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Home My WebLink About13-0127r ^ KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF cm~ h' ATTORNEY LD. NO. 66287 , r.m .Y `. . • - r.; WILLIAM E. MILLER, ESQUIRE r?~' ` ., .. r ATTORNEY LD. NO. 308951 _ r ~.w~' - J e :._ 298 Wissahickon Avenue ~~{ i ~ ~ -~-~ P.O. Box 1489 ~c~ -,~ North Wales, PA 19454 ?~ (215) 855-9521 w y PARTNERS FOR PAYMENT RELIEF DE, ~' COURT OF COMMON PLEAS'dF ~ III, LLC 3748 West Chester Pike, Suite 103 CUMBERLAND COUNTY, PA Newtown Square, PA 19073 PLAINTIFF, v. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011 DEFENDANTS. f-, '+T _.~ ~. T.. ""~ r-.~~+~ `r ~.~ i ~::- w~ --1 c;~ -*t ~c ~, ~r ,.y as NO: a~ (~IV( ~3-1 COMPLAINT -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 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 ~/,. ~~.~ 3~(j3.~s~a-'J ~L.~ 7~/l f ~~ a~s~c 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: LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, LISTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. LISTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI LISTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA LISTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. LISTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. 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. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue P.O. Box 1489 North Wales, PA 19454 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE, COURT OF COMMON PLEAS OF III, LLC CUMBERLAND COUNTY, PA 3748 West Chester Pike, Suite 103 Newtown Square, PA 19073 PLAINTIFF, v. JOSEPH E. JIRAS a/k/a JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011 DEFENDANTS. NO: COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff hereby complains against Defendant as follows: 1. Plaintiff is Partners for Payment Relief DE, III, LLC, ("Plaintiff'), with an address of 3748 West Chester Pike, Suite 103, Newtown Square, PA 19073. 2. Plaintiff is the current holder of the mortgage described below (the "Mortgage"): (a) Parties to Mort~a~e: Mortgagee: Mortgage Electronic Registration Systems, Inc. MERS as nominee for GMAC Mortgage Corporation Mortgagor: Joseph E. Jiras, III and Athena J. Brellos (b) Date of Mort~a~e: May 5, 2005 (c) Place and Date of Record of Mort~a~e: Recorder of Deeds County: Cumberland Mortgage Book: 1906 Page: 3693 Date: May 10, 2005 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No.1019 (g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignment: Assignor: Mortgage Electronic Registration Systems, Inc. as Nominee for GMAC Mortgage Corporation Assignee: Partners for Payment Relief DE, III, LLC Date of Assignment: August 10, 2011 Recording Date: February 7, 2011 Instrument No.: 201104595 3. Plaintiff is, therefore, the present holder of the mortgage by virtue of the above- described Assignment. 4. Contemporaneous with execution of the Mortgage, Defendants executed a Note (the ``Note") 5. The real property which is subject to the Mortgage is generally known as 2014 Lincoln Street, Camp Hill, Pennsylvania 17011. A true and correct copy of the legal description is attached hereto and marked as Exhibit "B." 6. The name and mailing address of Defendants is: Joseph E. Jiras and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011. 7. The interest of Defendants are as Mortgagors, Real Owners, or both. 8. The Mortgage is in default because the loan matured and all interest and other charges stated below, all as authorized by the Mortgage have not been paid, and the whole of the principal, together with charges specifically itemized below are immediately due and payable. 9. The following amounts are due as of January 2, 2013: Principal of Mortgage debt due and unpaid Interest currently due and owing currently at $1.60 each day Late Charges at $17.60 and for each month hereafter Title Search Court Costs (filing and service) Attorneys' Fees $17,980.91 $3,086.70 $1,091.20 $175.00 $203.75 $1,650.00 TOTAL X2.41 10. Interest accrues at a per diem rate of $1.60 each day that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 11. The attorneys' 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 Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 12. Notice pursuant to Act 91, was sent to Defendants on November 28, 2012. A true and correct copy of the Notice sent to Defendants is attached hereto and marked as Exhibit "C." WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, in the amount set forth in paragraphs 9 and 10, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and. for the foreclosure and sale of the mortgaged premises. Respectfully submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP/°`1„ I ~'° Date: ~ BY: Step n M adi ,Esquire VERIFICATION Stephen M. Hladik, Esquire, hereby states that he is the attorney for Plaintiff in this action, that he is authorized to take this Verification on behalf of said Plaintiff, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Due to the Plaintiff being out of the state and jurisdiction, counsel has been unable to obtain the Plaintiff's verification at this time, which verification, when received, shall be substituted in place and instead of this verification. The undersigned understands that this statement herein is made subject to the penalties of 18 PA. C.S. §4904, relating to unsworn falsification to iolii'ti Date: ~ Stephen M. Hl d Attorney for P ai ,v COMb40NWFJaI TH of PENNSYLVANW g)~ County al CUMBERLAND ~ 5S I Robert P Ziegler, Recorder, do hereby J Certify that the foregoing is a true ttrtd 3 ' ~~~~~°~sdmy page 3(e ~1_S 2- S I ~ ~x ~ ~ ,,;..- uy corrrnbeton 1q 1~Aonds~, tG1i~ Jan, 20, 2014 AccountNo.:9738196 *'~~`~` i'1hY 10 P~1 3 09 Branch No.: ] 22 Loan Product: 90% CLTV Piggyback MIN 1000697-8250973819-0 OPEN END MORTGAGE TH1S MORTGAGE SECURES FUTURE ADVANCES TffiS MORTGAGE, as amended and extended (this 'Mortgage") is signed to secure advances »nder a GbiAC Mortgage Corporation Home Egttity Linc of Credit Agreement and Federal Truth in Lending Disclosure S~tement (the 'Agreement'); it is dated as of May 5, 2005, and is made by Joseph E. liras and Athena J. $rellos who reside(s) at 2014 Lincoln Street ,Camp Hit], Pennsylvania 17011, as mortgagor(s), who irrevocably mortgages, grants and conveys to GMAC Mortgage Corporation, a Pennsylvania Corporation, I00 Witmer Road, Horsham, PA ]9044-0963 (hcrcin "GMAC") and the Mortgage Electronic Registration Systems, inc., P.O. Box 2026, Flint, MI 48501-202b ("MFRS") acting solely as nominee for GMAC and GMAC's successors and assigns under this Mortgage, as mortgagee. 7hrouehout this Mortgage, "we", "us" and "our" refer to mortgagor(s). "GMAC" refers to GMAC Mortgage Corporation or its assigns. The "Account" refers to the Home Equity line of credit account established by GMAC under the Agreement "Borrower" refers to each person who signs the Agreement as borrower. The Agreement and this Mortgage, taken together, are called the "Credit Documents." "Signer" refers w any person (other than GMAC) who bas signed a Credit Document_ DESCRIP'i70N OF SECURITY By signing this Mortgage, we mortgage to MFRS acting solely as a nominee for GMAC, subject to the terms of this Mortgage, (a) the real estate located at 2014 Lincoln SL , City/1'ownship/Borough of Camp Hill, County of Cumberland; Commonwealth of Pennsylvania 17011, more fully described in Schedule A; (b) all buildings and other structures on the property; (c) all rights we may have in any road, alley, easement or license regarding the property or in any mineral, oil, gas or water which is part of the property, (d) all rents and royalties from the property; (e) all proceeds of any insurance on the property and all refunds of premiums on such inc~rrance; (f) all proceeds of any taking (or threatened taking) of the property by any governmental authority, and (g) all fixtures on the property at any tune (collectively, the 'Property ). The Property includes all righu and interests which we now have or which we may acquire in the future. For example, if the security mortgaged under this Mortgage is a Leasehold estate and we subsequently acquire fee title to the Property, the rights and interests granted to MFRS acting solely as a nominee for GMAC by this Mortgage will include the fee title that we acquire. In all events if this Mortgage is a first mortgage, and to the extent permitted by law if this Mortgage is a second mortgage, this Mortgage is also a security agreement under the Pennsylvania Uniform Coirmrercial Code and we hereby grant MFRS acting solely as a nominee for GMAC a security interest in the personal property desen~bed in (d) through (f) above. 1 hereby certify that the precise address of GMAC Mortgage Corporation is 100 Witmer Road, Horsham, PA 19044-0963. GMnGPA 9~(I 906PG3693 G1 /14/2011 ~ 1:05:32 AM Inst.#J 200516235 -Page 1 of 10 SECURED OBLIGATIONS THIS MORTGAGE SECURES FUTURE ADVANCES. We have signed this Mortgage to secure payment to GMAC of up to $18,000.00, plus accrued and unpaid FINANCE CHARGES and any other amotmts due GMAC under the Agreement (the "Total Balarue Outstanding') and to secure performance by Borrower under the Agreement and our performance of the covenants of this Mortgage (collectively, the "Secured Obligotions'). PRIORITY OF ADVANCES The lien of this Mortgage will attach on the date this Mortgage is recorded. The indebtedness e~'idenced by the Credit Documents is a revolving indebtedness. The Credit Documents provide that amounts may be advanced, repaid and readvatxed from time to time in accordance with the terms and provisions of the Agreement Accordingly, the aggrEgate advances during the term of the Credit Documents may exceed the Credit Limit However, the Total Balance Outstanding less F7T)ANCE CHARGES at any time (the "Earning Balance Outstanding') shall never exceed the Credit Limit, except for advances made to protect the lien of this Mortgage. We agree that the lien and security title of this Mortgage shall not be deemed released or extinguished by operation of law or implied intent of the parties if the Total Balance Outstanding is zero as of the date of this Mortgage or is from time to time reduced to zero by payments made to GMAC. PROMISES AND DUTIES We promise that, except for Permitted Liens: (a) we own the Property; (b) we have the right to mortgage the Property to GMAC; and (c) there aze no outstanding claims or charges against the Property. The term "Permitted Lien" means (x) any mortgage, deed to secttre debt or deed of trust ("security instrument) disclosed to GMAC by any Signer in app]ying for the Account, to the extent that the amount secwed by such security instriunent does not exceed the amount disclosed on such application; and (y) any liens, claims and restrictions of record that do not individually or collectively have a material adverse impact upon GMAC's security, the value of the Property or the Property's current trse. Each of us gives a general warranty of title to GMAC. This means that each of us will be fully responsible for any losses which GMAC sugers because someone has rights in the Property other than Permitted Liens. We promise that we wt11 defend our ownership of the Property against any claims of such right a+'e will neither take nor permit any action LG partition, subdivide or change the condition of title to all or any part of the Property. We will not amend any Pemvded Lien without GMAC's prior written consent CERTAIN PROVLSIONS OF THE AGREEMENT We understand that GMAC tray, under certain circumstances set forth in the Agreement, cancel its obligation to make future advances and/or require repayment at once of the Total Balance Outstanding. BK 1906PG3694 01/ta/20ti 11:05:32 AM CUMBERLAND COUNTY Inst.3! 