Loading...
HomeMy WebLinkAbout13-0224KML LAW GROUP, P.C. ~} ~~ ~ _ 1 QUITE 5000-BNY MELLON INDEPENDENCE CENTER''" T ~,f~ ~y' ~ ~ ~$$~,'~..7~'a 701 MARKET STREET ; ~~ !"~~~H~tT~Iryjr~ (866) 413 23 1 ~ PA 19106 ~~ ~ ~ a~~ f ~ ~~'~: GREEN TREE SERVICING, LLC 7360 S. Kyrene Road Mail Stop: T-208 Tempe, AZ 85283 Plaintiff Y I~ C~~IIE COURT OF COMMON PLEAS .YA ~1 f ~ OF Cumberland COUNTY CNIL ACTION -LAW vs. ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO KENNETH P. URSIN Mortgagor(s) and Record Owner(s) 5020 Mendenhall Drive, Unit 150 Mechanicsburg, PA 17050 Defendant(s) ACTION OF MORTGAGE FORECLOSURE ~N /~ ~ No. CN~• ~~~: IIIIv~~ NOTICE ~~~ 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notificacion. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la torte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars us S c~~ ap a ~~ , LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL 5ERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http•//www phfa.or~/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention~,kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 112695FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is GREEN TREE SERVICING, LLC, 7360 S. Kyrene Road, Mail Stop: T-208 Tempe, AZ 85283. 2. The name(s) and address(es) of the Defendant(s) is/are ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO, 5020 Mendenhall Drive, Mechanicsburg, PA 17050 and KENNETH P. URSIN, 5020 Mendenhall Drive, Mechanicsburg, PA 17050, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On November 30, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE A DNISION OF NATIONAL CITY BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on December 04, 2006 as Book 1974 Page 4920. The mortgage has been assigned to: GREEN TREE SERVICING, LLC by assignment of Mortgage recorded on September 20, 2010 as Instrument # 201026209. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property„). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June O 1, 2010 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance .............................................•-----.............------............$191,486.17 Interest from 05/01/2010 through 10/06/2012 at 7.0550% .....................$32,832.72 Per Diem interest rate at $37.02 Negative True Escrow ............................................................................$15,624.96 UAF Balance .............................................................................................. ($210.87) Prior Attorney Expenses .............................................................................$901.99 Property Preservation ....................................................................................$60.00 Reasonable Attorney's Fee .......................................................................$1,450.00 $242,144.97 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $242,144.97, together with interest at the rate of $37.02, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: . KML LAW GROUP .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff VERIFICATION ,-- >- as the representative of the Plaintiff corporation I, within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date:~(~ ( ~1~ #112695FC - ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO and KENNETH P. URSIN 5020 Mendenhall Drive, Unit 150 Mechanicsburg, PA 17050 ~hi6itA First Arrrerican Title insurance Company Conunitment Number: 06569 StIL,E C PRGPERTY DE>sCRPTION The land rsfsmed b in this Commi4nent is deaa~ed ss fiolows: ALL THAT CERTAMI Unit. being UNt No. 150 (the "Unit'), of the Courts at Brandywine. a TvwN~orne Corrdondnium (ths "Cordom~m"j, IocaAed in Hampden Township. Cumberland County, ~, which Unit is dssipna>led in ~ Declaration of Condominium of tl~e Courts at Brandywine, a 7ownhorere Condominium (the'Dadaralbn of Condorniniumh and Dedaration Phta and Plans raoorded in the OINoa of iha Gunberand Coungr R,soorder of Osads In NiisaeNaneous Book 721. Pape 47t>t8 and Rift of Way Plan Book 13. Paige 1 t 9 resp-. together' wMh any and al amendments tlrarebo. TOGETHER w>ih the in~vidual peroerrtape merest in the Corrunon Ele<nenb ~pculanarrt to the the Unitas more partirxrbrly set forth in the aforesaid Declaration d Condominium, as ~ amended. TOGETHER wig fhe r~ht bo use the Limited Common Elerrrents applcable b the Unit being oorweyed herein, pursuant ~ the Dedaratlort of Condominium and Dedaratlon PIS and Plans, ~ last arrrerrded. UNDER AND SUB,~CT to any and al coverumts, con~iorrs, , ripMs of way, easemsrrts and aproerrranta of record in the aforesaid OlNoe, the aGaroeaid Dedaratlon of Condorr~nium, and matters which a physicd irwpec~on or survey of the Uri and Cortrrrion Eletrter~s would disclose. BEING part of the s~rre promises which Wiliam T. Lehmer and Pbarl E. Lehmer by deed dated February 19, 2003 and rooorded Febniary 24, 2003 in the Office d the aurrbsrland Coungr Recorder of Deeds in Record Book 255. Page 4245, gratrted and convoyed urrto Fiahir>g Croak Valet' Assodates, L.P. ALSO BEING part of the same prerrrises wtuch Gtadys M. Watts by deed dated Sap6smb~sr 30, 200:1 and recorded October 6, 2003 in the Oifloe of the Recorder of Deeds in Record Book 259, rage 3673, granted and conveyed unb Fishing Creek Valet' Associates. LP. I Certify this tta be recorded In Cumbd CanatY PA _z-!