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Home My WebLink About12-5689 f_-_ Leon P. Haller, Esquire 21~ ~ 2 SEP i 3 PM 2~ t, 3 Purcell, Krug & Haller 1719 North Front Street rUM~~t#LA~N~ COUNT Y Harrisburg, PA 17102 P 5~~.b~N~~~, 717.234.4178 mtg@Pkh.com ~a - J`~D~ ~~''VGC ~f'~~ MTDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW MARGARET L. DUFF ACTION OF MORTGAGE FORECLOSURE Defendant THIS FIRl1?±1 IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT C~~VED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WI~.L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in icourt. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after th@ Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAIC~ THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMB)RLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVI O LE HAN DEMANDADO, A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARl10 QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ~S NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTEDNO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SM SU PARTTCIPACION. ENTONCES, tiA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROP~EDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN AIBOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBI~RLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 S 717-249-3166 ~~os.7s Pd Alf C''~ 17R `l oS P.~' aso~~3 _ _ _ ~ MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW MARGARET L. DUFF, ACTION OF MORTGAGE FORECLOSURE Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any informations obtained will be used for that purpose. The amount of the debt is stated in this Complaint. ' Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days a$ler your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If th$ Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different frgm the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW MARGARET L. DUFF, ACTION OF MORTGAGE FORECLOSURE Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff is MI1~3FIRST BANK, a corporation, whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. The Defendant, MARGARET L. DUFF, is an adult individual whose last known address is 135 ELM STREET, CARLISILE, PA 17013. 3. On or about, Octobeer 29, 1992, the Defendant executed and delivered a Mortgage Note in the sum of $78,800.00 payable' to CENTRAL MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A"'. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, the Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on (October 30, 1992 in Mortgage Book 1097, Page 948 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to INLAND MORTGAGE CORPORATION aril was recorded on October 30, 1992 in the aforesaid County in Mortgage Book 430, Page 110. They Mortgage was subsequently assigned to ATLANTIC MORTGAGE & INVESTMENT COhRPORATION and was recorded in the aforesaid County on September 7, 1999 in Mortgage Book 624, Page 443. The Mortgage was subsequently assigned to MIDFIRST BANK and was recorded in the'aforesaid County on February 17, 2012 as Instrument Number 201204916. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 135 ELM STREET, CARLISLE, PA 17013 and is more particularly described in Exhibit "B" attached hereto. ~ - - 6. The Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on March O1, 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $$0,351.23 Interest at $11.89 per day $2,853.20 From 02/01 /$012 To 10/01 /2012 ( based on contract rate of 8.5000%) Accumulated Late Charges $286.88 Good through 08/31 /2012 Escrow Deficit $2,915.56 Corporate Advance $51.00 Attorney's Fee at 5% of Principal Balance $2,517.56 TOTAL $58,975.43 * *Together with interest at the per diem rate noted above after October O 1, 2012 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff s Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by PlaintiFf. 8. Notice of intention td foreclose and to accelerate the loan balance was sent to the Defendant by letter dated July 12, 2012 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the July 12, 2012 Act 6 Notice is attached hereto and marked Exhibit "C". _ _ _ ~~r 9. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, conErming non-active military duty is attached as Exhibit "D". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.5000% ($11.89 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: PURCELL, G & LLER Leon P. Haller, Esquire LD. # 15700 Jill M. Wineka I.D. #58802 Attorneys for Plaintiff 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) t/ . ' r ' Multistate NOTE FHA Case No. I 441-451620-0-79b I ocTOaER Z9th,1992 ? [Datel ~ 135 ELM STREET, CARLISLE, PA 17013 ' (Properly Address] 1. PARTIES "Borrower" means each pdrsort sigt?ing at the end of this Note, and the person's successors and assigns. "Lender" means CENTRAL MORTGAGE COMPANY and its successors and assigns. ~ Z. BORROWER'S PROMI5IE TO PAY; INTEREST ' In return for a loan received from Lender, Borrower promises to pay the principal sum of SEVENTY EIGHT THOIrSAND E[GHT HWIDREO ANO NO/100 { Dollars (U.S. S 7880o.Q0 plus interest. to the order of Ltndu. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of EIGHT AND 500/1000 per cent ( e.soo 96) per year until the full amount of principal has bees pail. 3. PROMISE TO PAY SECURED Borrower's promise to poly is secured by a mortgage. deed of trust or similar security instrument that is dated the same date as this Note and called the "Saarurity Instrument." That Security Instrument protects the Lender ~Erom losses which might result if Borrower defaults under this Note. I 4. MANNER OF PAYMEN"f ~ (A) Time ' Harrower shall male a payment of principal and interest to Lender on the first day of each month beginning on DECr~IBEa 1st , t99z .Any principal and interest remaining on the first Iday of NOVEMBER 1st , 2022 ,will be due on that date, which is called the "Maturity Dart." (B) Place Payment shall be made at P.O.BOx 70x5 1810 OREGON PIKE LANCASTER, IPA 17604 or at such other place as Lender may designate in writing by notice ro Borrower. (C) Amount , Each monthly payrr~IGst of principal and interest will be in the amount of $ 605.90 .This amount will be part of a larger mont~tly payment required by the Security Instrument, that shall be flied to principal, interest and other ittuns in the order described ~ the Security Instrument. (D) AUonge to tbis Noted tior payment adjustments If an allonge providing for payment adjustments is executed by Borrower wgether with this Note, the covenants of the allonge shall be incorporated', into and shall amend and supplement the covenants of this Note as if the allange were a part of this Mott. [Check applicable box] I ? Graduated Payment Allonge ? Growing Equity AUonge ? Other [specify] 5. BORROWER'S RIGHT!TO PREPAY ~ Borrower has the right to pay the debt evidenced by this Note. in whole ar in part, without charge or penalty, on the 1`ust day of any month. ~ Pap• t of 2 I FItA Multistate Flied Rate Note • t 1 R (Yt03).02 Vi1P MORTGAGE FORMS • (913)29.8100 • (800)521.7291 InNtalt: _ _ _ ~ _ _ I . ~ ..r . 6. BORROWER'S FAILU~tE TO PAY M. (A) Late Clrarga for Oi~ardue Payments ~ ,,,,ry.~~ ~ts~t?.t'r, if Lender has not rd¢eived the full monthly payment rewired by the Security Instrument, as described.iii Paragraph,4(C) of this Note by the end of'fifteen calendar days after the payment is due. Lender may:"eollect'at=laoc;'~~ ' ~ iiipttie'~ariiotint of Faun percent ( 6 of the overdue aittw' tnc of. each payment (B) Default t•~ • ~ V ".~{~...'1"•' If Borrower defau b failin to in full an monthl ent, then Lender'iria~'`'elai'"` ' ~ Y 8 1~Y Y Y paYm y,, ~ cept as litttited bytiegula~idti's of the Secretary in the case of ~~pyment defaults, require immediate payment in full of the principal balance!riemain;itg 'due acid -all accrued interest. Lender ma choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances t~egu 'ens issued by the Secretary will limit Lender's rights co requir~el immediate payment in full in the case of payment defaults. Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secre of Housing and Urban Dtvelopment or his or ha dcsignec. j (C) Payment of Costs a Expenses , If Lender has rcq ' 'immediate payment in full, as described above. Lender may require Borrower to pay costs and expenses including rr~sonab c and customary attorneys' fens for enforcing this Note. Such fees! and costs shall bear interest from the date of disbursement at We same rate as the principal of this Note. 7. WAIVERS Borrower and any other n who has obligations under this Note waive the rights of prtsentmtatt and notice of dishonor. "Presentment" means the ri t w requirt Lender to demand payment of amounts due. "Notice of dishonor" means the right w require Lender w give nods to other persons that amounu due have not been paid. 8. GIVING OF NOTICES ~ Untess applicable law uirGS a different method, any notice that must be given to Bornower under this Note will be given by delivering it or by mailing it y fast class mail to Borrower at the property address above or at s different address if Borrower has given Lender a notice of Bo wcr's different address. Any noticx that must be ~g(vat to Lender