2D0516235 - Paye 2 of iG Under the Agreement; FINANCE CHARGES are based on the "prime rate" published in The Wall Street Jotunal or in certain circumstances the "prime rate" published in The New York Times or a similar index selected by GMAC. The rate of FINANCE CHARGES changes on a daily basis as the index or the amount outstanding under the Agreement increases or decreases. We understand that Borrower will not receive advance notice of such changes. PROMLSES AND AGREEMENTS 'JVe agree with GMAC as follows: 1. TI)VIELY PAYMENT. Except as limited by paragraph 10 below, Borrower shall pay when due all sums owed Gh1.AC under the Credit Documents. Z. APPLICATION OF PAYMENTS. All payments shall be applied by GMAC as set forth in the Agreement 3. MORTGAGES AND DEEDS OF TRUST; CHARGES; CLAIMS. We shall make payments when due and perform all our obligations undo any mortgage, deed of trust or other security agreement on the Property. We shall pay or cause to be paid when due all taxes, assessments, maintenance charges or costs incumd for the protection of the Property or the lien of this Mortgage (collectively "Assessments"). Receipts evidencing such payments shall be delivered to GMAC upon its request Except for Permitted Liens, we shall not allow any encumbrance, charge or lien on the Property to become prior to this Mortgage. 4. HAZARD INSURANCE; GOVERNMENTAL TAKINGS. (a) We shall, at our cost, keep all improvements on the Property insured against loss caused by hazards included. in the term "extended coverage" or against loss by any other hazards GMAC may reasonably specify to be covered. Hazard insurance shall be in an amount equal to the lesser of (i) the full replacement cost of the building that is part of the Property or (ii) the amount of this Mortgage plus the total amount of all Permitted Liens. However, coverage will never be less than the amount necessary to satisfy any coinctirance requirement contained in the insurance policy. \Ve may choose the insttrartce company, subject to approval by GMAC which may not be unreasonably withheld. All insurance policies and renewals must be in a form acceptable to GMAC and must include a standard mortgagee clause in favor of GMAC. GMAC shall have the right to hold the policies and renewals, subject to the terms of any Permitted Liens. ]f we pay the premiums directly, we shall provide GMAC with all renewal notices and, if requested by GMAC, all receipts for premiums. if policies and renewa)s are held by any other person, we shall supply copies of them to GMAC within ten calendar days aRer they are issued. In the event of loss, we shall give prompt notice to the insurance company and GMAC. GMAC may file a proof of loss if we fail to do so promptly. BK190oPG3~95 O~tiai2011 ~1 05:32 AM CUMBERLAND COUNTY Inst.it 200516235- Page 3 of 1U (b) The proceeds of any taking or threatened taking of the Property by a governmental authority shall be paid to GMAC, subject to any Permitted Liens. We shall give GMAC notice of any such threatened taking and sign all documents required t,o carry out this paragraph 4. No sealement relating to such a taking or threatened taking may be made without GMAC's prior written approval which shall not be unreasonably withheld. (c) Subject to the tcmts of any Permitted Lien, GMAC may elect that the proceeds of any insurance or condemnation (after payment of all reasonable costs, expenses and attorneys' fees paid or incurred by GMAC and us) shall be applied to pay the Secured Obligations, to repair or reconstruct the Property, andlor pay us for our Loss. In the event that such proceeds are not used entirely for repair and rcroncinrctien, we shat] provide GMAC with a new appraisal or valuation of the Property, conducted by a person or entity and in a form reasonably acceptable to GMAC, unless GMAC waives this t~quirement in writing. The receipt of proceeds shall not cure or waive any default or notice of default under this Mortgage or invalidate any act done pursuant to such notice. If the Property is abandoned by us, or if we fail to respond to GMAC in writing within 30 calendar days from the date notice of a proposed insurance or condemnation settlement is given to us, GMAC may settle the claim, collect the proceeds and apply them as set forth above. if the Property is acquired by GMAC, all of our right' title and interest in and to any insurance or condemnation proceeds shall become the property of GMAC to the extent of the sums secwed by this Mortgage. 5. MAINTENANCE OF 'THE PROPERTY; LEASEHOLDS; CONDOMINIUMS: PLANNED UNIT DEVELOPMENTS. We shall use, improve and maintain the Property in compliance with law; keep the Property in good repair and pay when due all repatr costs; prevent waste, impairment and/or deterioration of the Property; and comply with the provisions of any lease of the Property- if the Property is part of a condominium project or a planned unit development, we shall promp!ly perform all of our ob]igations tinder the governing documents of the projector development. b. PROTECTION OF GMAC SECURITY. We shall appear in and defend any action or proceeding which may affect the security of GMAC under this Mortgage or result in a violation of paragraph 3 above. if such an action is filed, we violate this Mortgage or Borrowers violate the Agreement, then GMAC may disburse funds and do whatever it believes necessary to protect the security of this Mortgage. In doing so, GMAC shall give us notice bu! it need not tnalce demand or release us from any obligation. To the extent permitted by law, any amounts paid by GMAC under this paragraph ti, including any amounu advances for the payment of Assessments, insurance premiums, or expenses incurred by GMAC by reason of default by any Mortgagor under the Mortgage with FINANCE CHARGES at the variable rate in effect under the Agreement, shall be paid by us upon demand- Until paid by us, such amounts are secured by this Mortgage. GMAC is not required to incur any expense or take any action under this Mortgage and no action taken shall release us from any duty. 7. INSPECTION. Representatives of GMAC may inspect Lhe Property from time to time. Except in an emergency, rMAC must first ive notice r - ---- - - - g spectfymg reasonable cause for .he inspection. BK1906PG3696 Ot/1 a/201 t t 1:05'.32 AM CUMBERLAND COUNTY Inst.# 200516235 -Page 4 ct 10 8. FINANCE CHARGES AFTER END OF ACCOUNT A_t1'D/OR JUDGMENT. To the extent permitted by law, we agree that FINANCE CHARGES after the end of the Account and/or after a judgment is entered shall continue to accrue at the rates and in the manner specified in the Agreement 9. OUR CONTINUIiVG DUTIES AND GMAC'S RIGHTS; SURRENDERS OF RIGHTS. To the extent permitted by law, for otnselves and ow successors, we hereby sturender the benefit of all homestead, dower, cttrtesy, appraisement, vahration, redemption, reinstatement, stay, extension, exemption and moratorium laws now existing or hereafter enacted and any right to have the Property marshalled upon any foreclosure. This surrender does not extend to any rights we may have under the Pennsylvania Loan Interest and Protection Law or the Pennsylvania Secondary Mortgage Loan Act. We further agree that any court having jurisdiction to foreclose may order the Property sold as an entirery. No surrender of any GMAC right under the Credit Documents shall release or limit otu liability, Borrower's liability or that of any person who subsequently becomes subject to our duties or Borrowers duties (a "successo>•'), nor shall any such surrender affect the claim or priority of this Mortgage. GMAC shall not be required to start proceedings against any successor or modify payment terms by reason of any demand made by us or any successor. No GMAC act or failure to act shall constitute a surrender of any right tinder this Mortgage. All surrenders of rights must be in writing and signed by GMAC; they shall apply only to t]re extent and with respect to the event specified in the writing. Obtaining iaztrrance, or paying taxes or other claims or charges shall not be a surrender of GMACs right to demand payment at once of the sums secured by this Mortgage in the event of a default under the Credit Documenu. l0. SUCCESSORS AND ASS]GNS; JOINT AND SEVERAL LIABILITY; CO-S]GNERS. This Mortgage shall bind us and our respective successors and assigns for the benefit of GMAC and any persons or entities that subsequently become entitled to GMAC's rights. All agreements made by us or any successor or assign are "joint and several," which means that they may be enforced against each of us or any successor or assign. Any Signer who does not sign the Agreement (a} is co-signing only to mortgage that person's interest in the Property and w release all marital rights in the Property, (b) is not personally liable under the Credit Documents, and (c) agrees that GMAC and any Signer may modify either Credit Document, without consent and without modifying their interests under this Mortgage. ] 1. NOTTCES. All notices sha11 be in writing. Except where applicable law requires otherwise: (a) GMAC notices shall be hand delivered or mailed by first class, registered or certified mail to the address of the Property or to such other address specified by the addressee in a written notice given to GMAC. Any GMAC notice shall be considered given on the day it is deposited in the U.S. mail or is hand-delivered. (b) Our notices shall be mailed to GMAC by first doss, registered or certified mail to the address for Stich notices specified on ottr most recent monthly statement under the Agreement or to such other address specified by GMAC in a written notice given to tu. Any such notice shall be considered given on the day it is received by GMAC. BK1906PG3697 Ot/~4/20tt >>-05:32 AM CUMBERLAND COUNTY hst.# 2005'16235 -Page 5 of t0 12. GOVERNING LAW. This Mortgage will be governed by federal and Pennsylvania law. if anv provision is invalid, illegal, or unenforceable, this Mortgage shall be interpreted as if such provision had never been included. 13. COPIES. We shall receive copies of the Credit Documents and any other documents we sign at the time they are signed or after this Mortgage is recorded. ]4. EXERCISIlVG REMEDIES. GMAC may exercise all of the rights and remedies provided by the Credit Documents or law, and any of these rights and remedies may be exercised individually or together, once or a numbea of Ames. The parties to this document are subject to the provision for Arbitration a_t set forth in the Agreement which is incorporated by reference as if set forth at length herein. 15. EVENTS OF DEFAULT. fa) The events set forth in paragraph 15(b) are Events of Default if and when GMAC gives any Signer notice of default We agree to notify GMAC promptly upon the happening of any event that would be an Event of Default under either Credit Document upon the giving of notice by GMAC. (b) After giving notice of default, GMAC may end the Account and/or demand repayment at once of the Total Balance Outstanding in any of the following events: (i) There: has been fraud or material misrepresentation by any Signer in connection with the Account; (ii} Borrowers have failed to meet the repayment terms of the Agreement for any amount outstanding; or (iii) Any action or inaction by any Signer has adversely a$ected the Property or any right of GMAC in the Property; to the extent permitted by law, this will include, but not be limited to, any Signer (or any legal representative or successor of any Signer) ageeing to sell, transfer or assign or selling, transferring or assigning any interest in the Property, without the prior written consent of GMAC. (c} Notwithstanding any language in this Mortgage to the contrary, GMAC will not give notice of default unless permiried by applicable law and GMAC will give us any gate period, right to cure and/or reinstatement right required by applicable law. This paragraph 15 is intended to give GMAC all rights permitted by applicable law. 16. REMEDIES. IF BORROWERS DO NOT REPAY AT ONCE THE TOTAL BALAT~iCE OUTSTANDING WHEN DUE, GMAC MAY EXERCISE ANY REMEDY AVAILABLE TO TT UNDER APPLICABLE LAW, IlVCLUD~IG FORECLOSURE. 