HomeMy WebLinkAbout12-5899UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675
SALVATORE CAROLLO, ESQUIRE - ID#311050
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
KASSIA FIALKOFF, ESQUIRE - H}#310530
ELIZABETH L. WASSALL, ESQUIRE - H?#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
856-669-5400 leadings @ udren.com
PNC Bank, National Association
C/O PNC Bank, N.A.
3232 Newmark Drive
Miamisburg, OH 45342
Plaintiff
v.
RANDALL V. PHELPS, JR.
8 TAYLOR AVENUE
WINDSOR, VA 23487
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CNII. DNISION
CUMBERLAND County
NO. ~ a..S~
COMPLAINT IN MORTGAGE FORECLOSURE
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YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
GLrNt ~"'°.JSfd
Ck-# 3Cey70
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LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
AVISO
Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y
entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Ademas, la Corte puede decidir a favor
del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted
puede perder dinero o sus propiedades a otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
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 PARR AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
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 notify
us within 30 days after receipt of this Notice and the attached document that the validity of
the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If
you do notify us in writing of a dispute within the 30 day period, we will obtain verification
of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute
the debt, it is not an admission of liability on your part. Also, upon your written request
within the 30 day period, we will provide you with the name and address of the original
creditor if different from the current creditor.
If you notify us in writing within the 34 day period as stated above, we will cease
collection of your debt, or any disputed portion of it, until we obtain the information that
is required and mail it to you. Once we have mailed to you the required information, we
will then continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document
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
Plaintiff' is PNC Bank, National Association. Plaintifi~ is the legal bolder 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 the Mortgage by virtue of
Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of
Assignment of Mortgage, it is by the following Assignments of Mortgage, all of
which have either been recorded or Plaintiff is in the process of formalising the actual
Assignment of Mortgage in Plaintiff s favor:
Assignor: N/A
Assignee: N/A
Date of Assignment: N/A
Recorded Date: N/A
Book/Instrumeni #: N/A
Page: N/A
?. Upon information and belief Defendant(s) and/or their predecessor:
Randall V. Phelps, Jr.
(hereinafter "Defendants"), are the owners of property located at 209 Clearview Road,
(Township of Fairview), New Cumberland, PA 17070 , b}~ virtue of Deed dated
11/08/2007 and recorded 11/14/2007 in Official Records Book 1932 at Page 8061 of the
Public Records of Cumberland County, Pennsylvania (hereinafter the "Property").
3. On 11/08/2007 ,Defendant(s) and/or their predecessor:
RANDALL V. PHELPS, JR.
promised to pay to the order of National City Mortgage, a division of National
City Bank ,the principal sum of $163,500.00 payable with interest thereon
provided in the Note.
4. By Mortgage dated 11/08/2007 ,Defendant(s) and/or their predecessor:
RANDALL V. PHELPS, JR.
to secure the Note, mortgaged to National City Mortgage a division of National
City Bank , the Property which is the subject of this action. The Mortgage was
recorded on 11/14/2007 in Official Records Book 1932 at Page 8096. Said
Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g).
A legal description of the mortgage premises is attached hereto and made a part
hereof.
5. Said mortgage is in default in that the payment due 03/01/2(112, and all subsequent
payments have not been made, and by its terms, upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage, together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of
the Mortgage as follows:
(a) By failing or refusing to pay the installments of principal and interest when due in
the amounts indicated below;
(b) By failing or refusing to pay other charges, if any, indicated below..
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $155,370.66
Accumulated Interest $6,376.32
Accumulated Late Charges $211.90
Escrow Deficit/(Reserve)
$2,212.54
Pro Rata MIP/PMI $193.9$
Grand Total $164,364.90
The above figures are calculated to 09/10/12:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 6.75000 %. The per diem interest accruing
on this debt is $28.73 and that sum should be added to the above date and 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 charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $53.02.
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 $164,364.90 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDR ICES, P.C.
BY:
Sherri J. Braunstein, esquire
PA ID 90f;75
VERIFICATION
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of the Plaintiff, PNC
Bank, National Association, do hereby verify that I am authorized to and do make this
verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are
true and correct to the best of my information and belief. I understand that false statements
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:~~~~ ~ ~ n o ~ 2-
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Title: l~l~W1~Z~d ~f18~1'
Company: PNC Bank, National Association
MJU #: 12060624 CASE #: 12060624-1
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REPRESENTATION OF PRINTED DOCUMENT
PN ~ Attention: Collection Department
(86-YM07-01-5)
MOtt'TGAGE°" Miam sburg ~OH 45342
710? 8381 6546 2135 958?
6-749-77406-0000006-001-01-000-000-000-000
RANDALL V PHELPS JR
209 CLEARVIEW RD
NEW CUMBERLAND PA 17070
Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE
PA001
Exhibit A
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT
July 30, 2012
Re: Loan No. 00058781 17
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or
ours) on your property located at 209 Clearview Rd New Cumberland PA 17070, IS IN SERIOUS DEFAULT
hecuuseyou have not made the monthly payments of~ $7,364.70 for the months of March 1, 2012 and July 1, 2012.
