tie Id$ : _ ZIP 08003 $ 001. 0 0 P g g If 02 1YY '�° E EF ki 0• 04 r40. - - 0001387090 NOV 13,' Y g c � o ioB 4 cf.,. E E slit �f �� � s• s °0t 0 a�g � og gyp' S b P p�p v A A. F(Y �( iryi O o g- . 2 1 .B n,s" W ; ?ail� . to IA Tit '-"-4118i1J kd rik14dE LI,11 • r UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 MTG Finance,LLC COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. MARGARET K.DRIVER; et al NO. 12-5232-CIVIL Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: f ■ J 1 1 ✓ UDREN LAW OFFICES,P.C. c i BY: " ._1 , - (14-. Attorney or Plaintiff Nicole LaBlefta, Esquire PA PAID 202194 1 Li ti4,/(1"katt tiP 1 _ Service of Process by MTG Finance,LLC,et.al.,Plaintiff(s) �l 1 APS International, Ltd. vs. /-w •C7.� Margaret K.Drive.et.al.,Defendant(s) ` , 4 — 1'\` 1-800-328-7171 AI's INTtiRNAIIONAL 1 M'S International Plaza . ` 7800 Glenroy Rd. i Minneapolis,MN 55439-3122 APS File N: 126344-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Margaret K.Drive,by posting LAW OFFICES g y p g Court Case No.Cumberland Co 12-5232-Civil Ms.Henni Crommarty I1 I Woodcrest Rd..Ste.200 Cherry Hill.NJ 08003-3620 State of: '�lr1S (\i ' a- ,`s County of: tt Name of Server: • I et,\€ al 40,„ , , undersigned, being duly sworn,deposes and says that at the time of service, s/he was of legal age and was not a party to this action: Date/Time of Service: that on the I day of k\o hOr .20 a.at a t 3to'clock P M Place of Service: at 833 Old Silver Spring Road . ill Alecbarricsbur PA 17055 _ ,.,_ Documents Served: the undersigned served the documents described as: Order of Notice and Limited Assistance Representation Information Sheet Cover Letter Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Margaret K. Drive, by posting Person Served,and _ - "-'- -° -- —-- Method of Service: . By personally delivering them into the hands of the person to be served. '(By delivering them into the hands of O 3SA-t f1 ,a person of suitable age. who verified,or who upon questioning statedat he/she resides with Margaret K. Drive,by posting at the place of service,and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ; Skin Color ; Hair Color • Facial Hair Approx. Age : Approx. Height : Approx. Weight ' To the best of my knowledge and belief,said person was not engaged in the US Military at the time of service. Signature of Server: Una• .IL ed .- es under penalty of perjury Subscribed and mill rn to before me this tiiii the f•r' toing s true and correct. / / i, day •f Be tz op � I r elliw Signature of Server Public (Commission Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA . Notarial Seal Tammie L.Peters,Notary Public - a(: Carlisle Bum,Cumberland County f ��� 'a fJ t'� My Cammisston Ires Sept.3,2015 + f �;;J MEMBER,PF SYiVANtA A a "'.sRTION OF NOTARIES UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s ' udren.com MTG Finance,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CUMBERLAND County MARGARET K. DRIVER, MORTGAGE FORECLOSURE Defendant(s) NO. 12-5232-CIVIL VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: MARGARET K. DRIVER 833 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 DATE MAILED: November 13,2013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: December )( ,2013 UDREN LAW OFFICES, P.C. po A t n y of r Pl' ainhf MJU#: 12051077 CASE#: 12051077-1 Nicole LaBlefta, Esquire PA ID 202194 '' co �-) _73-ma c_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION MTG Finance,LLC Plaintiff v. Margaret K.Driver NO. 12-5232-CIVIL Defendant(s) ����ORDER AND NOW,this2day of )G teA,2013,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s),Margaret K.Driver,shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 833 OLD SILVER SPRING ROAD MECHANICSBURG,PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MARGARET K.DRIVER 833 OLD SILVER SPRING ROAD MECHANICSBURG,PA 17055 BY T- " OURT• J. rya -1 Fri C :t ""I .ru`..... 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'Ln F- cod ` C" i 05 1 k c'N 5. y 0S85 g � x i 6 v% w i d o r • ,SHERIFF'S OFFICE OF CUMBERLAND COUNTY l: ! t RonnyRAnderson ��C f i ;� Oj-j'•"}t;"' Sheriff t turd OF THE PRO I }'SONO iAP,Y gat: -- - Jody S Smith t� �, -1) 2: i Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE OF z";£ Si•tEP.IF} PENNSYLVANIA MTG Finance, LLC vs. Case Number Margaret K. Driver 2012-5232 SHERIFF'S RETURN OF SERVICE 09/20/2013 04:46 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 833 Old Silver Spring Road, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 11/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Margaret K. Driver, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 833 Old Silver Spring Road, Mechanicsburg, PA 17055, property is vacant. 