17. APPOINTA~.NT OF RECEIVER Upon an Event of a Default or our failure to pay taxes assessed against the Property and/or inci,rance premiums on the Property (which we agee shall constitute waste), GMAC shall be entitled to the appointrnenl of a receiver if permitted by law. BK1906Pt~3698 OViol20~ ~ 11:05:32 AM CUMBERLAND COUNTY Inst.# 2D05t6235 - Page 5 0' 10 18. SATISFACTION OF MORTGAGE. Upon payment and discharge of all sutns secured by this Mortgage and termination of the Account, this Mortgage shall be void and GMAC shall (a) satisfy this Mortgage, (b) mark the Agreement "paid in fittl" or "canceled" and return it to us, and (c} file a discharge or release. 19. REQUEST FOR NOTICES. GMAC requests that copies of notices of default, sale and foreclosure from the holder of any claim which has priority over this Mortgage and copies of any Notices under Section 8143 of title 42 of the Pennsylvania Consolidated Statutes be sent to GMAC at 100 Witmer Road, Horsham, PA 19044-09b3. 20. EXHIBTTS, SCHEDULES AND RIDERS, ETC. The terms of any Exhibit, Schedule or Rider attached to this Mortgage or executed and recorded with this Mortgage shall be treated as if fully set forth in this Mortgage. All of the terms of the Agreement are made part of this Mortgage. 21. TIME OF ESSENCE. Time is of the essence in this Mortgage. 12. ACTUAL KNOWLEDGE. For purposes of the Credit Documents, GMAC shall not be deemed to have actua] knowledge of any fact until it actually receives notice as set forth in paragraph 1 l or until it receives written notice thereof from a source GMAC reasonably believes to be reliable. The date of receipt shall be determined by reference to the "Received" date stamped on such written notice by GIvIAC or its agent 23. EXPENSES OF LITIGATION. To the extent autbori2ecl by law, we shall pay GMAC its anoroeys fees in the event GMAC must refer the Account for collection. We shall also pay GMAC, to the extent authorized by law, any additional expenses incurred in the sale of the Property in foreclosure proceedings or upon the entry of a judgment. Until paid by us all such amounts provided for in this Paragraph 23 are secured by this Mortgage. 24. CAPTIONS; GENDER; ETC. The headings in this Mortgage are not to be used to interpret or define its provisions. Ln this Mortgage, the masru]ine gender includes the f~+inine and/or neuter, singular numbers include the plurals, and p]uraLs include the singular. 25. ASSIGNMENT OF RENT'S; RECEIVERS; GMAC POSSESSION OF THE PROPERTY. As additional security, we hereby assign to GMAC any rents due on the Property after an Event of Default or abandonment of the Property. In any action to foreclose this Mortgage, GMAC shall be eutiiled to the appointment of a receiver. if an Event of Default occurs or we abandon the Property, GMAC, without notice, may enter upon, take possession of, and manage the Property. GMAC may then collect or sue in its own name for any rents due on the Property. All rents so collected shat] be applied first to payment of the reasonable costs of operation and management of the Property (such as collection costs, receiver's fees, bond premiums and attorneys' fees) and then to the Total Balance Outstanding. GMAC and the receiver must account only for rents actually received. BK i 906FG3699 07na/2U1~ ~rU5:32 AM CUMBERLAND COUNTY Inst.# 200516235 - Fage 7 0l 1U Acts taken by GMAC under this paragraph 25 shall not cure or waive any Event of Default or invalidate any act done pursuant to notice of default. We will not, without the written consent of GMAC, receive or collect rent from any tenant on the Property more than one month in advance. Upon an Event of Default, we will pay monthly in advance to GMAC or any receiver the fair and reasonable rental value of the Property or that part of the Property in otu possession. If we fail to pay such rent, we will vacate and surrender the Property to GMAC or to such receiver. We may be e~~cted by summary proceedings. 26.ME3LS. Borrower understands and agrees that MFRS holds only legal title to the interests granted by Borrower in this Mortgage, but, if necessary to comply with local !aw or custom MERS (as nominee for GMAC and GMAC's successors and assigns) has the right to exercise any ar all of these interests, including, but not limited to, the right to foreclose and sell the property; and to take any action required of Lender including but not limited to, releasing and canceling this Mortgage. By signing this Mortgage, we agree to all of the above. WITNESSES: M TGAGOR Joseph .liras MORTGAGOR MORTGAGOR MORTG R (.~ M TGAGO tb . BreIIos MORTGAGOR 1 btrcby certify chat the praise address of GMAC Mortgage Corporation (Mortgagee) is 100 Witmer Road, Horsham, PA 19044-0963. On b f of the Murtg gee: t3y Title: ~ LJ / BK190i~PG3700 Oi~-~5~20~ ~ 1'1:05:32 AM CUMBERLAND COUNTY Inst.# 200516235 -Page 8 of 10 COMMONWF_A]_TH OF PENNSYLVANIA SS COUNTY OF • ~~ _ On this, the ~_ day of /'mil ~00 5 before rne, a Notary Public of the Commonwealth of Perutsyly a, personally appeared Joseph E. Jiras Atbena J Brcgos who, I am satisfied, is (are) the person(s) who executed the foregoing instrument, and thereupon (s)he (they) aclmowlcdged that (s)he (they) signed, sealed and d°livered he same as (her) his (thou) a and deed. ~~ Notary Public of th ommonwealth of Pennsylvania My Cornmission Expires: co+~MONwEN,rH of PE~r+snv~r,u NOTARIAL SEJ1L CHERYL A. SWARTZ, Nobry p~ Sus wh~nna TMrp,, Dauph~ C ~ ~ e, zo B~ 190b~'G370 0~/1a120ii 11.05:32 AM CUMBERLAND COUNTY Inst.it200576235-Page90li0 SCHEDULE "A" PARCEL NO. 01-21-0271-1358 ALL THAT CERTAIN tract of land situate in Camp Hiil Borough, Cumberland CGUnty, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the notthem line of Lincoln Street, formerly Berkley Street, on the dividing line between Lots 156 and 157 on the hereinafter mEntioned plan of lois; thence in a westerly direction along the northern line ofi Lincoln Street, a distance of 60 feet to a point on the dividing line between Lots 158 and 1 b9 on said plan; thence in a northerly direction abng said dividing line between Lots 158 and 159, a distance of 100 feet to a point on the southem line of Lot 179 on said plan; thence in an easterly direction along the southem line of Lot 179 and Lo# 180 on said plan, a distance of 60 feet to a point on the dividing line between Lots 156 entl 157 on said plan; thence in a southerly direction along said dividing line between Lots 166 and 157 on said plan, a distance of 100 feet to a point on the northern pne of LI'ncoln Street afon~aid, the point and place of BEGINNING. BEING Lots Nos. 157 and 158 on the plan of Camp Hlq Estates as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 1, Page 90. HAVING thereon ereded a single family dwelling house known and numbered as 2014 Lincoln Street. UNDER AND SUB.lECT, nevertheless, to all conditions, restrictions, easements and rsghts of way of prior record. .~.. r, .~.r of [.?~~_'(]c Ot/t4/2Utt tt:05:32AM BK 190b~G~702 Ins1.1! 200516235 • Fage 10 of 10 Date: November 28. 2012 Joseph Jiras 2014 Lincoln Street Camp Hill, PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached a es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800=342-2397 (persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representative at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. the local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Joseph Jiras and Athena J. Brellos PROPERTY ADDRESS: 2014 Lincoln Street, Camp Hill, PA 17011 LOAN ACCT. NO.: 101002005-RC ORIGINAL LENDER: Mortgage Electronic Registration Systems, Inc. MERS as nominee for GMAC Mortgage Corporation CURRENT LENDER/SERVICER: Partners for Payment Relief DE III, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVER YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: *IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, *IF YOU HAVE A REASONABLE PROSECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS AND, *IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOU MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCY- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the p~erty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your ]ender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance. are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date) NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 2014 Lincoln Street, Camn Hill, Pennsylvania 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payments of $352.09 from 9/20/07 to 11/20/12 $21,125.40 Late Charges and Other Charges $1,056.00 Total $22,181.40 TOTAL AMOUNT PAST DUE: $22,181.40 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $22,181.40 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Partners for Payment Relief DE III, LLC c/o KERNS, PEARLSTINE, ONORATO & HLADIK, LLP 298 WISSAHICKON AVENUE P.O. BOX 1489 NORTH WALES, PA 19454 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the creditor begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30 DAY period, you will not be required to pay attorne 's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, oy u still have the right to cure the default and prevent the sale at an time up to one hour before the Sheriff s Sale. You may do so by paving the total amount then past due plus anv late or other char es then due, reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by~erforming an other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: Partners for Payment Relief DE III, LLC Address: Pa ents: 3748 West Chester Pike, Suite 103, Newtown Square, PA 19073 Correspondence: 3748 West Chester Pike, Suite 103, Newtown Squaze, PA 19073 Phone number: 888-879-4997 Contact uerson: Matthew Kadash EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that al] the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. _TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. _TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR-) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE. YOU MAY HAVE TO SUCH ACTION BY THE LENDER. _TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). CERTIFIED MAIL RETURN RECEIPT REQUESTED FIRST CLASS MAIL Pathstone Corporation Pennsylvania '..Clinton County 1625 North Second St *CCCS of Northeastern PA Harrisburg PA 1'7102 717.234.6616 202 W Hamilton Ave; Hamilton Sq Plaza State College PA 16801 Philadelphia Council for Community Advancement 800.922.9537 ! 800.922.9537 (PCCA) 1617 JFK Blvd; STE 1550 Philadelphia PA 19103 215.567.7803 Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia PA 19107 215.985.3220 Clarion County *CCCS of Western PA 2403 Sidney St; STE 400 Pittsburgh PA 15203 888.511.2227 / 888.511.2227 Butler County Homeownership Program 114 Woody Dr Butler PA 16001 724.287.6797 Clearfield County *CCCS of Northeastern PA 202 W Hamilton Ave; Hamilton Sq Plaza State College PA 16801 800.922.9537 ! 