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MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Heather Riloff, Esquire / No. 309906
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
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~` NSYLVANI,~
NATIONWIDE ADVANTAGE MORTGAGE
COMPANY
1100 Locust St., Dept. 2009
Des Moines, IA 50391-2009
Plaintiff
v.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
Defendants
30428CFC-BI
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
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NO. ~ a-~O
CIVIL ACTION -MORTGAGE FORECLOSURE
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 aze 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
Le han demandado a usted en to torte. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dial de plazo al partir de la fecha de la demanda y la
notification. Hate falta a sentaz una compazencia escrita o en
persona o con un abogado y entregaz a la torte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea a visado que si usted no se defiende, la torte toms ra medidas y
puede continuaz la demanda en contra soya sin previo aviso 0
notification. Ademas, la torte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisioner de esta
demanda. Usted puede perder dinero o sus propiedades o otros de
rechos importances paza usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN
PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO .
ESTA OFICINA LE PUEDE PROVEER INFORMACION
SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED
NO TIENE EL DINERO SUFICIENTE PARR CONTRATAR A
UN ABOGADO, LE PODEMOS DAR INFORMACION
SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A
PERSONAS ELEGHiLE PARR SERV[CIOS A COSTO
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
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THIS IS AN ATTEMPT TO COLLECT A DEBT
ANY INFORMATION OBTAINED MAY BE
USED FOR THAT PURPOSE
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692,
et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR
ANY PORTIQN THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF
WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID.
LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME
AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE
THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE
SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME.
FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS
COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH
LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT
AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON
REAL ESTATE.
MARTHA E. VON ROSENSTIEL, P.C. 30428CFC-BI
Martha E. Von Rosenstiel, Esquire / No. 52634
Heather Riloff, Esquire / No. 309906
649 South Avenue, Suite 7
Secane, PA 19018
(610)328-2887
Attorneys for Plaintiff
NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF
COMPANY CUMBERLAND COUNTY
1100 Locust St., Dept. 2009
Des Moines, IA 50391-2009
Plaintiff
v. NO.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
Defendants
CIVIL ACTION -MORTGAGE FORECLOSURE
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
1. Plaintiff is Nationwide Advantage Mortgage Company, a corporation organized and
existing under state law, with offices for the conduct of business at 1100 Locust St., Dept. 2009,
Des Moines, IA 50391-2009.
2. Defendants, Todd E. Anthony and Evelyn R. Anthony are the mortgagors and real
owners of premises 77 Mountain Street-Rear A, Mount Holly Springs, PA 17065, hereinafter
described, whose last known address is listed in the caption.
3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and
real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the
above named defendants, mortgagors and real owners to Broadview Mortgage Company on
October 25, 2005, which mortgage is recorded on November 2, 2005 in the Office of the
Recorder of Deeds of Cumberland County in Mortgage Book 1929, Page 1977, secured on
premises 77 Mountain Street-Rear A, Mount Holly Springs, PA 17065 a true and correct
description of which is attached hereto as Exhibit I.
4. The mortgage has since been assigned to Nationwide Advantage Mortgage Company
by written assignment dated October 25, 2005 and recorded on November 2, 2005 in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book 722, Page 831.
5. Plaintiff alleges each and every term, condition and covenant in the aforesaid
mortgage, and hereby incorporates them herein by reference thereto.
6. The aforesaid mortgage is in default in that monthly installments of principal and
interest have not been made in conformity with the terms of the mortgage, from February, 2012
and each month thereafter, up to and including the present time.
7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the
mortgage documents, the entire principal balance and all interest due thereon are collectible
forthwith.
8. The following is an itemized statement of the amount due plaintiff under the terms of
the aforesaid mortgage:
Principal Balance $ 128,477.33
Interest from 1/1/2012 to 9/15/2012
at $20.68 per diem $ 5,321.51
Accrued late charges to 9/15/2012 $ 315.20
Accrued Escrow deficit to 9/15/2012 $ 2,208.25
Corporate Advances $ 315.42
Attorney's Fee $ 1,450.00
Hazard Insurance $ 1,191.00
Property Inspection Fee $ 85.00
Total $ 139,363.71
9. Plaintiff sent to defendants a Notice of Intention to Foreclose advising of rights
available under Act 6 of 1974 (Exhibit II).
WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged
premises in the amount of $139,363.71, plus per diem interest at $20.68 from September 16,
2012 to the date of judgment plus costs thereon.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
BY .,.~i
Martha E. Von Rose quire
Heather Riloff, Esquire
Attorneys for Plaintiff
EXHIBIT I
ALL THAT CERTAIN lot or piece of ground situate in Borough of Mount Holly Springs, County of
Cumberland, Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at an existing iron pin located in the North corner of land now or formerly of Kenneth and
Sherry Anthony, recorded at Cumberland County Deed Book 31-T, page 743 and Plan Book 45, page 19;
thence along land now or formerly of Hempt Bros., Inc., South 38 degrees 3 minutes 33 seconds East, a
distance of 90.61 feet to a set iron pin; thence along the Northwest border of Lot No. 1 on the hereinafter
Plan of Lots, South 43 degrees 59 minutes 21 seconds West, a distance of 236.24 feet to a set concrete
monument; thence along land now or formerly of Michael L. Gumby, North 43 degrees 38 minutes 48
seconds West, a distance of 90 feet to an existing iron pin; thence along land now or formerly of Hempt.
Bros., Inc., North 43 degrees 59 minutes 21 seconds East, a distance of 241.93 feet to an existing iron pin,
the place of BEGINNING.
CONTAINING 0.4925 acres and being Lot No. 2 on a final subdivision plan for Kenneth Anthony by
Eric L. Diffenbaugh, Professional Land Surveyor, and recorded in the Office of the Recorder of Deeds in
and for Cumberland County in Plan Book 68 page 7.
HAVING THEREON erected a dwelling known and numbered as 77 Mountain Street- Rear A.
UNDER AND SUBJECT, nevertheless, to all restrictions, reservations, conditions, covenants, easements
and rights of way of prior record.
BEING the same premises which TODD E ANTHONY and SUSAN ANTHONY, married persons, by
deed dated May 14, 2003 and recorded June 23, 2003 in the Office of the Recorder of Deeds in and for
Cumberland County in Deed Book 257, page 3621, granted and conveyed to TODD E ANTHONY,
single person, the Grantor herein.
PARCEL IDENTIFICATION NO: 23-32-2338-078., CONTROL #: 23000750
EXHIBIT II
ACT 6 NOTICE
Date: July 12, 2012
#30428va1 BP
NOTICE OF INTENTION TO FORECLOSE AND
ACCELERATE LOAN BALANCE
TO: Todd E. Anthony and Evelyn R. Anthony
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
LOAN #: 0001927565
PREMISES: 77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
The MORTGAGE held by (Nationwide Advantage Mortgage Company) , (hereinafter, we us or
ours) which is currently being serviced by Nationwide Advantage Mortgage Company on your
property located at:
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
is in default.
As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you
have not made the monthly payments as listed, and/or for other reasons as indicated below:
Monthly payments 2/1/2012 to 7/31/2012
@ $1,346.00 per month $8,076.00
Late Charges
$ 422.88
Corporate Advance $ 51.00
TOTAL AMOUNT PAST DUE $8,549.88
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us
the above amount, plus any additional monthly payments and late charges which may fall due
during this period. Such payment must be sent to:
Nationwide Advanta a Mortgage Company
1100 Locust St.. Dept. 2009
Des Moines, IA 50391-2009
If you do not cure the default within THIRTY (30) DAYS, we intend 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, we also intend to instruct our attorneys to start a law suit to
foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will
be sold by the Sher~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 $50.00.
However, 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 period, you will not be required to pay attorney's fees.
Remember you are also responsible for keeping all real estate taxes current.
We may also sue you personally for the unpaid 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 Before the Sheriff's foreclosure sale. You may 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
requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale
could be held would be approximately one-hundred and fifty (150) days from the date of this
letter. A notice of the date of the Sheriff s sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment will be by calling us at the following number: (1-800-
356-3442). The payment must be in cash, cashier's check, certified check or money order and
made payable to us at the address previously stated.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and
your rights to remain in it. If you continue to live in the property after the Sheriff's sale, a
lawsuit could be started to evict you.
NOTICE -This is an attempt to collect a debt and any information obtained will be used for that
purpose.
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 PROEPRTY SUBJECT TO THE MORTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT
ALL OUTSTANDING PAYMENTS, CHARGES ANDATTORNEY'S FEES AND COSTS
ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER
REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU
HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR 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.
Sincerely yours,
Martha E. Von Rosenstiel, Esquire
Heather Riloff, Esquire
Attorneys for Mortgagee
P.S. Please be advised that if you have previously been discharged from a Chapter 7 bankruptcy,
this is not a demand for payment but a Notice of Intent to Foreclose.
ADDITIONAL INFORMATION
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, we offer consumer
assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These
services are provided without cost to our customers. You may be eligible for a loan workout
plan or other similar situation. If you would like to learn more about these programs, you may
contact the Loss Mitigation Department at 515-224-7100. WE ARE VERY INTERESTED IN
ASSISTING YOU.
Attention Servicemembers and dependants: The Federal Servicemembers; Civil Relief Act
("SCRA") and certain state laws provide important protections for you, including prohibiting
foreclosure under most circumstances. If you are currently in the military service, or have been
within the last nine (9) months, AND joined after signing the Note and Security Instrument now
in default, please notify the servicer immediately. When contacting Nationwide Advantage
Mortgaee Company as to your military service, you must provide positive proof as to your
military status. If you do not provide this information, it will be assumed that you are not
entitled to protection under the above-mentioned Act.