~~ _.,.. "~ ~~~ Recorder of Deed ~~ ALTA Cama~hrnsit SrJwdule C BK1974PG494O (OOeeYItle~NO) _T . ..... ____ ~Fti6it ~ *Exhibit has been redacted to remove all personally identifiable information or non public information ACT 91 NOTICE DATE OF NOTICE: 11/16/2012 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the m ortgage on your ho me is in default, and the lender intends to foreclose Spec ific information about the nature of the default is provided in the attached pages. The HOME OWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) m ay be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help you mu st MEET WI TH A C ONSUMER CR EDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling A eg ncy. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this N otice. If you have an~ques tions, you m ay call the Pennsylvania Housing Finance A gency toll free at 1-800-342-2397. (Persons with im paired hearing can call (717) 780-1869.) This Notic a contai ns im portant legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association m ay be able to help you find a lawyer. La notificacion en adjunto es de soma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el cont enido de esta notification obtenga una traduccion immediatamente llamanda esta a gencia (Pennsylvania Housing Finance A gency) sin cargos al numero m encionada a rriba. Pue des ser elegib le para un prestam o por el pr ograma llam ado "Homeowner's Emergency Mortgage Assistance Pr ogram" el coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: KML Law Group, P.C. Suite 5000 - BNY Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: 11 / 16/2012 Homeowners Name: ADRIANNE DEL TORO A/K/A ADRIANNE DEL TORO and KENNET H P. URSIN Property Address: 5020 Mendenhall Drive, Unit 150, Mechanicsburg, PA 17050 Loan Account No.: 053 Original Lender: N NAL CITY MORTGAGE A DIVISION OF NATIONAL CITY BANK Current Lender/Servicer: GREEN TREE SERVICING HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HA5 BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBII.ITY 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (331 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BTtING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "I-~OW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - 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.) 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 for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY VVITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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. Ni~'.~~'Y,O[1 ~1~.CUItRILY,PRgTECTl~~~BX~~ FI~II~ ~ A_,~DN iN' ~,. ,; ~'C~ ~ >A'(~~,I.,QWIN~ I`A~t.'~"~~~`~ ~1'1(!1€CI~ ~"~'q } „- ,r E ,~s~I.Y AND SHOULD~1SdT $>~ ~~l~sl~l~l~. AS°~N AT~T To-Ca~l~~c~r ~' DI~Bfi. (If you 4~ve Bled ba~kru~tiy ypu. caa stilt. ugly for Emer~cuc3''Marfe Asais~auce.} HOW TO CURE YOUR MORTGAGE DEFAULT (Brink it up to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 5020 Mendenhall Drive, Unit 150, Mechanicsburg, PA 17050 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: (a) Monthly payment from 06/01/2010 thru 11/16/2012 (18 mos. at $1,331.07/month) $23,959.26 (5 mos. at $1,590.67/month) $7,953.35 (3 mos. at $1,634.00/month) $4,902.00 (3 mos. at $1,640.00/month) $4,920.00 (1 mos. at $1,672.50/month) $1,672.50 (b) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $43,407.11 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 $43,407.11, 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: GREEN TREE LLC 1400 Turbine Drive, Suite 200 Rapid City, SD 57703 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 ezercise its rights to accelerate the mort~a~e 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 Sheriffto pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings 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, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so bypayin~ the total amount then past due, plus any late or other charges then due, reasonable attorneys 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 byperforming any other requirements under the mort~a~e. 