11/12/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/8/2014 01/07/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/12/2014 03/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Mark Udren, on behalf of, Bayview Loan Servicing, LLC, a Delaware Limited Liability Company, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,216.71 SO ANSWERS, April 14, 2014 RONR ANDERSON, SHERIFF c) `ountvSu: e Sheriff, "eleosott Inc. a -as- id -Co. iNft 3 os- S310 On August 23, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 833 Old Silver Spring Road, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 23, 2013 ..1" ; 1 .1 By: d/ 'Real Estate Coordinator SE :01 V Z I 9r1vil [101 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2012-5232 Civil Term MTG FINANCE, LLC vs. MARGARET K. DRIVER Atty.: Mark Udren ALL THAT CERTAIN Unit in the property known, named and identi- fied in the Declaration .referenced. to below as 'Walnut Villas Condo- minium" located in the Borough of Mechanicsburg, County of Cum- berland, Commonwealth of Penn- sylvania, which has heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform Condo- minium Act, 68 PA.Cons. Stat.Ann. 553101 et seq. (Purdon Supp. 1987), by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declara- tion of Condominium dated July 30, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, page 147, which Declaration of Condominium dated December 31, 1985, and recorded on December 31. 1985, in the aforesaid office at Miscellaneous Book 313, page 133, and further amended by a second Amendment to Declaration of Condominium dated March 23, 1987 and recorded on March 27. 1987. in the aforesaid Office at Miscellaneous'tBook 331, page 933. and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous Book 335, page 283, :being and designated in such Declaration, as amended by such first Amendment and Second Amendment and Third Amendment as Unit No. 833 as more fully described in such Declaration, as amended by such First Amend- ment and Second Amendment and Third Amendment together with a 48 proportionate undivided interest in the Common Elements of such Condominium as set forth in such Declaration as amended by the First Amendment and Second Amendment and Third Amendment and any fur- ther amendments thereto hereafter recorded in the aforesaid office. Being the same premises which Roy W. Driver and Alice M. Driver, husband and wife, by deed :dats 5/12/1997 and recorded 8/13/1997 in Cumberland County in deed book 182 and page 794, then granted and conveyed to Margaret K. Driver Parcel: 18 BEING KNOWN AS: 833 OLD SILVER SPRING ROAD, MECHAN- ICSBURG, PA 17055 PROPERTY ID NO.: 18-22-0519-001-UP833. TITLE TO SAID PREMISES IS VESTED IN MARGARET K. DRIVER BY DEED FROM ROY W. DRIVER AND ALICE M. DRIVER, HUSBAND AND WIFE DATED 08/12/1997. RECORDED 08/13/1997 IN DEED BOOK 162 PAGE 794. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot -News Co. 2120 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 (ie patriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in ad for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2012-5232 Chill Term • ratpap MTG FINANCE, LLC logg vs. p pug MARGARET K. DRIVER map Atty: Mark Udren tJo ALL THAT CERTAIN Unit in the property' w known, named and identified in the Declaration referenced to below as `Walnut A. Villas Condominium" located in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, which has !n heretofore been submitted pursuant to the provisions of the Pennsylvania Uniform q Condominium Act, 68 PA.Cons. Stat.Ann. 553101 et seq. (Purdon Supp. 1987), by the B recording .in the Office of the Recorder of d Deeds of Cumberland County, Pennsylvania, of a Declaration of Condominium dated July 30, 1985, and recorded On August 14, aI 1985, in Miscellaneous Book Vol. 308, page 6 147, which Declaration of Condominium dated December 31, 1985, and recorded on .L December 31. 1985, in the aforesaid office at Z Miscellaneous Book a, 313, page 133, and further amended by L a second Amendment to Declaration of n Condominium dated March 23, 1987 and 1 recorded on March 27. 1987. in the aforesaid Office at Miscellaneous Book 331, page 933. 3 and further amended by a Third Amendment to Declaration of Condominium dated June 12, 1987 and recorded on June 12, 1987 in the aforesaid office at Miscellaneous This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 11 day of November, 2013 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bayview Loan Ser LLC is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 8th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 5232, at the suit of MTG Finance LLC against Margaret K Driver is duly recorded as Instrument Number 201409318. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 6 day of /r[ , A.D. c2 / ' Recorder of Deeds of Deeds, Cumberland County, (Artiste, e, PA My Co ' mission Expires the First Monday of Jan.2018