800.922.9537 *CCCS of Northeastern PA -Pittston a01 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 *CCCS of Western PA 917A Logan Blvd Altoona PA 16602 888.511.2227 / 888.511.2227 Central PA Community Action, Inc. 207 E Cherry St; PO Box 792 Clearfield PA 16830 814.765.1551 Indiana County Community Action Program, Inc. 827 Water St Indiana PA 15701 724.465.2657 Pathstone Corporation Pennsylvania 1625 North Second Si Harrisburg PA 17102 717.234.6616 *CCCS of Northeastern PA -Pittston 401 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 Step, Inc. (a.k.a. Lycoming-Clinton Counties Commission for Community Action) 2138 Lincoln St Williamsport PA 17701 800.346.3020 / 570.326.0587 Columbia County *ACCI-American Credit Counseling Institute -Nescopeck 212 Berwick-Hazleton Hwy Nescopeck PA 18635 888.212.6741 / 888.468.8847 *CCCS of Northeastern PA -Pittston 401 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 *Commission on Economic Opportunity 165 Amber Lane Wilkes-Barre PA 18702 570.826.0510 Crawford County --~ *CCCS of Western PA -Northwest 4402 Peach St; Lower Level Erie PA 16509 888.511.2227 / 888.511.2227 Center for Family Services, Inc. 213 W Center St Meadville PA 16335 814.337.8450 Warren-Forest Counties ~ Economic Opportunity Council (EOC) 1209 Pennsylvania Ave, West Warren PA 16365 800.231.1797 / 814.726.2400 _Cumberland County *CCCS of Western PA 114 N Hanover St Carlisle PA 17013 888.511.2227 ~ ---- - NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 8/15/2012 8:59:38 AM Page 5 of 16 'CCCS of Western PA 'CCCS of Delaware Valley dlbla Clarifi -Media 55 Clover Hill Road 280 N Providence Rd Dallastown PA 17313 Media PA 19063 888.511.2227 ! 888.511.2227 800.989.2227 ! 215.563.5665 Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717 232.9757 Harrisburg Fair Housing Council 2100N6thSt Harrisburg PA 17110 717.238.9540 Housing 8 Redevelopment Authority -Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717234.6616 Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 Dauphin County `CCCS of Western PA -Greater Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg PA 17110 888.511.2227 / 888.511.2227 Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 ~ Delaware County ~ 'ACCT-American Credit Counseling Institute 6800 Market St; 1st Floor Upper Darby PA 19082 888.212.6741 / 888.212.6741 'American Angel Housing Gounseling-RHD 1060 First Ave; STE 400 King of Prussia PA 19406 610.768.2611 'CCCS of Delaware Valley d!b!a Clarifi -Philadelphia 4400 North Reese St Philadelphia PA 19140 800.989.2227 / 215.563.5665 `CCCS of Delaware Valley d/bla Clarifi -West Chester 770 E Market St; STE 190 West Chester PA 19382 800.989.2227 ! 215.563.5665 `Credit Counseling Center 832 Second Street Pike Richboro PA 18954 215.348.8003 'Credit Counseling Cen±er 8150 Route 13 Levittown PA 19057 215.348.8003 Chester Community Improvement Project 412 Ave of the States Chester PA 19013 610.876.8663 Diversified Community Services @ Dixon House 1920 S 20th St Philadelphia PA 19145 215.336.5505 Genesis Housing Corporation 208 DeKalb St; #212 Norristown PA 19401 610.275.4357 Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia PA 19104 215.386.1298 Korean Community Development Services Center 6055 N 5th St Philadelphia PA 19120 215.276.8830 Liberty Resources, Inc. 714 Market St Philadelphia PA 19106 215.634.2000 Media Fellowship House. Inc. 302 S Jackson St Media PA 19063 610.565.0434 --- NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 8/15/2012 8:59:38 AM Page 6 of 16 ~ 1• • • ~ fl_1 m m - I~ Postage $ .~ C:edilieo Fee n.l O Return Receipt Fee p (Endorsement Required) -°----- - ~ ~ Postmark ~H~re .,_ O ---- Restricted Delivery Fee ~ (Endorsement Required) r~ __ ~~~ l~ rntal POSiaC7e c~. FeeS ~~ _- ~ ._T___._._._ I sent To --"" ('LJ ~~ T ._..~.~~ ~.P.......~...:...._._~-s--------------------- ~ Street, Apt. Nn.: ~ or PO FJox No. ~~~_ Cily, State, T_ + ~ ~ - :rr r. Date: November 28. 2012 Athena J. Brellos 20 ] 4 Lincoln Street Camp Hill, PA 1701 l ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the wort a e on our home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM EMAP ma be able to help save vour home. This notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency The name, address and phone number of Consumer Credit counseling Agencies serving vour County are listed at the end of this Notice If you have any questions, you may call the Pennsylvama Housing Finance Agency toll free at 1-800=342 2397 (persons with impaired hearing can call (717) 780-1869 This Notice contains important legal information. If you have any questions, representative at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. the local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO r "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Joseph Jiras and Athena J. Brellos PROPERTY ADDRESS: 20 ] 4 Lincoln Street, Camp Hill, PA 1701 l LOAN ACCT. NO.: 101002005-RC ORIGINAL LENDER: Mortgage Electronic Registration Systems, lnc. MERS as nominee for GMAC Mortgage Corporation CURRENT LENDER/SERVICER: Partners for Payment Relief DE III, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVER YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: *IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, *IF YOU HAVE A REASONABLE PROSECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS AND, *IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOU MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCY- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling_~agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out; sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT Bring it un to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 2014 Lincoln Street, Camp Hill, Pennsylvania 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payments of $352.09 from 9/20/07 to 11/20/12 Late Charges and Other Charges $21,125.40 $1,056.00 Total $22,181.40 TOTAL AMOUNT PAST DUE: $22,181.40 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $22,181.40 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DiJRING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or moneyorder made payable and sent to: Partners for Payment Relief DE III, LLC c/o KERNS, PEARLSTINE, ONORATO & HLADIK, LLP 298 WISSAHICKON AVENUE P.O. BOX 1489 NORTH WALES, PA 19454 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30j DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the creditor begins legal proceedings against you; you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you; you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, oy u still have the right to cure the default and~revent the sale at any time up to one hour before the Sheriff's Sale You may do so by paving the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: Partners for Payment Relief DE III, LLC Address: Payments: 3748 West Chester Pike, Suite 103, Newtown Square, PA 19073 Correspondence: 3748 West Chester Pike, Suite 103, Newtown Square, PA 19073 Phone number: 888-879-4997 Contact person: Matthew Kadash EFFECT OF SHERIFF`S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. • • YOU ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. _TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, _TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU -MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). CERTIFIED MAIL RETURN RECEIPT REQUESTED FIRST CLASS MAIL r Pathstone Corporation Pennsylvania CllntOn COUnty 1 1625 North Second St *CCCS of Northeastern PA Harrisburg PA 17102 202 W Hamilton Ave; Hamilton Sq Plaza 717.234.6616 State College PA 16801 Philadelphia Council for Community Advancement 800.922.9537 / 800.922.9537 (PCCA) 1617 JFK Blvd; STE 1550 Philadelphia PA 19103 215.567.7803 Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia PA 19107 215.985.3220 Clarion County *CCCS of Western PA 2403 Sidney St; STE 400 Pittsburgh PA 15203 888.511.2227 / 888.511.2227 Butler County Homeownership Program 114 Woody Dr Butler PA 16001 724.287.6797 Clearfield County -.J *CCCS of Northeastern PA 202 W Hamilton Ave; Hamilton Sq Plaza State College PA 16801 800.922.9537 1800.922.9537 *CCCS of Northeastern PA -Pittston 401 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 *CCCS of Western PA 917A Logan Blvd Altoona PA 16602 888.511.2227 1888.511.2227 Central FA Community Action, Inc. 207 E Cherry St PO Box 792 Clearfield PA 16830 814.765.1551 Indiana County Community Action Program, Inc 827 Water St Indiana PA 15701 724.465.2657 Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 171D2 717.234.6616 *CCCS of Northeastern PA -Pittston 401 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 Step, Inc. (a.k.a. Lycoming-Clinton Counties Commission for Community Action} 2138 Lincoln St Williamsport PA 17701 800.346.3020 ! 570.326.0587 Columbia County 1 `ACCT-American Credit Counseling Institute -Nescopeck 212 Berwick-Hazleton Hwy Nescopeck PA 18635 888.212.6741 1888.468.8847 *CCCS of Northeastern PA -Pittston 401 Laurel St Pittston PA 18640 800.922.9537 / 570.602.2227 *Commission on Economic Opportunity 165 Amber Lane Wilkes-Barre PA 18702 570.826.0510 Crawford County --~ *CCCS of Western PA -Northwest 4402 Peach St; Lower Level Erie PA 16509 888.511.2227 t 888.511.2227 Center for Family Services, Inc. 213 W Center St Meadville PA 16335 814.337.8450 Warren-Forest Counties I Economic Opportunity Council (EOG) 1209 Pennsylvania Ave, West Warren PA 16365 800.231.1797 / 814.726.2400 Cumberland County -~ 'CCCS of Western PA 114 N Hanover St Carlisle PA 17013 888.511.2227 NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 8115/2012 8:59:38 AM Page 5 of 16 'CCCS of Western PA 'CCCS of Delaware Valley dlbla Clarifi -Media 55 Clover Hill Road 280 N Providence Rd Dallastown PA 17313 Media PA 19063 888.511.2227 1888.511.2227 800.989.2227 ! 215.563.5665 Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing 8 Redevelopment Authority -Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 ! 717.249.0789 Pathstone Corporation Pennsylvania 1625 North Second Si Harrisburg PA 17102 717.234.6616 Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 Dau hin Count 'CCCS of Western PA -Greater Harrisburg 2000 Linglestown Rd; STE 302 Harrisburg PA 17110 888.5112227 / 888.511.2227 Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 Delaware County `ACCT-American Credit Counseling Institute 6800 Market St; 1st Floor Upper Darby PA 19082 888.212.6741 / 888.212.6741 "American Angel Housing Counseling-RHD 1060 First Ave; STE 400 King of Prussia PA 19406 610.768.2611 *CCCS of Delaware Valley dlbla Clarifi -Philadelphia 4400 North Reese St Philadelphia PA 19140 800.989.2227 ! 215.563.5665 'CCCS of Delaware Valley dlb/a Clarifi -West Chester 770 E Market St; STE 190 West Chester PA 19382 800.989.2227 ! 215.563.5665 "Credit Counseling Center 832 Second Street Pike Richboro PA 18954 215.348.8003 'Gredit Counseling Center 8150 Route 13 Levittown PA 19057 215.348.8003 Chester Community Improvement Project 412 Ave of the States Chester PA 19013 610.876.8663 Diversified Community Services @ Dixon House 1920 S 20th St Philadelphia PA 19145 215.336.5505 Genesis Housing Corporation 208 DeKalb St; #212 Norristown PA 19401 610.275.4357 Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia PA 19104 215.386.1298 Korean Community Development Services Center 6055 N 5th St Philadelphia PA 19120 215.276.8830 Liberty Resources, Inc. 714 Market St Philadelphia PA 19106 215.634.2000 Media Fellowship House, tnc. 302 S Jackson St Media PA 19063 610.565.0434 ~_ NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you- Report last updated: 8/15/2012 8:59:38 AM Page 6 of 16 .+ .- ~ ~ •. t.n .. ~ ru m m ~ p _ ' Postage ~A Certified Fee ~~_- '~~' '~ =:=postmark ~ p , Return Receipt Fee ~ red) ~ R Here p _~_ equ (F_ndorsemenl ~ Restricted Delivery Fee (F_ndorsement Required) p r~ p Q 'total Postage R Fees 4, _ rl flJ -- Sons Ta _ ~-J------ ~ - :.