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 four (4 to six (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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: GREEN TREE LLC Address: 1400 Turbine Drive, Suite 200 Rapid City, SD 57703 Phone Number: 800-643-0202 Fax Number: 866-479-6843 Contact Person: Collection Department 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 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 MAY 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. Contact: Collection Department Phone Number: 800-643-0202 ,~.~ ~ i _ t~Et{MSYtYI-t~t{.A t$<}USiN Ei#tA A ~NCY Comprehensive Housing Counseling Agencies Agencias de Consejo al Cliente pars Vivienda Cumberland County ~ "CCCS of Western PA -York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 / 888.511.2227 www.cccsaa.ora Community Action Commission -Capital Region 1514 Deny St Harrisburg PA 17104 717.232.9757 www. cactricounty. ora 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 www.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www, ru ralisc.oro/oathstone~a. htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 4/30/2012 9:03:04 AM Page 1 of 1 GREEN TREE SERVICING, LLC Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV z ~° ~ r.... -< r- -•- -G 13 ~aK~~t Case No. yam. ~ --- ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO ~ KENNETH P. URSIN Defendant(s) by C7 f~~J .:..~.i 41 _.~ ~ ~, -~ .. r.,~ _ a ~-` ~ _i ,c- -±o ~, ~ ~~ c? ~ ~ i NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the 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 the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEP5 REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: (Signature of Couns r Plaintiff) 1/10/2013 Date Cumberland County Residential Mortgage Foreclosure Diversion Prograrxi Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete•yaur request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide Ehc Following information to the best of your knowledge: Borrower name(s): Prpperty Address: City: Is the property fnr sale? Realtor Name: Borrower Occupied? Tailing Address (if different), State: .Zip: Yes ^ No ^ Twisting date: Price: S_ Realtor Phone: Yes No ^ Cify: State' Zip: Phony Numbers° Honte: Office; Celt: Other: Email: ~ of people in household: How long? Mailing Address: City: _ State: Zip: Phone Numbers: Home: Office: CtTI: Other: Email: - -- # ofpeople inhousehold: How long? , First Mortgage Lender: Type of Loan: )roan Number: Date You Closed 'Your Iroan: Second Mortgage Tender: Type of Loan.: Toari Nutnbcr: • Total Mortgage Payments Amount: $ Date of Last Fayment: Primary Reason for Default: Included Taxes & Ir~surancc; Is the loan in T3ankruptcy? Yes ^ No ^ l;1• yes, provide names, location of court, case number & attorney; Assets Amount awed: ue: Dome; $ ~ Other Real l:.state: $ $ Retircmenk Funds: $ $ _-. Jnvestments: $ $ Checking:. $ $ Savings: $ ~ Other:. $ A,tttomobile #I: Model: Year: Amount owed: ~ Value: Automobile #2: Model: Year: Amount awed• Value: Other transportation (aukamobiles. boats m tty~re Rrlegg1: Model: 5 ~SX ~S 7 ----. ___ _..-------._._..._..._._. .. 'Year: Amount owed: Value Manfhly Income Name of Employers: 1. Z. 3. Additional Income Description (not wages): 1. montlily amount; 2. monthly amount: Harrower Pay Days: Go-Borrower P$y Days: Monthly Expenses: (Please only include expenses you are currently paying} P,XPI~ISL~ AMOUNT E~'ENSE AMOUNT Ma Food 2 M UtilitiGS Car l'a an s Cando/Nei .Foes A,utq Insurance MGd. not coy Auto fuc irs Other ro . a cnt Install. Loan Pa mcnt Cabla TV Child S rtJAlim. S din Mane Da /Child Carr.ITuit. Otl~cr Ex s Amount Available for Monthly Mortgage Payments Based an Income & ExpensGS: Have you boon working with a Housing Counseling Agency? 'Y'es [~ No ^ Tf yes, please provide the following information; Counseling Agency: Couriselar: Pl~orte (Office):. l'~ax;,_,_ Email: Have you made application for I-lorneowners Emergency Mortgage Assistance Program (HEMAia) assistaricc? 