For your benefit and assistance, there are government approved homeownership counseling
agencies designed to help homeowners avoid losing their homes. To obtain a list of counseling
agencies, please call (800) 569-4287 or by visiting httn'//www.hud.aov/offices/hssJsfh/hcc/cfm.
You may also contact the Homeownership Preservation Foundation's Hope Hotline at (888) 995-
HOPE (4673).
This matter is very important. Please give it your immediate attention.
Sincerely:
Martha E. Von Rosenstiel, Esquire
Heather Riloff, Esquire
Attorneys for Mortgagee
3~y~~
VERIFICATION
Lisa A Nicholson hereby states that he/she is the
Associate Vice President
of Nationwide Advantage Mortgage Company,
plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Nationwide
Advantage Mortgage Company and verifies that the statements made in the foregoing Complaint
in Nationwide Advantage Mortgage Company v. Todd E. Anthony and Evelyn R. Anthony
relating to the property located at 77 Mountain Street-Rear A, Mount Holly Springs, PA 17065
are true and correct to the best of his/her information and belief. The undersigned understands
that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
~~~~+ ~ ~ ~.avaavlJ Vll
Title: Associate Vice Presiders
Nationwide Advantage Mortgage Company
Plaintiff herein
Dated: Sentember 20, 02 12
FORM 1
NATIONWIDE ADVANTAGE MORTGAGE
COMPANY
1100 Locust St., Dept. 2009
Des Moines, IA 50391-2009
Plaintiff
vs.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. ~a~~jjODb
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NOTICE OF REStDENTIAI AtORTQAQE Ftrtl~ECtOSfJRE
DfVERStON /+ROGRAM
You have been served with a foreclosuretompiaint that could cause you to bee your home.
If you own and live in the. residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with yourlender.
if you do oat have a lawyer you must take the follow#ng steps to be stilt#ble for a
conciliation conference. First, within twenty (20} days of your receipt of this notice, you must contact MidPenn legal
Services at (717}243-9400 extension 2510 or (800} 822-5288 extension 2510 and request appointment of a legal representative,
at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the 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 en your behalf, if
you and your legal representative complete a financial worksheet in the format attached hereto, the Iegai representative will
prepare and flile a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty {60}days
ofthe-service upon you of the foreclosure complaint. IF you do so and atonciliation conference is3cheduled, you will have an
opportunity to meet with a representative nfyour tender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
tf you are represented by a lawyer, you and your lawyer must take the foryowing steps to
be eligit3le fOr a GOnt;i#lation GanterenCe. It is not necessary for ypu fo 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 nn 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 Conciiation Conference with the Court, which must be filed
with the Court withfn sixty {60} days of the service upon you of the foreclosure complaint. Ff you do so and a conciliation
conference is scheduled, you. will have an opportunity to meet wkh a representative of yourlender in,an attempt to work out
reasonable arrangements with your lender before the mortgage foredosure suit proceeds forward.
IF YOU W/BH TO $AVE YOUR HO1NE, YDU -MUST ACT QU/CICtY AND TAKE THE
STEPS REQ(!/REO BY TH/S NQT/CE. TH/S PROtiR11M /$ FREE.
Respectfully submitted:
September l7, 2012
Date Signature of Counsel for lai tiff
FORM 2
Cumberland County Res/denttet Moritaaga Foreo/osure DJveraton hrogrsm
FtnsaclaJ Worksheet
Date
Cumberland County Court of Common Pleas Docket
BORR0INER 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 prgvide the fgilowing information to the best of yqur knowledge;
Borrawername (s}:
Property Address:
City: State: Zip:
is the property far sale? Yes ^ No ^ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied: Yes ^ No ^
Mailing Address lif different)
City: State: Zip:
Phone Numbers: Home: Office:
Cell: _ Other:
Email:
# of people in household: How long?
Mailing Address:
City: State: Zrp:
Phone Numbers: Home: Office:
Cell: __ Other:
Email:
q of people in household:
First Mortgage lender:
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount:
Date of Last Payment:
HOW.
Date You Closed Your Laan:
Included Taxes and insurance:
Primary Reason for Default:
Is the loam in Bankruptcy? Yes ^ Na ^ If yes, provide names, location of court, case number & attorney:
Assets Amount Ctwed:
Home: $
Other Reai Estate: $
Retirement Funds: $
Investments: $
Checking:
Savings: $
Other: $
Automobile #1: Model:
Amount owed:
Automobile #z; Model:
Amount owed:
Other transportation (automobiles. boats, rnotorcvcles-
Year Amount owed::
Value:
$
S
Year:-
Value-
Year:
Value•
Model:
Value:
Manthhr Income
Name of Employers:
i.