-----•----------- a ~ ~ -- ---- Stroet, Apt. No.; ar PO Dox No. ~--- ------ _ . ----•--•-----=- - n n ._ - - - 1 /~ i t • ~ ., Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA i~oi3 Ph: ~~.z4o.639o Fx: ~i~.a4o.6397 ~ Plaintiff/s: Court Number: ~ PARTNERS FOR PAYMENT RELIEF DE III, LLC Expiration Date: Type of Action: MORTGAGE FORECLOSURE Defendant/s: JOSEPH E. JIRAS,1111 AND ATHENA J. BRELLOS, Serve Upon: JOSEPH E.JIRAS, III Address for Service: 2014 LINCOLN STREET CAMP HILL State PA 17011 Alternate Address for for Service: N/A Type of Service: State AR (X Adult in Charge {X Personal (~ Deputize (- Certified Mail (~ Posting **Copy of Court Order Required with Posting** Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: STEPHEN M. HLADIK, ESQUIRE Address: KERNS, PEARLSTINE, ONORATO &HLADIK, LLP 298 WISSAHICKON AVENUE NORTH WALES State PA 19454 Phone Number: +1 (215) 855-9521 ~ ~, Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA i~oi3 Ph: ~i~.z4o.639o Fx: ~i~.a4o.6397 Plaintiff/s: Court Number: PARTNERS FOR PAYMENT RELIEF DE III, LLC Expiration Date: Type of Action: MORTGAGE FORECLOSURE Defendant/s: JOSEPH E. JIRAS, IIII AND ATHENA J. BRELLOS, Serve Upon: gTHENA J. BRELLOS Address for Service: 2014 LINCOLN STREET CAMP HILL ~ State PA 17011 Alternate Address for for Service: N/A State AR Type of Service: (X Adult in Charge rX Personal r Deputize (- Certified Mai] ~-~` Posting **Copy of Court Order Required with Posting*' Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: STEPHEN M. HLADIK, ESQUIRE Address: KERNS, PEARLSTINE, ONORATO &HLADIK, LLP 298 WISSAHICKON AVENUE NORTH WALES State PA 19454 Phone Number: +1 (215) 855-9521 r ~' 4 Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA i~oi3 Ph: 7i~.a4o.639o Fx: ~i~.z4o.6397 Plaintiff/s: Court Number: ~~~"" PARTNERS FOR PAYMENT RELIEF DE III, LLC Expiration Date: Type of Action: MORTGAGE FORECLOSURE Defendant/s: JOSEPH E. JIRAS, (III AND ATHENA J. BRELLOS, Serve Upon: TENANT /OCCUPANT Address for Service: 2014 LINCOLN STREET CAMP HILL Alternate Address for for Service: N/A Type of Service: rX Adult in Charge r Special Service Instructions: Filing Attorney: N State PA 17011 ____ ~~ State AR Personal r Deputize (-' Certified Mail ~ Posting **Copy of Court Order Required with Posting** *If service is to be made by deputized service to another county please specify which county" ame. (STEPHEN M. HLADIK, ESQUIRE Address: KERNS, PEARLSTINE, ONORATO &HLADIK, LLP 298 WISSAHICKON AVE NORTH WALES State PA ~- 19454 Phone Number: +1 (215) 855-9521 Q1.{118.I7_o13 1Q:10 KERMS.PEARLSTIME,ONORATO&HLADlK r~PJC}' 2'S""~~a!~1,?' P.002/009 Partnez•s for Payment Relief DE III, LLC, Plaintiffls) vs. Joseph E;. Jiras, III and Athena J. Brel~oa, Defendant(s) FARM 1 t c„.~ ~ ~ - ---~ IN THE COURT OF COMMCiM PLEA,;i C)F ~ -c~ ~'' -^,-: ~ CUMBERLAND COUNTY, PEWIVSYLVAPJ'A r+'st.,.j c... ~~ , -. T ,s ','=; _" . Zt,,,, t ; ':.:.~ ~ - Y is ~ ~ ~ t°~ _` Z~ y ~ w..tr. ~ ~ _ Civl I ~ .__i y NOTICE OF RESIDENTIAL MORTG4GE POREC~OSURE DIVERSION PROGRAM Yau have been served with a foreclosure complaint that could cause you t0 lose your hom e. If you own and Ilve In the residential property which Is the subject of this foreclosure action, you may be able to participate In a court-supervised contiliation Conference In an effort to resolve this matter with your lender. If you do not have a lawyer you must tak® the following steps to be ellglbls for a conciliation conference. First within twenty (20) days of your receipt of this notice, you roust contact MldPenn Legal Servlees at (717)243.9400 extension 2530 or (g00) 82Y-5288 extension 2510 and request appelntmr!nt 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 I~repared on your behalf. If you and your legal representative complete a flnandal worksheet In the format attached hereto, ~~e legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be flied with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference Is scheduled, you will have an opportunity to meet with a representative of your lender In an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take tiho following steps to be e)Iglble for a conclllatlon conference. It fs not necessary for you to contact Mlcit'enn 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 lawyv complete a fnancial worksheet In the format attached hereto, your lawyer w11t prepare and file a Request for Conciliation Conference with the Court, which must be flied with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conclllatlon conference is scheduled, you will have an oppoRUnlty to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suet proceeds forward. IF YOL/ WISH TO SAVE YOUR HOME, YOV MUST ACT QV/CKLY AND TAKE THE STEPS REQV/RBD BY TH/S NOTICE. THIS PROGRAM /S FREE. i Respec y fled: I Date Slgn ure o unsel for Plaintiff 01 !0812013 10:10 KERMS,PEARLSTIME,ONOR,~TO~HLADiI~ (FNf)' 2' S X55 !9~?t P.0031009 _FS~M.2. Cumbor/and Gounty Rasldont/el A~Jo.rtQaya Foroclosure D/verslon Program F/nanc/al' Worksheet Date Cumberland County Court of Common Pleas Docket ~I BORROWER REQUEST FOR HARDSHIP ASSISTANCE 7o complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your _ Please provide the following information to the best of your knowledge: Borrower name (s): Property Address: ~_ City: _ Is the property for sale? Yes D oNoN Realtor Name: Borrower Occupied: Yes ^ No ^ Melling Address (If different) City: Phone Numbers: Home• Email: # of people In household: Listing d~~te:. Celli State: 21p: Price: $ Reator Phone: State: Zip: Office: Other: How Melling Address: City: ~ State: Zip; Phone Numbers: Home: ,_, Office: _... _... ... .. _ .... _.. - CeIL• Other: t~tratl. _. # of people 1n household: r. How lona~ _ First Mortgage Lender: Type of Loan: Loan Number: ~ Pete You Closed Your Loen: Second Mortgage Lender: Type of Loan: '~ loan Number; Total Mortgage Payments Amount: S __, 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: 10:10 KERNS,PEARLSTINE,ONOR,ATO~HLA~DIK 1~A)t)' ~' ~5 ^5 ~~~? P.004/009 csssu~ emouni uwea• Home: $ Other Real Estate: $ Retirement Funds: S Investments: $ Checking: $ Savings: $ Other: $ Automobile tl? ;Model; Amount owed: Autorn_ ob_Ile#2: Model: Amount owed: Other transoortatlon (a~MOmobiles boats, motorcycles Year: Amount owed: >laonthly Income Name of Employers: i. 2, 3. Additlonal Income Description (not wages): 1. 2. Borrower Pay Days: Value: -------- S S - Year: Value; - Year: balue: 1: Model• _ Value: Monthly Gross __ Monthly Net Monthly Gross Monthly Net_ Monthly Grass Monthly Net Monthly Amount: Monthly .Amount: Co-Borrower Pay Days: Monthly xnenses~ IPlease only Incl ~~o exDan3eS VAII IIrP ~urrenNu n~u~ws1 EXPENSE M AMOUNT EXPENSE AMOUNT ortgage Food 2 Mort age Utilities Car Pa ment s Condo/Nel h. Pees Auto Insurance Med. (not Covered Auto fuel/re airs Other Pro .Payment Install. Loan Pa ment CableTV ChHd Su ort All rn. 5 endln Mone Da /Child Care/Tult. Other Expenses Amount Available for Monthly Mortgage Payments f3ase:d an Income and Expenses: Have you been working with a Housing Counseling Agency'r' Yes ^ No ^ If yes, please provide the following Information: Counseling Agency: ~ ~~ Counselor: Phone (Office): i Fax: Email: --"-'- O1.{08,+?_n1S 1Q:1Q KERNS,PEARLSTINE,ONOR~ITO&NI.ADIY. !~la?r~' i'a`~ii?i~' P.005/009 Have you rnade application for HomeoHrners 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 following Inforrnatlon, If know, regarding your lender nr lender's loan servicing company: lender's contact (Name): Phone: Servicing Company (Name): Contact: Phone ~__._ I/We~ _, au~thnrize the above named to use/refer this Information to my lenider/seivi,:er for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provid~:d by the above named Borrower Signature Borrower Signature Date 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 last 45 days v Copy of a current utility bill v letter explaining reason for delinquency and any supporting docuim~antation v (hardship letter) listing agreement (If property is currently on the market) ~ Copy of 2 years of federal income tax returns V Copy of deed 01/0$/2015 10:10 KERMS,PEARLSTIME,OMOR~,TO~HLt~DIK (~{1X}~ i'~i °;i:a ~ ii' P.006/009 Partnersfor Payment RE:l:r,ef DE III, IrLC,, Plaintiff{s) vs. Joseph E. Jiras III and Athena J. Bxellos, Defendant(s) FC-RM 3 IN THE COURT OF COMMCil1i PLEA:. (:~F CUMBERLAND COUNTY, PENIJSYWANIP. REQUEST FOR COIVCIL1AT10N CONFERENCE Ctvll Pursuant to the Administrative Order dated ,_ .2012 goe~erning t;he Cumberland County Residential Mortgage Foreclosure Dl~rerslon 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 Ilves In the subJec~t real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Divers(on Program: and has taken all of the stel7s required in that Notice to be ell,glble to participate In a court-supervised concllfation 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 hifPltl Signature of Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date Date Date 01 t08t2013 10:10 KERMS,PE,ARLSTINE,ONORATO&HLADI~K t~tt>~' 2' ~ "5~ P~'?' P.007t009 Partners for Payment Relief DE III, LLC, Plaintiff(s) vs. Joseph E. Jiras IIland Athena J. Brellos, Defendant(s) IN Tlif: COURT OF COMMON PLEA,;i OF CUMBERLAND COUNTY, PENNSYLVANIA Clvll CASE MANAGEMENT ORDER AND NOW, this day of 2D ,the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has compiled with the Administrative Rule requirements for the scheduling of a Conciliation Conference, It Is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in acourt-supervised conclllatlon Conference on _ at r,~' M. In - at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conclllatfon Conference, the defendant/borrower must serve upon the Plaintiff/fender and Its counsel a copy of the "Cumberland County Resldentl:al Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which hats been completed by the defendant/borrower. Upon agreement of the parties In writing or 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 _~~ ~, ., .~:... .. ^:? 1 K'ERMS,PEARLSTINE,ONORATO&HLADIK p.008/009 Court of the defendant/borrower's failure to serve the completed i-orm 2 with the time frame set forth herein or such other date as agreed upon by the t~artl~es In writing or ordered by the Court, the case shall be removed from the Conclllz~tlon Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conclllatlon Conference in person and an authorized representative of file plalntlff/lender must either attend the Conclllatlon Conference In person or be available by telephone during the course of the Conclllatlon Conference, The representative of the plalntlff/lender who participates in the Conclllatlon Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the alaintiff/lender must discuss resolution proposals with the au~thorized representative in advance of the Conclllatlon Conference. If the duly authorized representative of 1:he plaintiff/lender is not available by telephone during the Conciliation Conference, ~~he court will schedule another Conciliation Conference and require the personal ~~ttendance of the authorized representative of the plalntlff/lender at the rescheduled Conclllatlon Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to cllscuss and explore all available resolution options which shall Include: bringing the rortgage 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 Iri the near future in exchange for not contesting the matter; offering the lender a deed in Ileu of foreclosure; ~~~ ' ^:~ 1 KERf~S,PEARLSTINE,ONORATO&HLADIK FNS}' ~':~ "5 ~ ^S?' ?.009/OOQ entering Into a loan modification or a reverse mortgage; paying the r.