under this Note will be given by Fuss class mail to Lender at the address stated in Paragraph 4(B) or at a diifY t address if Borrower is given a notice of that differ+er?t address. ~ 9.OBLIGATIONS OF PEiswS~ONS UNDER THIS NOTE ~ If more ihaat one person Signs this Note. each person is fully and personally obligated to keep all of the promises made in this Notc, including the promise tb pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things.', Any person who takes over these obGgadons, including the obligations of a guarantor, surety or endorser of this Note, is also] obligated to keep all of the promises made in this Note. Lender may enforce its righu under this Note against each perscm indi idually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed undet~ this Note. i i BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained ,in this Note. f I (S~) (Seal} IUtRCARET L FF -Borrower -Borrower (S~) ~ (Seal) --.r -Borrower t -Borrower; . , Pay To The 'Order 0~ f: ~ , w~lhout Recdl~rse ~ _ PAY TO THE ORDER OF ~ Ce.~t Mor ialge o pa _BY;~~-~ WITHOUT RECOURSE lea /.fa.~ l~iGtllilS DAY OF , 19~__._,_,_" f D RPOAATION ~m 1R ta~oal.oz .z tz I LAS. ft33. VIG PRESIDENT _ _ _ _ e _ • . i ALL Chat cattii» lot Ot gtousfd Yith lh~ la~provsrsete tl+areon •recsad situated on Last ~53a Street i» the Sosongh'ot Caslirle, County a[ CuoDarland end Stete of Pe»»eylva»ia, bon»ded a»d daacribad as,tollowai ! ON tha NortA by a» alleys o» the 1[aet by lot »oY az tora~arly of Jacab Carbaugt+t oa the South by xlaa pttsett et~d ot? the Nest' by lot' nave at tora~erly a! Jof~n 1ldaae, co~ttaiuit+g 'ive»t -txo {!Z? tllet in front of Sln Street, e»d Osre Etoadred ratty ~ 150 .[aet i» detrth to ' ~ tri. allay atoresoid, avers or lees, and said property kMnrA ee No. 1~3 Lla+ Street. , ~ , ~ 1 7~y :S ,q ~4~I' ! 7 r _ , .nw~e.re~anr~re Midland Mortgage A Division of MidFirst Bank P.O. 13ox 2664b • Oklahoma City, OK 7312b • 800..S.S2.3000 07!12!12 MD441R16eE1686i1P1of2 MARGARET L DUFF 135 ELM ST a,,, CARLISLE PA 17013-1921 NOTI E OF INTENTION 70 FORECLOS~ND ACCELERATE LOAN BALANCE 'UNDER SECTION 403 OF PE[JNSYLVANIA ACT N0.6 OF 1974 RE: 135 ELM ST CARLISLE F?A 17013 Loan Number 0054895803 Dear Mortgagor: MidFirst Bank is tht; holder of a Mortgage and a Note on the above premises, or is the mortgage-servicing agent for such hold®r, As of the date of this notice. THE MORTGAGE IS IN DEFAULT STATUS because of non-payment of'the following: payments, late charges, and advances from 03/01h2 through 07/01112 The fatal amount now required to cure the default (or in other words, to get caught up on your payments) is $6,359.53. All payments referred to in this notice must be in the form of Cashier's or Certified Check made payable to Midland Mortgage' and must be received at the expedited payment processing address on your coupon book not later than the dates and times speafied herein. In the event that payment (as specified in the proceeding paragraph) is not made WITHIN THIRTY {30) bAY5 from the dajte of this letter, it is the intention of the holder of the mortgage, through this company, to accelerate (declarle due and payable immediately the entire loan) the mortgage obligation and all other lawful charges and instruct our attorney to institute MORTGAGE FORECLOSURE PROCEEDING. (A) If you wish to'CURE THE DEFAULt within thirty (30) days from the date of this letter, you must pay the TOTAL AlwIOUNT DUE stated above, plus an addtional monthly installment if payment is made after the 1st day of the next month, plus an additional fate charge if due at time of payment and not included above. A LATE CHARGE is due with each mortgage payment that is paid more than fifteen (15) days after the due date. Your current monthly installment is $1,260.30. (B) If payment i~ made AFTER THIRTY (30) DAYS from the date of this letter, but BEFORE FORECLOSUIRE PROCEEDING has been started, the amount you will have to pay will also. include the regular monthly installments and late charges then due, plus, if incurred, any ATTORNEY'S FEE OF NOT MOaI~ THAN ;50.00 and any title report costs, which amount can be obtained by contacting Midland Mortglage at 1-800-552-3000, extension 1799. `If you have received S bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are cur?enty in bankruptcy under the protection a~ the automatic stay, this letter is not an ariempt to cotlect tha debt, but any default wig need to be cured to avoid foroctosure. H your ban was in default at the time MidFiret Bank acquired the servioinp of your ban and you have not filed bankruptcy or received a discharge of the debt