2.
3.
Additional Income Description (not wages):
1.
2.
Borrower Pay Days:
Manthlr Ezoenses:iPiease Qnlvinc~ude expenses you are currently oavinal
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Foad
2 Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Autoinsurance Med. (not covered).
Auto fuel/repairs Other Prop. Payment
Install. Loan Payment Cable N
Child SupportJAiim. Spending Money
DayjChild CarejTuit. Other Expenses
Amount Available for Monthly 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):
Email:
Monthly Gross
Monthly Gross
Monthly Gross
Monthly Net
Monthly Net
Monthly Net
Monthly Amount:
Monthly Amount:
Co-Borrower Pay Days:
Fax:.
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 servicfig company to resolve your
delinquency?
Riease provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Phone:
named
purpose of evaluating
understand that t/we
named
authorize the above
to use/refer this information to my lender/servicerfor the sole
my financial situation for possible mortgage options. IJwe
am/are under no obligation to use the services provided by the above
Borrower Signature
Borrower Signature
Date
Please forward this document along with the following information to lender and
lender counsel:
~ Proof on income
V Past 2 bank statements
V Proof of any expected income for the cast 45 days
V Copy of a current utility bill
d Letter explaining-reason for delinquency and any supporting documentation
(hardship letter)
lasting agreement (if property is currently on the market)
V Copy of 2 years of federal income tax returns
y Copy of deed
date
FORM 3
NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF
COMPANY CUMBERLAND COUNTY,
1100 Locust St., Dept. 2009 PENNSYLVANIA
Des Moines, IA 50391-2009
Plaintiff
vs. NO.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
Defendants
REQUEST FOR CONCIltATtON GONFlrRENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is .the owner of the real praperty 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 Lo the penalties of 18 Pa. C.S. §4904 relatirsg to unsworn falsification to
authorities.
Signature of Defendant's. Counsel/Appointed Date
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
FORM 4
NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF
COMPANY CUMBERLAND COUNTY,
1100 Locust St., Dept. 2009 PENNSYLVANIA
Des Moines, IA 50391-2009
Plaintiff
vs. NO.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
77 Mountain Street-Rear A
Mount Holly Springs, PA 17065
Defendants
CASE .MANAGEMENT ORDER
AND NOW, this day of
20 ,the defendantf borrower in
the above-captioned residential mortgage foreclosure action having fited a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
QRDERED AND DECREED that:
1. The parties and their counsel. are directed to participate in acourt-supervised
conciliation Conference on
at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-ane ('21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upan
agreement of the parties in writing ar at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made maybe extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set #orth herein or such other date as agreed upon by the parties. in writing
or ordered by the .Court,. the case shalt be removed from the .Conciliation Conference
schedule and the temporary stay of proceedings-shall be terminated.
3. The defendant/barrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The. representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with. the authorized representative
in advance of the Conciliation Conference. if the duty autharized representative of
the plaintiff/fender is not available by telephone during. the Conciliation Conference,
the court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/tender at the rescheduled
Conciliation Conference
4. At the Conciliation Conference, the parties and their counse! shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage;: proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future to exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE CDURT,
1.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith ##r?? ?
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Chief Deputy - r
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Richard W Stewart tV
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Solicitor .
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Nationwide Advantage Mortgage Company Case Number
vs. 2012-6088
Todd E. Anthony (et al.)
SHERIFF'S RETURN OF SERVICE
10/03/2012 10:53 AM - Deputy Robert Bitner, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the
Defendant, to wit: Todd E. Anthony at 77 Mountain Street-Rear A, Mt. Holly Springs Borough, Mount Holly
Springs, PA 17065.
ROB RT BITNER, DEPUTY
10/03/2012 10:53 AM - Deputy Robert Bitner, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be TODD
ANTHONY, HUSBAND, who accepted as "Adult Person in Charge" for Evelyn R. Anthony at 77 Mountain
Street-Rear A, Mt. Holly Springs Borough, Mount Holly Springs, PA 17065.
RO ERT BITNER, DEPUTY
SHERIFF COST: $51.00
October 04, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
;c Ccu^: y$uite Sheriff, Teleesoft.. Inc-
30428- CPG -RD
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Heather Riloff, Esquire / No. 309906
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS
COMPANY : CUMBERLAND COUNTY
Plaintiff
vs.
TODD E. ANTHONY AND EVELYN R.
ANTHONY
Defendants
: NO: 12-6088 Civil
PRAECIPE TO MARK CASE DISCONTINUED AND ENDED
TO THE PROTHONOTARY:
Kindly mark this action discontinued and ended without prejudice.
Dated: September 22, 2014
MARTHA E. VON ROSENSTIEL, P.C.
BY:
Martha E. Von Rose
Heather Riloff, Esqu
Attorneys for Plaintif
squire
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