•~urt13age default over sixty months; and the institution of bankruptcy proceedings~ S. All proceedings in this matter are stayed pending the completion o1~ the scheduled conciliation conference. BYTHE COURT, J. PEARLSTINE, ONORATO & HLADIK, LLP w-> KERNS , STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINF ATTORNEY I.D. NO. 66287 n WILLIAM E. MILLER, ESQUIRE mar= ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue ° P.O. Box 1489 r :° C) North Wales, PA 19454 t' (215) 855-9521 PARTNERS FOR PAYMENT RELIEF COURT OF COMMON PLEAS OF DE III, LLC, CUMBERLAND COUNTY, PA Plaintiff v. JOSEPH E. JIRAS, III AND ATHENA J. BRF,LLOS, Defendants NO: 13-127 CIVIL PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: N co w Kindly substitute the annexed Verification to the Complaint filed in the above- captioned docket. Respectfully Submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP Date: BY: Stephen. .M Hladik, Esquire Attorney for Plaintiff VERIFICATION I )6?A'A A y6ZA- i 4rv\., , hereby states that he/she- is an agent for the Plaintiff in this action; that he/she is authorized to and does take this Verification on behalf of said Plaintiff, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of his/4x knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 PA. C.S. §4904, relating to unsworn falsification to authorities. Date: Name: Title: 1.?? ?; S d d. d CC Company: File 4 12-0018 KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, , o (73 ,:) P.O. Box1489 North Wales, PA 19454-1489- (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS Olg- 111, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). PRAECIPE TO ENTER JUDGMENT BY DEFAULT AGAINST DEFENDANT, JOSEPH E.JIRAS,III ONLY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a Default Judgment against Defendant, Joseph E. Jiras, III and in favor of Plaintiff, Partners for Payment Relief DE III, LLC, for failure to answer Plaintiffs Complaint within the time prescribed by Pa. R.C.P. No. 1026 and assess Plaintiffs damages as follows: Amount from Complaint $24,187.56 Additional Interest currently due and owing at 3.25%per annum calculated currently at $1.60 per diem $107.20 TOTAL $� Page 2 of 7 Total damages to be assessed at together with interest at the aggregate daily rate of$1.60 from March 15, 2013, until the date of entry of final judgment, plus interest thereafter on the judgment, at the rate stated in the subject note, plus any costs, expenses, attorneys' fees and all other amounts due and payable under the Note and Mortgage, up through the sale of the mortgaged premises. Respectfully submitted, KERNS, PEARLSTINE, ONO O & HLADIK, LLP Date: 's BY: Stephen M. Hla k, Es uire Attorney for Plat Page 3 of 7 AND NOW, 31�� 2013, Judgment is entered in favor of Plaintiff and against Defendant, Joseph E. Jiras, III, by Default, for want of an Answer, and damages assessed at the sum of as per the above certification. Prothonotary Page 4 of 7 KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box 1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). CERTIFICATE OF SERVICE I, Stephen M. Hladik, Esquire, hereby certify that I served a true and correct copy of the foregoing Praecipe for Entry of Jud er}� y efault and 236 Notice on the following individuals by first class mail on 1� Joseph E. Jiras, III 2014 Lincoln Street Camp Hill, PA 17011 By: Stephe ladik, Esquire Page 5 of 7 KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box 1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). STATE OF: PENNSYLVANIA COUNTY OF: MONTGOMERY AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Defendant: Joseph E. Jiras, III Age: Over 18 Residence: 2014 Lincoln Avenue, Camp Hill, PA 17011 Page 6 of 7 Respectfull/su itted, KERNS,PE T ONORATO&HLADIK BY: Step ,Esquire Swn to d subscribed before me this ltk'day of -%2�0 s No Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHUMN M.VINCENT,Notary Pubk I�POW T 1 20 4 Page 7 of 7 Results as of:Mar-15.2013 11:51:35 Department of Defense Manpower Data Center • SCRA 3.0 40 F+u plepmt PursujM to Scrvzcni= crs Civil Relief Act Last Name: JIRAS First Name: JOSEPH Middle Name: Active Duty Status As Of: Mar-15-2013 3W 4 NA NA NA This response re - �'eogYi dlRp ft/itftbeted on tus Date mf NA NA This response reflects dual left ac11v(�; precedito ty Status Date E7rdar NA NA This response reflects whether.;" ur t lies report for active duty x Upon searching the data banks of the Department of Defense Manpower C9eiF�',based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. IMA A f-w-porw 7.Ae�VRANIF Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 .___.._....... ._. The"Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting Sysfem(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 12S58DB1707CVF0 KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). RULE 236 NOTICE To: Joseph E. Jiras, III 2014 Lincoln Street Camp Hill, PA 17011 PURSUANT TO RULE 236, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT HAS BEEN ENTERED AGAINST YOU ON THIS D TE IN THIS ACTION. By: • Deputy Prothonotary Page 1 of 7 '�":?� KEt��"S,PEARLSTINE,ONORATORIiLADIK fcAX;1 215 855 452' P.0021004 f:1'�RRNS,P'T-P.RI.STIN:E, ONORATO &c M ADIK,LLP !i7T;PI-T3N TA. H".ADI K,ESQUIRE ATTORNEY FOR PLAINTIFF ��'CrORlIf'f I.�). NO. 66287 VID.LU�lvl E., �'F::LLE]' ESQUIRE xCI'ORTiuf I.L. NO. 308951 :1.98 Wissahickon Avenue, [1,10. BOXIZ-39, 'North Wales,PA 19454-1489 .(215 8:i f-4521 F'ART,NE:R.S FOR PAYMENT RELIEF DE COURT OF CONSION PLEAS OF III,LLC, CUMBERLAND COUNTY PA 3748 West C:he.,aer Pike ' Suite 10 3 Newtown Squaie,PA 19073, PLAINTIFF V. NO: 2013-127 Civil JOSEPH E.JIRAS,III and ATHENA J. BR.ELL 0S) 2014 Lincoln Street Camp Hill,PA 17011, DEFENDANT(S). NQ'TICE OF INTENTION TO TAKE WYALLL UNDER Pa.ILC.P.237.1 r=QILTANT NOTICE TAD: Joseph E. Jiras,III 2C,14 Lincoln Street Camp Dill,PA 17011 DATE OF NOTICE:February 22,2013 You are is default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment ma:y be entered against you without a hearing and you may lose your property or other importmil rights. You shouuld take this notice 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. 0?12112O'? '4?5'BERN°S,PEARLSTINE,ONORATO&HLAQIK 1,f0,1 V M. P.0031004 if you cannot e.fford to hire a lawyer, this office may be able v) provide you with informaia o n about agencies that may offer legal services to eligible per:ons lit a reduced fee or no tee. CUMBERLAND COUNTY BAR ASSOCIATION 32 S.BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 PURSUA NT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISEE;L THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTnfYTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se;elcuentra en estado de rebeldia por no haber tomado la action requirida de su parte en este cuio. Al no tomar la action debida dentin de un temnino de diez (10) dias de la fecha de a sta notificacion, el tribuna podra, sin necesidad de compararecer usted in torte o escuchar xroulka alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notification a un abogado immediatamente. Si usted no ti,ene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: CUMBERLAND COUNTY BAR ASSOCIATION 32 S.BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 PURSUkIT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE,USED FOR THAT PURPOSE. l'F,RSONS TC WHOM RULE 237.1 NOTICE SENT TO: Joseph E. Jiras,III—2014 Lincoln Street, Camp Hil ,-P. 17011 By: Stephen ladik,Esquire Attorney for Plaintiff 03121/2013 11:?5 KERMS,PEARLSTINE,ONORATO&'HLADIK 9 21 P.0041004 KERNS,PEA RLSIIN E, ONORATO &FILADIK,LLP STEPHEN M[. H[,AI)1K,ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D, NO. 66287 WILLIAM E, NULLER,ESQUIRE ATTORNEY I.G.NO, 308951 29811Viss.ahick-Orl Avenue, P.O.Box 1489, North Wales, PA 194:14.1489 215 855-9521__ _ PARTNERS FOR PEfYMENT RELIEF DE COURT OF COMMON PLEAS OF III,LL(',, CUMBERLAND COUNTY,PA 3748 West Chester P ike Suite 103 Newtown Square,PA 19073, PLAINTIFF NO: 2013-127 Civil V. JOSEPH E.JIRAS,IM and ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill,PA 17011, DEFENDANT(S). CERT(FICATION OF MAILING NOTICE UNDE>3RIlLE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant(s)and to his,her,their attomey of record, if any, iifter the default occurred and at least (10) days poor to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,February 22,2013 to the following Defendants: Joseph E.Jiras,III 2014 Lincoln Street Camp Hill,PA 17011 By: Stephen ' .Hladik,Esquire Attorney for Plaintiff KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454 215 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike, Suite 103 Newtown Square, PA 19073 NO: 13-127 Civil Plaintiff V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, ; - :fie 2014 Lincoln Street Camp Hill, PA 17011, Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the attached Complaint in Mortgage Foreclosure, for service on the Defendant, Athena J. Brellos, in reference to the above-captioned matter Respectfully Submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP Date: 3/19/13 By: Stephen N(_HlaAik, Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED-UFFI" Sheriff OF THE PROTHONOTARY Jody S Smith Chief Deputy 2013 APR 15 AN 9: 24 Richard W Stewart Solicitor OFFICE OF THE SMERIFF CUMBERLAND COUNTY PENNSYLVANIA Partners for Payment Relief DE III, LLC Case Number vs. Joseph E. Jiras(et al.) 2013-127 SHERIFF'S RETURN OF SERVICE 04/10/2013 11:40 AM-Deputy William Cline, being duly swom according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Athena J. Brellos, pursuant to Order of Court by"Posting"the premises located at 2014 Lincoln Street, Camp Hill Borou h, Camp Hill, PA 17011 with a true and correct copy according to law. LIA CLINE, SHERIFF COST: $49.00 SO ANSWERS, 6z X 2X� April 11, 2013 RON RANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft.Inc. KERNS, PEARLSTINE, ONORATO &HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF I11, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, ' '+ PLAINTIFF, „ , JOSEPH E. JIRAS, III AND ATHENA J. <CD '.t;-C--) BRELLOS, :ro CDC 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). PRAECIPE TO ENTER JUDGMENT BY DEFAULT AGAINST DEFENDANT, ATHENA J. BRELLOS ONLY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a Default Judgment against Defendant, Athena J. Brellos and in favor of Plaintiff, Partners for Payment Relief DE III, LLC, for failure to answer Plaintiff's Complaint within the time prescribed by Pa. R.C.P. No. 1026 and assess Plaintiff's damages as follows: . Amount from Complaint $24,187.56 Additional Interest currently due and owing at 3.25%per annum calculated currently at $1.60 per diem $230.40 TOTAL $ 42_ � auk Page 2 of 7 Clc,W-10�q V b�� (�tlAatc=G� �V - q1?. q1, 1 0 Total damages to be assessed at together with interest at the aggregate daily rate of $1.60 from May 31, 2013, until the date of entry of final judgment, plus interest thereafter on the judgment, at the rate stated in the subject note, plus any costs, expenses, attorneys' fees and all other amounts due and payable under the Note and Mortgage, up through the sale of the mortgaged premises. Respectfully submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP Date: 6 13 I BY: Stephen M. H106.ikN, squire Attorney for aintif Page 3 of 7 " AND NOW, I 2013, Judgment is entered in favor of Plaintiff and against Defendant, Athena J. Brellos, by Default, for want of an Answer, and damages assessed at the sum of a7s above certifi ion. Prothonotary Page 4 of 7 KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box 1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF 111, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). CERTIFICATE OF SERVICE 1, Stephen M. Hladik, Esquire, hereby certify that I served a true and correct copy of the foregoing Praecipe for Entry of JudRi ent y Default and 236 Notice on the following individuals by first class mail on 3 Athena J. Brellos 2014 Lincoln Street Camp Hill, PA 17011 By: Stephen M. la A, quire Page 5 of 7 KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). STATE OF: PENNSYLVANIA COUNTY OF: MONTGOMERY AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Defendant: Athena J. Brellos Age: Over 18 Residence: 2014 Lincoln Avenue, Camp Hill, PA 17011 Page 6 of 7 Respectfully submitted, KERNS, PEARLSTINE, ONORATO &HLADIK, LLP BY: Stephen M. Hla ' quire M d s bscribed before me this o L�J 20 r�Lq� Not Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHLEEN M.VINCENT,Notary Public Upper Gwynedd Twp.,Montgomery County My Commission Expires September 1,2014 Page 7 of 7 • Department of Defense Manpower Data Center Results as of:Jun-06-2013 12:20:29 SCRA 3.0 Pursuant,to Smicememben Civil Relief Act Last Name: BRELLOS First Name: ATHENA Middle Name: J Active Duty Status As Of: Jun-06-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA _ No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty StaA Date Active Duty End Date Status Service Component NA NA k No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date I�� t The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty �j Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Ot Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 ,The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA maybe invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a Gall to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: F3XDOB21 POF9U40 KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue P.O. Box 1489 North Wales, PA 19454 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE IN THE COURT OF COMMON PLEAS III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO.: 13-127 Civil Newtown Square, PA 19073, Plaintiff, V. JOSEPH E. JIRAS, III and ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, Defendant. NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Athena J. Brellos 2014 Lincoln Street Camp Hill, PA 17011 DATE OF NOTICE: May 2, 2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice 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. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S.BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S.BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Athena J. Brellos—2014 Lincoln Street, Camp Hil ,P�( 6011 By: Stephen Madik, Esquire Attomeyf Plaintiff KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue P.O. Box 1489 North Wales, PA 19454 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE IN THE COURT OF COMMON PLEAS 111, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO.: 13-127 Civil Newtown Square, PA 19073, Plaintiff, V. JOSEPH E. JIRAS, III and ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, Defendant. CERTIFICATION OF MAILING NOTICE UNDER RULE 23 7.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,May 2, 2013 to the following Defendants: Athena J. Brellos 2014 Lincoln Street Camp Hill, PA 17011 By: Stephen M. lad , Esquire Attorney fo Plai iff KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue, P.O. Box1489 North Wales, PA 19454-1489 (215) 855-9521 PARTNERS FOR PAYMENT RELIEF DE COURT OF COMMON PLEAS OF III, LLC, CUMBERLAND COUNTY, PA 3748 West Chester Pike Suite 103 NO: 13-127 CIVIL Newtown Square, PA 19073, PLAINTIFF, V. JOSEPH E. JIRAS, III AND ATHENA J. BRELLOS, 2014 Lincoln Street Camp Hill, PA 17011, DEFENDANT(S). RULE 236 NOTICE To: Athena J. Brellos 2014 Lincoln Street Camp Hill, PA 17011 PURSUANT TO RULE 236, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT HAS BEEN ENTERED AG�NST YOU ON THIS DA IN,THIS ACTION. t f cY By: Deputy Prothonotary �1171(3 Page 1 of 7 r KERNS, PEARLSTINE, ONORATO & HLADIK, LLP .- 7 STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIF ' _ ATTORNEY I.D. NO 66287 '"`= WILLIAM E. MILLER, ESQUIRE " ATTORNEY I.D. NO 308951 r Fti3 298 Wissahickon Avenue North Wales, PA 19454-1489 (215) 855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, v. NO: 13-127 CIVIL Joseph E. Jiras, III and Athena J. Brellos, 2014 Lincoln Hill Street, Camp Hill, PA 17011, DEFENDANT(S). PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Execution in the above matter, and direct the Sheriff to levy on the real property located at 2014 Lincoln Street, Camp Hill, Pennsylvania 17011. Amount due $24,417.96 Interest from 6/17/13 to 3/5/14 $ 566.37 At $2.17 per day TOTAL $24,984.33 *together with interest at the aggregate daily rate of$2.17, 448.50 PA I plus costs, expenses, attorneys' fees, and all other amounts g5.00 CBF due and payable under the Note and Mortgage and for qq,oo foreclosure and sale of the mortgage premises. 103.15 " 110,50 " Respectfully submitted, II. 15 IV.50 " KERNS, 'IR TINE, ONORATO & 3 d.1 OD_ Any PD Any HLADIK, Date: '3 By: fr,.. Stephen M Hladi7�'q ire °Z'O�'S Q� So 0*1a.37 Or344&442A41'61 KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, =r-n - v. NO 13-127 CIVIL-. - Joseph E. Jiras, III and Athena J. Brellos, c �- 2014 Lincoln Street, F3 Camp Hill, PA 17011, = DEFENDANT(S). AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANTS Stephen M. Hladik, Esquire, attorney for the Plaintiff in the above- captioned action, hereby certify that the last known address of each of the Defendant(s) is as follows: Name: Address: Joseph E. Jiras, III 2014 Lincoln Street Camp Hill, PA 17011 Athena J. Brellos 923 St. Petersburg Road Carlisle, PA 17013 RESPECTFULLY SUBMITTED, KERNS, PEARLSTI •NORATO & HLADIK, LLP Date: /°I BY: Stephen M. Hladik, Esquire Attorney for Plaintiff KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, —} V. NO: 13-127 CIVIL '1 Joseph E. Jiras, III and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011, ce_ F:, DEFENDANT(S). ACT 91 CERTIFICATION STEPHEN M. HLADIK, ESQUIRE, herby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because ( ) an FHA Mortgage ( ) non-owner occupied ( ) vacant (X ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. 11 Date: BY: Stephen M. H adi , Esquire Attorney for P tiff KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, ? �a> v. NO: 13-127 CIVIL ' = cni` Joseph E. Jiras, III and Athena J. Brellos, �^ 2014 Lincoln Street, Camp Hill, PA 17011, r ' DEFENDANT(S). AFFIDAVIT PURSUANT TO RULE 3129.1 Partners for Payment Relief DE, III, LLC, Plaintiff in the above-captioned action, sets forth as of the date of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the following was information concerning the real property situate at 2014 Lincoln Street, Camp Hill, Cumberland County, Pennsylvania 17011, the same being more particularly described on Exhibit "A" attached hereto and incorporated by reference: 1. Names and Addresses of Owner(s) or Reputed Owner(s): Name: Address: Joseph E. Jiras 2014 Lincoln Street Camp Hill, PA 17011 2. Name and address of Defendant(s) in judgment: Name: Address: Joseph E. Jiras 2014 Lincoln Street Camp Hill, PA 17011 Athena J. Brellos 923 Petersburg Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is of record on the real property to be sold: Name: Address: Partners for Payment Relief DE, III, 3748 West Chester Pike, Suite 103, LLC Newtown Square, PA 19073 Northstar Capital Acquisitions c/o Apothaker & Associates, P.C. David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 Pennsylvania State Employees One Credit Union Place Credit Union (PSECU) Harrisburg, PA 17110 c/o Shawn M. Long, Esquire Barley Snyder LLC 126 East King Street Lancaster, PA 17602 Penn Waste Inc. 85 Brickyard Road PO Box 3066 York, PA 17402 GMAC Mortgage, LLC 1100 Virginia Drive PO Box 8300 Fort Washington, PA 19034 c/o Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 . ` Camp Hill Borough 2145 Walnut Street Camp Hill, PA 17011 c/o Scott A. Dietterick, Esquire James, Smith, Dietterick & Connelly, LLP PO Box 650 Hershey, PA 17033 Russell Silverman d/b/a DBA 335 Front Street Advanced Plastering Marysville, PA 17053 Commonwealth of Pennsylvania Bureau of Compliance Department of Revenue Lien Section PO Box 280948 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: Name: Address: Partners for Payment Relief DE, III, 3748 West Chester Pike, Suite 103, LLC Newtown Square, PA 19073 Mortgage Electronic Registration PO Box 2026 Systems Inc. MERS Flint, MI 48501-2026 GMAC Mortgage Corporation 100 Witmer Road PO Box 963 Horsham, PA 19044 GMAC Mortgage LLC 1100 Virginia Drive PO Box 8300 Fort Washington, PA 19034 5. Name and address of every other person who has any record lien on the property: Name: Address: 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: Name: Address: None. 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: Name: Address: Tenant/Occupant 2014 Lincoln Street Camp Hill, PA 17011 Domestic Relations 13 N. Hanover St. P.O. Box 320 Carlisle, PA 17013 Commonwealth of PA P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 I hereby verify that the statements made in this Affidavit are true and correct to the best of my knowledge or information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP 3 X\ Date: By: _ Stephen M. Hla,i , Es,uire Attorney for Pl.'nt. • LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, the County of Cumberland and the Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Lincoln Street, formerly Berkley Street, on the dividing line between Lots 156 and 157 on the hereinafter mentioned plan of lots; thence in a westerly direction along the northern line of Lincoln Street, a distance of 60 feet to a point on the dividing line between Lots 158 and 159 on said plan; thence in a northerly direction along said dividing line between Lots 158 and 159 on said plan, a distance of 100 feet to a point on the southern line of Lot 179 on said plan; thence in an easterly direction along the southern line of Lot 179 and Lot 180 on said plan, a distance of 60 feet to a point on the dividing line between Lots 156 and 157 on said plan; thence in a southerly direction along said dividing line between Lots 156 and 157 on said plan, a distance of 100 feet to a point on the northern line of Lincoln Street aforesaid, the point and place of BEGINNING. BEING Lots 157 and 158 on the plan of Camp Hill Estates as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 1, Page 90. HAVING THEREON erected a single family dwelling house known and numbered as 2014 Lincoln Street. BEING THE SAME PREMSIES which Joseph E. Jiras and Athena J. Brellos by Deed dated May 16, 2012 and recorded May 17, 2012 in the Cumberland County Recorder of Deeds Office at Instrument No.: 201214719 granted and conveyed unto Joseph E. Jiras, in fee. KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, c, PLAINTIFF, .. = ; m l.. :"7v; -4 v. NO 13-127 CIVIL r ! C"= . Joseph E. Jiras, III and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011, _ DEFENDANT(S). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joseph E. Jiras, III 2014 Lincoln Street Camp Hill, PA 17011 Real estate situate at 2014 Lincoln Street, Borough of Camp Hill, Camp Hill, Cumberland County, PA 17011, as more fully set forth on Exhibit "A" attached hereto, is scheduled to be sold at Sheriff's Sale on March 5, 2014 at 10:00a.m. in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the Court Judgment of$24,417.96, (plus any additional interest and costs) obtained by Partners for Payment Relief DE, III, LLC, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sale you must take immediate action. The Sale will be stopped if you pay Partners for Payment Relief DE, III, LLC, back payments, late charges, costs, and reasonable attorneys' fees due. To find out how much you must pay, you may call: Stephen M. Hladik, Esquire 298 Wissahickon Avenue North Wales, PA 19454 Telephone number 215-855-9521 1. 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. 2. You may 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 below to find out how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff of Cumberland County at (717) 240-6390. 