seoured by fhe MorigapelDeed or Trust, tiva are required to advise you that this communication is from a debt collector, this is an attempt to eoQed a debt, and any information obtained wHl be used for that purpose. I • <<~ _ _ _ uouia ae[ta+e~rert • Midland Mortgage A Division of Mid~irst $ank P.O. Boz 2bb48 • Oklahoma City; OK 7311b • 800..552,3000 AFTER FORECLOSURE PROCEEDING HAS BEEN STARTED, you have the right to STOP the foreclosure action at any time up to ONE (1) HOUR BEFORE the commencement of the SHERIFF'S SALE by paying the entire amount due at the time (which shall include all delinquent installments and unpaid late chargt#s, together with REASONABLE LEGAL FEES ACTUALLY INCURRED, costs and other sums related to the foreclosure action, and which amount can be obtained by contacting Midland ~ Mortgage at 1-800-652-3000). Should you FAIL ko reinstate the loan as outlined above, the mortgage premises will be SOLO AT SHERIFF'S 3ALE,Iwhich will take place approximately seven (7} to eleven (11 }weeks following SERVICE of the Complaint i~t .Mortgage Foreclosure, at which time your OWNERSHIP interest in the mortgaged premises will be "PERMINATED, and thereafter, if occupied, proceedings will be taken to OBTAIN POSSESSION of the real estate. You have the right to REFINANCE THE LOAN with another lending institution or TRANSFER THE PROPERTY to another person, under and subject to the existing mortgage. That person will have the SAME RIGHT TO SURE THE DEFAULT as you Rave, subject to the same limitations and requirements. You may CURE DEFAULTS up to three (3) times in any calendar year. upon cure of a default you will be in the same position as if there had been NO DEFAULT. A default may be cured by ANYONE on your behalf. It is important that y+ou call our office as soon as possible to discuss the options available to you. Our Loan Counselors may be reached toll-free at 1-800-552-3000, Monday through Friday, 8:00 a.m, to 9:00 p.m. (Central Time}. Sincerely, Delinquency Assistance Center Midland Mortgage Loan Number 0054895803 'lf you have received a bankruptcy discharge of the debt secured by the Moetgsge/Deed of Trust or you are currently in bankruptcy under the protectbn of~ttie automatic stay, this letter is not an attempt to c:albet the debt, but any default wiA need to be cured to avoid forecbsure. tf y¢ur ban was in default et the time MidFirst Bank acquired the servicing of your loan and you have not filed bankruptcy or received' a discharge of the debt secured by the MortgageJDeed of Trust, we are required to advise you that this communication is from g debt collector, this is an attempt to coAect a debt, and any Information obtained will be used for that purpose. -T1T~ - _ - _ _ _ _ _ _ _ _ _ Department of Defense Manpower Data Center Resits e: er: AUg-23.2012105224 SCRA 2.3 t tf1 ~C~twI17~7~ ~~iirl~ ~.G~~B~ 1~4`~ Last Name: DUFF First Name: MARGARHT Middle Name: Active Duty Status As CDf: Aug-23-2012 + Aawe. t?wy soon oak ' ~ar.twtr'Eiw oi• ~ = r ~ ~ ~ ~ ~ z,. t., NA NA. .,i,~;~^'~-Ei~-. ~?'~S ..'~yz. ;~a`•.IJO:v NA TNe rasporua refeGa:thgZiieN4diiils'A§tH'! ~!;>»~.R^?R,~:6'•SWUS DrH~ ,4!R,]?dhsOulYMApin~6T~biy~, ..'yl~igt&atluDr~.. i.~.ic„ ,..x ' AChW thM~c$rrt.tbtB ~C^;'r~, i. t ta'= ~f.. }nt.2~i.1 ~~4~a`.^..^' - i I';+ae B!'.'r"~ , 5~ NA •i~.w: 4ttA ~`v, -hc. t ~.`4-i`~pr.. yy~f~~~: 'rMe rebap.. nuea vrt«+:M. ~tr.cr~"s~;~?r:''~-.i~et a.a» `.".,~^r awu. wro "'app rt`:r>' i.#a,~ w~'tr,.,~;~C 'kj ~ 1 ~'i3'i: '.>f ? ~~i _ # TtrAllri~r;or;}~FY!r~!RYSt~e~4o;, r.: b`Aet>vi;Duy~cf,• OrtM.:~;' ;y ..F'.... fir. S'4 ~ r. b'3R. n`.1n.rc' U;::t:y ~ "5 ~ A ~ 9 344 t - 4`~i.+ Ordr NOYiertlotiSWt Da!• i , t ~ . .adM',t!?~!?!t:~.l?t?!!;= - , :L . ~nx,. NA '4riA;k'r::4'F:.`..~~~",c;~~,~^,y~.:. ,;:,,i-:r: ~;'~J:r:~.. ]HsnsP~senlledswMtner/i4~i~ijFAd.f~M~;Ql~1~(e!11~f:w~i111iHrank~dia~f... 'bropoAtoradNeduty Upon searchi the data banks of Rhe Department of Defense Man i e. ' ng powe7'ij ta- ~ bai'sed on the Informatbn that you provided, the above is the status of the individual on the acgve duty st~kus date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Publk: Health, ark Coast Gird). This status includek information on a Servtcemember or hisRter urrit receiving notification of future orcters to report for Alive Duty. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center A80D Mark Center Drive, Suite 04ff25 Arlington, VA 22350 ~i ~ i tb ~ ~ - r- COMPANY NAME: MIDFIRST BANK VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge end upon 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. Dated R16! ~ By se h ~aaea" 3eniorForeclosttre Title Litigation Specialist IN THE COURT OF COMMON PLEAS OF MIDFIRST -BANK CUMBERLAND COUNTY, PENNSYLVANIA t:°w:• Plaintiff(s) ~ C t!) ~ Tg Vs. ~ -gyp 'L3~~ MARGARET L. DUFF ~r Q`~ ~p? - ~ ~ / --Gx' W --i G Defendant(s) Civil • 2.tp tV t~f j_, G NOTVCE OF RESIDENTIAL MORTGAGE FORECLOSURE ~ ~ ~ DIVERSION PROGRAM ~ You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conferelnce. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243-9404 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. C>rnce you have been appointed a legal representative, you must promptly meet with the legal representative within tvYenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and f+le a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with is representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. if you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal~,can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixtiy (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. /F YOU WISH TQ SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIREDI BY THIS NOTICE. THIS PR06RAM IS FREE. Respectfully submitte 9/12/12 Date Leon P. g:aller / Jill M. Wineka Attorney. for Plainftiff Purcell, Krug and Haller 1719 North Front Street Harrisbur PA 17101 PA ID 157~a 158802 nn- _ IN THE COURT OF COMMON PLEAS OF MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. MARGARET L. DUFF Defendant(s) Civil IItEQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28 , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. 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 residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendants Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendarnt Date _ _ ~ Cumberland County Residential Mortgage Forsc/osure Diversion Program Flnancisi Worksheet Date Cumberland County Caurt of Common Pleas Docket # BORROWER REQUEST OR HARDSHIP ASSISTANCE To complete your regyest for hardship assistance, your lender must consider your circumstances to determine possible options while uvorking with your Please provide the foil ' ing information to the best of your knowledge: • Borrower name (s): Property Address: City: State• Zip• Is the property for sale? Yes ? No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied: Yes ? No ? Mailing Address (if diff$rent) City: State: Zip: Phone Numbers: Home: Office: Cel I: Other: Email: # of people in househo! : How long? Mailing Address: City: State• Zip• Phone Numbers: Home: Office: Cell: Other: Email: # of people in househo) ; , 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 and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: ModeL• Year: Amount owed: Value: Other transportation (aj}itomobiles. boats, motorcvclesl: Model: Year: Aimount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days:. Co-Borrower Pay Days: M n e : PI se nl inclu a ex ense ou re rrentl in EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Pa ment Cable N Child Support/Alim. Sending Money Day/Child Care/Tuit. Other Expenses Amount Available for Mlonthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: _ _ _ Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the folbwing information, if know, regarding your lender or lender's loan servicing company: lender's Contact (Najrne): Phone: Servicing Company (Name): Contact: Phone: I/We, authorize the above named to use/refer this information to my lender/servicer fqr the sole purpose of evaluating my financial situation for possible mortgage options, I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of ~ current utility bill V letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of ~ years of federal income tax returns V Copy of deed 3_.j MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff ~`~~~~ ~`m~'~ -~ ~g ~ I(~i9~i'~BERLAND COUNTY, PENNSYLVANIA ~s~Js`'ic~~. ~ ~~~~ I ,F, CNIL ACTION -LAW vs. ~'s~S ~ L~~,l~if? MARGARET L. DUFF ACTION OF MORTGAGE FORECLOSURE Defendant No. 12-)!5689 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: November 19, 2012 PURCELL, KRUG, & HALLER Y Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 ~g~~ ~ C~ ~ 8r ~ ~a83>~~ S 4 F `1 IE � oIHONOTA1�'.r, 2013 KAY 16 1'N 1: 3 1 CUMBERLAND OOUNTY I ENNSYLVANIA Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller @pkh.com MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW VS. No. 12-5689 Civil MARGARET L. DUFF, Defendant IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY: Please mark the above action settled and discontinued, without prejudice. PURCELL, KRUG & HALLER BY Lkn�P.Haller ID #15700 Attorney for Plaintiff Date: May 14, 2013