Late charges and other charges have also accrued to this date in the amount of 5247.90. The total amount now
required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is
57,612.60.
You may cure this default within THIRTY (30) DAYS of the date of this letter, by pawing to us the above amount of
57,612.60, plays any additional monthly payments and late charg=e which may fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or money order, and made at PNC
Mortgage/Collections Center, Mail Code B6-YM09-Ol-Ol, 3232 Newmark Drive, Miamisburg, OH 45342.
If you do not cure the default within THIRTY (30) DAYS, we irzterad to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment
of the amount of default is not made within THIRTY (30) DAYS, tir-e also intend to instruct our attorneys to start a
lmvsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged properh~ will he sold by
the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they
begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to
5 50.00. }Iowever, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees
even if they are over $ .50.00. Any attorney's fees will be added to whatever you owe us, which may also include our
reasonable costs. If you cure the default within the thirty day perioa; you will not he required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you
have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour beJoa-e the Sheriff's foreclosure sale. You
naav do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as
well as the reasonable attorney's fees and costs connected with the foreclosure sale ,(and perform any other
reyuia•ements under the mor-tgageJ. It is estimated that the earliest date that such a Sheriffs sale could be held would
be approximately nine -ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of
course, the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment will. be by calling us at the following number: 1-800-523-8654. This payment
must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain
init. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE
PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR 'TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT'. [YOU MAY HAVE THE RIGHT TO SELL
OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYE'sR OR TRANSFEREE WHO
WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS,
CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT
THE OTHER REQUIREMENTS CINDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE TIIE RIGHT
TO HAVE, THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOt_1R BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However,
you are not entitled to this right to cure your default more than three times in any calendar year.
We do encourage you to contact aHUD-approved counseling agency for financial counseling. To Locate an agency
near you, please visit www.hud.vov or call 1-800-569-4287.
This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have
received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan
was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only
exercise its rights against the property itself, and is not attempting to collect the discharged debt from you
personally.
INTERNET REPRINT
REPRESENTATION OF PRWTED DOCUMENT
As you go through the process of trying to resolve your account, you may receive additional
communications from PNC Mortgage, a division of PNC Bank, National Association (PNC Mortgage). Below
are answers to some frequently asked questions that will provide additional guidance.
Q1. I am attempting to resolve my delinquent loan with PNC Mortgage. Why am I receiving this letter?
Answer: PNC Mortgage is anxious to assist you. However, until we have received a!! required information from you
to determine what assistance can be provided, we must pursue a possible foreclosure action.
Q2. What will happen if PNC agrees to a workout option?
Answer: The goal of any workout option is to prevent fhe foreclosure action from starting. The specific actions will
depend on the agreed upon workout option.
Q3. What can I do to make sure all relevant PNC Mortgage solutions are explored to try and assist me'?
Answer: The most important thing is to maintain contact with us. If we have already sent you a workout package,
complete your documentation accurately, timely, and completely. Although this does not guarantee an approval, it will
help facilitate a timely decision.
Q4. What should I do if I do not have all the past due amount that is required?
Answer: PNC Mortgage has several options that maybe available to assist you. Please call us at 1-800-523-8654
fo talk with a representative about the available options.
Q5. Will I continue to receive calls attempting to collect the past due payments?
Answer: You may receive additional calls about your account. Discuss the status of the account with the caller to
see if any additional information is needed.
Q6. If I have questions or concerns in regards to the package 1've received, who should I contact?
Answer: Please contact PNC Mortgage at 1-800-523-8654.
Q7. Can I go to my local PNC Bank branch to discuss my account?
Answer: We recommend you contact a PNC Mortgage representative at 1-800-523-8654 to better serve your needs.
INTERNET REPRINT
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FORM 1 _°;
Plaintiff(s)
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Defendant(s)
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III' THE COURT- OF COMMON PLEAS 0~= ,
CUMBERLAND COUNTY, PENNSYL~rAl~
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NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
if you own and live in the residential property which is the subject of this foreclosw•e action, you may
be able to participate in a court-supen~ised conciliation conference in an effort to resoh~e this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twent<~ (20} days of your receipt of this notice, you must contact MidPenn Legal
Sen~ices at (7 ] 7) 243-9400 extension '?~ IO or (800) 822-528& extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, yc~u mint
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the Regal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the sen~ice upon you of
the 1'oreclasure 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.
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If you are represented by a IaKyer, 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 lawver complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. if you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOL` WISH TO SAtTE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Res ubmitted:
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Date jSignature of Counsel for Plaintiff;,
Sherri J. Braunstein, Esquire
PA ID 90675
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROVdF.R REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your kno~~~ledge:
Borrower name(s):
Property Address:
Cite:
is the property for sale?
Realtor Name:
Borrower Occupied'?
Mailing Address (if different)
Citv:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
of people in household:
State:_ lip:
~'es ^ No ^ Listing date: _Price: $_
Realtor Phone:_
Yes ^ No ^
Home;
Cell:
State: Zip:
Office:
Other:
How long?