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 paid the Sheriff the full amount due in the Sale. To find out if this happened, you may call the Sheriff of Cumberland County at (717) 240-6390. 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 a 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 on or before April 5, 2014. This schedule will state who will be receiving the 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 filing the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your property 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE,PA 17013 717-249-3166 Respectfully submitted, KERNS, PEARLSTINE, ONORATO & HLADIK, LLP Date: q By: IP Stephen M. Hlad' , -quire Attorney for Pia"' tiff • LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, the County of Cumberland and the Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Lincoln Street, formerly Berkley Street, on the dividing line between Lots 156 and 157 on the hereinafter mentioned plan of lots; thence in a westerly direction along the northern line of Lincoln Street, a distance of 60 feet to a point on the dividing line between Lots 158 and 159 on said plan; thence in a northerly direction along said dividing line between Lots 158 and 159 on said plan, a distance of 100 feet to a point on the southern line of Lot 179 on said plan; thence in an easterly direction along the southern line of Lot 179 and Lot 180 on said plan, a distance of 60 feet to a point on the dividing line between Lots 156 and 157 on said plan; thence in a southerly direction along said dividing line between Lots 156 and 157 on said plan, a distance of 100 feet to a point on the northern line of Lincoln Street aforesaid, the point and place of BEGINNING. BEING Lots 157 and 158 on the plan of Camp Hill Estates as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 1, Page 90. HAVING THEREON erected a single family dwelling house known and numbered as 2014 Lincoln Street. BEING THE SAME PREMSIES which Joseph E. Jiras and Athena J. Brellos by Deed dated May 16, 2012 and recorded May 17, 2012 in the Cumberland County Recorder of Deeds Office at Instrument No.: 201214719 granted and conveyed unto Joseph E. Jiras, in fee. KERNS, PEARLSTINE, ONORATO & HLADIK, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, v. NO: 13-127 CIVIL Joseph E. Jiras, III and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011, DEFENDANT(S). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Athena J. Brellos 2014 Lincoln Street Camp Hill, PA 17011 Real estate situate at 2014 Lincoln Street, Borough of Camp Hill, Camp Hill, Cumberland County, PA 17011, as more fully set forth on Exhibit "A" attached hereto, is scheduled to be sold at Sheriff's Sale on March 5, 2013 at 10:00a.m. in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the Court Judgment of$24,417.96, (plus any additional interest and costs) obtained by Partners for Payment Relief DE, III, LLC, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sale you must take immediate action. The Sale will be stopped if you pay Partners for Payment Relief DE, III, LLC, back payments, late charges, costs, and reasonable attorneys' fees due. To find out how much you must pay, you may call: Stephen M. Hladik, Esquire 298 Wissahickon Avenue North Wales, PA 19454 Telephone number 215-855-9521 1. 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. 2. You may 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 below to find out how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 3. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff of Cumberland County at (717) 240-6390. 4. 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. 5. The Sale will go through only if the buyer paid the Sheriff the full amount due in the Sale. To find out if this happened, you may call the Sheriff of Cumberland County at (717) 240-6390. 6. 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. 7. You have a 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. 8. 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 on or before April 5, 2014. This schedule will state who will be receiving the 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 filing the Schedule of Distribution. 9. You may also have other rights and defenses, or ways of getting your property 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE,PA 17013 717-249-3166 Respectfully submitted, KERNS, PEARLSTIN', •NORATO & HLADIK, LLP ,9 vl Date: W_ By: _ Stephen M. Hladik, squir° Attorney for Plainti LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Camp Hill, the County of Cumberland and the Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Lincoln Street, formerly Berkley Street, on the dividing line between Lots 156 and 157 on the hereinafter mentioned plan of lots; thence in a westerly direction along the northern line of Lincoln Street, a distance of 60 feet to a point on the dividing line between Lots 158 and 159 on said plan; thence in a northerly direction along said dividing line between Lots 158 and 159 on said plan, a distance of 100 feet to a point on the southern line of Lot 179 on said plan; thence in an easterly direction along the southern line of Lot 179 and Lot 180 on said plan, a distance of 60 feet to a point on the dividing line between Lots 156 and 157 on said plan; thence in a southerly direction along said dividing line between Lots 156 and 157 on said plan, a distance of 100 feet to a point on the northern line of Lincoln Street aforesaid, the point and place of BEGINNING. BEING Lots 157 and 158 on the plan of Camp Hill Estates as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 1, Page 90. HAVING THEREON erected a single family dwelling house known and numbered as 2014 Lincoln Street. BEING THE SAME PREMSIES which Joseph E. Jiras and Athena J. Brellos by Deed dated May 16, 2012 and recorded May 17, 2012 in the Cumberland County Recorder of Deeds Office at Instrument No.: 201214719 granted and conveyed unto Joseph E. Jiras, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-127 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PARNERS FOR PAYMENT RELIEF DE,III, LLC, Plaintiff(s) From JOSEPH E. JIRAS,III and ATHENA J. BRELLOS (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: $24,417.96 L.L.: $.50 Interest from 6/17/13 to 3/5/14 -- $566.37 Atty's Comm: Due Prothy: $2.25 Atty Paid: $321.00 Other Costs: Plaintiff Paid: Date: 10/4/13 David D. Buell,Prothonotary // (Seal) : // i� L/ // Deputy REQUESTING PARTY: Name: STEPHEN M.HLADIK,ESQUIRE Address: KERNS,PEARLSTINE,ONORATO&HLADIK,LLP 298 WISSAHICKON AVENUE NORTH WALES, PA 19454-1489 Attorney for: PLAINTIFF Telephone: 215-855-9521 Supreme Court ID No. 66287 HLADIK, ONORATO & PEARLSTINE, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINiF1 ' ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER ESQUIRES ATTORNEY I.D. NO. 308951 --<> rte, <: 298 Wissahickon Avenue North Wales, PA 19454-1489 �`) 215-855-9521 Partners for Payment Relief DE, 111, LLC, "' COURT OF COMMON PL1fV*_ 3748 West Chester Pike, CUMBERLAND COUNT-.PA- Suite 103, Newtown Square, PA 19073, PLAINTIFF, V. NO: 13-127 CIVIL v == Joseph E. Jiras, III and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011, DEFENDANT(S). AFFIDAVIT OF SERVICE UPON ALL INTERESTED PARTIES PURSUANT TO Pa. R.C.P. 3129.2(c)(1)(iii) 1, STEPHEN M. HLADIK, ESQUI , att rney for Plaintiff in the above- referenced matter, hereby state that on , consistent with the provisions of Pennsylvania Rule of Civil Procedure 3129.2(c)(1)(iii), I caused written notice of the scheduled Sheriff's sale in the above-referenced matter to be served by first class mail, postage prepaid, with Certificate of Mailing, on all persons named in Plaintiff's Affidavit Pursuant to Rule 3129.1, at their respective addresses set forth in that Affidavit. A true and correct copy of Plaintiff's Affidavit Pursuant to Rule 3129.1 is attached to this Affidavit as Exhibit "A", and is made a part of it. A true and correct copy of U.S. Postal Service Form 3877 - Certificates of Mailing for each notice mailed is attached to this Affidavit as Exhibit "B", and is made a part of it. I hereby verify that the statements made in this Affidavit are true and correct, to the best of my knowledge, information and belief, and that the statements are made pursuant to 18 Pa. C.S.A. § 49 el to unsworn falsifications to authorities." STEPHEN M. HL _ , SQUIRE HLADIK, ONORATO & PEARLSTINE, LLP STEPHEN M. HLADIK, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 66287 WILLIAM E. MILLER, ESQUIRE ATTORNEY I.D. NO. 308951 298 Wissahickon Avenue North Wales, PA 19454-1489 215-855-9521 Partners for Payment Relief DE, III, LLC, COURT OF COMMON PLEAS OF 3748 West Chester Pike, CUMBERLAND COUNTY, PA Suite 103, Newtown Square, PA 19073, PLAINTIFF, V• NO: 13-127 CIVIL Joseph E. Bras, III and Athena J. Brellos, 2014 Lincoln Street, Camp Hill, PA 17011, DEFENDANT(S). AFFIDAVIT PURSUANT TO RULE 3129.1 Partners for Payment Relief DE, III, LLC, Plaintiff in the above-captioned action, sets forth as of the date of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the following was information concerning the real property situate at 2014 Lincoln Street, Camp Hill, Cumberland County, Pennsylvania 17011, the same being more particularly described on Exhibit "A" attached hereto and incorporated by reference: 1. Names and Addresses of Owner(s) or Reputed Owner(s): Name: Address: Joseph E. Jiras 2014 Lincoln Street Camp Hill, PA 17011 2. Name and address of Defendant(s) in judgment: Name: Address: Joseph E. Jiras 2014 Lincoln Street Camp Hill, PA 17011 EXHIBIT Athena J. Brellos 923 Petersburg Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is of record on the real property to be sold: Name: Address: Partners for Payment Relief DE, III, 3748 West Chester Pike, Suite 103, LLC Newtown Square, PA 19073 Northstar Capital Acquisitions c/o Apothaker & Associates, P.C. David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 Pennsylvania State Employees One Credit Union Place Credit Union (PSECU) Harrisburg, PA 17110 c/o Shawn M. Long, Esquire Barley Snyder LLC 126 East King Street Lancaster, PA 17602 Penn Waste Inc. 85 Brickyard Road PO Box 3066 York, PA 17402 GMAC Mortgage, LLC 1100 Virginia Drive PO Box 8300 Fort Washington, PA 19034 c/o Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Camp Hill Borough 2145 Walnut Street Camp Hill, PA 17011 c/o Scott A. Dietterick, Esquire James, Smith, Dietterick & Connelly, LLP PO Box 650 Hershey, PA 17033 Russell Silverman d/b/a DBA 335 Front Street Advanced Plastering Marysville, PA 17053 Commonwealth of Pennsylvania Bureau of Compliance Department of Revenue Lien Section PO Box 280948 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: Name: Address: Partners for Payment Relief DE, III, 3748 West Chester Pike, Suite 103, LLC Newtown Square, PA 19073 Mortgage Electronic Registration PO Box 2026 Systems Inc. MERS Flint, MI 48501-2026 GMAC Mortgage Corporation 100 Witmer Road PO Box 963 Horsham, PA 19044 GMAC Mortgage LLC 1100 Virginia Drive PO Box 8300 Fort Washington, PA 19034 5. Name and address of every other person who has any record lien on the property: Name: Address: 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: Name: Address: None. 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: Name: Address: Tenant/Occupant 2014 Lincoln Street Camp Hill, PA 17011 Domestic Relations 13 N. Hanover St. P.O. Box 320 Carlisle, PA 17013 Commonwealth of PA P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 I hereby verify that the statements made in this Affidavit are true and correct to the best of my knowledge or information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. 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