Home:
Cell:
State: 7_.ip:
How long?
First Mort~a~e Lender:
Type of .Loan:
Loan Number: Date You Closed Your Loan: _ _
Second Mortgage Lender:
Type of Loan: _
Loan Number:
Total Mortgage Payments Amount. $
Date of Last Payment:
Primary Reason for Default:
Included Tapes & Insurance:
Office:
Other:
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: S $_ _
Retirement Funds: $ $_ _
Investments: $ $_ _
Checking: S $_ _
Savings: $ $_ _
Other: $ $
Automobile #l: 1v~Zodel:
Amount owed: Value:
Automobile #2: Model:
Amount owed; Value:
Other transportation. (automobiles, boats, motorc cam= Model:
Year: Amount owed: Value
Monthh~ Income
'~?ame of Employers
1.
Year:
Year:
__
~ . __
,4dditional Income Description (n.ot wages):
I . monthly amount:
monthly amount:
Borrower Pay Days: Co-Borrower Pay Days: _ ____ _
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortva e Food
2" Mort ~a,~e Utilities
j Car Pa~nnent{s} Cnndo/Nei h. Fees
Auto Insurance
Med. {not covered) _ _
'Auto fuel/re airs Uther ro ayment i
'Install. Loan Pa ~ment Cable TV ' _
'~ Child Su orC/Alien.
S endin Money I ___
Dav'IChiid Care/Twit. Other Ex enses I
Amount Available for Monthly Mortgage Payments Based on [ncome & E~.penses:
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?
~'es ^ 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?
1'es ^ No ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if know. regarding your lender or lender's loan
servicing company:
Lender's Contact (1s;'ame):
Servicing Company (Name):
Contact.:
Phone:
Phone:
I We, ,authorize the above
named to use/refer this information to my lender,~servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that Uwe arn'are under no obligation to use the sen~ices provided b_y the above
named.
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
1
y Proof of income
1~ Past 2 bank statements
~V~ Proof of an}~ expected income for the last -15 days
~' Copy of a current utilih• bill
~V Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
r
~ Listing agreement (if properl3~ is currently on the market)
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FORM 3
IN THE COCIR"I~ OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYL,hAN1A
1'lainiiff(s)
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vs.
Defendant(s) CNLL,
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrati~%e Order dated .2012 ~,overning the Curnbcrland
County Residential Mortgage Foreclosure Diversion Pragram, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this martgage
foreclasure action;
^. Defendant lives in the. subject real property, which is defendant's primar}~
residence:
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken. alJ of the steps required in that Notice to be
eligible to participate in acourt-supervised conciliation conference.
The undersiuned verifies that the statements made herein are true and correct. 1
understand that false statements are made subject to the penalties of 18 Pa. C.S. 54904 relating to
unscvorn falsification to authorities.
Signature of Defendant's CaunsellAppointed Date
Legal Representative
Signature of Defendant
l:)ate
Signature of Defendant Date
" 1 J 4' :.,
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAIN TIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302 ~ ~ ry `~~~' %' a; ~~ ~: %w,
STUART WINNEG, ESQUIRE - ID#45362 ,.,
~
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ;
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SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 ~ ~ `~~ ~~~ ' ~
~ `~~~ ~`~ ~ ~
SALVATORE CAROLLO, ESQUIRE - ID#311050
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY 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#31.1713
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadinas~ udren.com
PNC Bank, National Association COURT OF COMMON PLEAS
3232 Newmark Drive, Miamisburg, OH CNIL DIVISION
45342 CUMBERLAND County
Plaintiff
c i
RANDALL V. PHELPS, JR. ~ NO. l ~- S ~~ ~ ^ U~
8 TAYLOR AVENUE
WINDSOR, VA 23487
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; on behalf of the Plaintiff, in the above-captioned matter.
UDRE FICES, P.C.
BY:
Sherri J. Braunstein, Esquire
NA ID 9UF,75
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
11.1 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings~~udren.eom
__- -- - __
PNC Bank, National Association
Plaintiff
RANDALL V. PHELPS, JR.; et al
Defendant(s)
ATTORNEY FOR PLAINTIFF
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COURT OF COMMON PLEAS n-~
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CNIL DIVISION ~ ~~~~'
County 'v "'`""
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Cu~S~.(,~~ s ~/M~.~ ~.
MORTGAGE FORECLOSURE :~ Y Yp
-~;
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NO. 12-5899 Civil
PRAECIPE TO DISCONTINUE WITHOUT PR>H:JUDICE
TO THE PROTHONOTARY:
kindly mark thei above DISCONTINUED WITHOUT PREJUDICE, upon payment of
your costs only.
DATED: ~~ ~~~ ~~
UDREN LAW OF FICES, P.C.
~.
Attorney for Plaintiff ~; ,~~
MJU#: 12060624 CASE#: 1.2060624-1 Eiana i3. Flehinger, Esia
PA ID 209197