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? Yes^ No^ If yes, please indicate the status of those negotiations: Please provide the following informat;on, if know, regarding your lender ar leader's loan servicing company: Lender's Contact (Name): Servicing Company (Name]: CQTktaCt; Phone: Phone: Y(We, ---, authorize the above named to use(refer thus information to my lender/serviccr far the sole purpose of evaluating my financial situation for passible mortgag~c options. UWe understand that Uwe amlare under no obligation to use the services provided by the above Warned Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to loader snd. lend_ejr's counsel: -Y Praaf of income j~ Past 2 bank statements ``Y~~ Preaf a# any expected income for the last 45 days -V Copy of a current utility bill "Y Letter expt~ning reason for delinquea~y and nay supporting documentation {l~Ardship letter) V Listing agreetuen# (if property is currently on the market] t KMIL LAW GROUP,P.C. 112695FC Suite 5000 CF: 01/14/2013 BNY Mellon Independence Center Flu 4 SD: 06/05/2013 701 Market Street �: i, '�-�GT4I0iGR $247,438.83 Philadelphia,PA 19106-1532 215-627-1322 3 Attorne for Plaintiff GREEN TREE SERVICING,LLCl p� bNSYIV>t� �� IN THE COURT OF COMMON PLEAS 7360 S.Kyrene Road Mail Stop: T-208 of Cumberland County Tempe,AZ 85283 Plaintiff CIVIL ACTION—LAW vs. ACTION OF MORTGAGE FORECLOSURE ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO Term KENNETH P. URSIN No. 13-224 Mortgagor(s)and Record Owner(s) 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Robert Murray, an employee of KML Law Group,P.C., counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult(copy of return attached). ( ) Certified mail by KML Law Group,P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriff s Office. ( ) Ordinary mail by KML Law Group,P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriff s Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). ( ) Certified Mail&ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail attached). ( ) Published in accordance with court order(copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders(if any)has been made by ordinary mail KML Law Group,P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, BY: Rboer Mu Legal Assistan '> I c @ @ / @ # R ¥ , ~ G -n »E 0) o Dz or ter§ t $ ] $3 . ���m _ �• m r-AC > 0 . _I- gCL ! . ■ \ C » -® 2 q »M ® g m �2 .z mss' f § R# c a �� t z . . 7 0 (a 2� \ 5 / $st k 2 @ m m m / . CD 6o ISo ^cn/\k 0) oOOO � I ° . 0 @ =I 0#? k x0 @ _ s o - 7 0- o 90 G . X203/ q}� §3 CL ¥ w[ A % n & �k) : �I� _ ƒ § . >�CD >\> ] ' ƒ / m $ 2 C)— G; 0 ; f 070%2 GOL mf . . . A 9 f X2 ca cOOO .E co $ »Xwm 3 !R 2 ( % E( i f ogE � / ma = 0 k . CD I 2� aRga> E© /(■O7 03 c) °m � / C CD { --- - ' \ > ,9 : � . . . . ■ , . 2 S m �£ ■ m § .o cn . . . - ■ : \ ice | . . . . m$� `| � 23 . . � t'ld Address of Sender Check type-of mail or service: Affix Stamp Here = 1 (H Issued as a pOLDBE K ❑ Certified ❑Recorded Delivery Qrriematlonal) oe tfi ate of meifrg SUITE 5000 ❑ COD ❑ Registered or for additional M MARKET STREET ❑Delivery Confirmation ❑ Return Receipt for Merchandise of this bill) --- --- -- - PHILADELPHIA,PA ❑Express Mai ❑Signature Confirmation Postmark and 19106-1532 ❑ Insured Date of Reca Amide Number Pddreseee(Nmna,Seeet pty,Smte,&ZIP Code) Postage Fee Nh;,., A � �;r.�, �3,.: 1. DOMESTIC RELATIONS OF CUMBERLAND j .. COUNTY , " I 02 1M ; "0 PO Box 320 COURT AT BRA DYWINE a . 0004285957 MAletx 2013 Carlisle,PA 17013 5020 M ndenhall rive AILE 1MD FRgM ZIPCODE_191o9 2 ec an urg, 1 -- PA DEPARTMENT OF PUBLIC WELFARE- L— _ Bureau of Child Support Enforcement TENAN.S/OCCUP NTS Health and Welfare Bldg.-Room 432 5020 M ridenhalf rive,Unit 50 7 0 3. Harrisburg,PA 17105-2675 COURT AT BRA DYWINE FIA CARD SERVICES A/K/A BANK OF 4712S ith Street AMERICA Harrisb 9,PA 171 cio 4• 520 Fellowship Road,C306 Mount Laurel,NJ 08054 i 5. 6. 7. 8. Total Number of Piece Total Number of Pieces ossnaster,Per(Name of receiving employee) uuee by sender Recelved at Post See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page 1 of�) Complete by Typewriter,Ink,or Ball Point Pen 112695FC Cumberland County Sale Date:06/05/2013 /► „ ADRIANNE DEL TORO A!K/A ADRIANNE DELTORO&KENNETH P.URSIN IJ//1f IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING,LLC;et seq. ;CASE and/or DOCKET No.:13-224 Plaintiff(Petitioner) i Sheriff's Sale Date• 06/05/201.3 i V. c ADRIANNE DEL TORO A/K/A ADRIANVE DELTORO;et al. Defendant(Respondent) ; AFFIDAVIT OF SERVICE ❑��oyu.pl�`lint p S m as Other: Notice of Sale I, I i 1[1�Q �L � 1 certify thaz I am eighteen years of age or older and that 1 am not a party to the a 'on nor an empkryee nor relative of a party, and that I tttmpted to serve ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO the above process on the day of I� _ 20 at o'cloclS _M,at 17 LAMAR AVENUE ASHEVILLE,NC 28803 3 Manlier of Service: By handing a copy to: ❑ An officer,partner,trustee,or registered agent of the Defendant organization who is not a plaintiff in the action* © The manager,clerk,or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action n An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action By handing a copy to the Dcfendant(s) By handing a copy at the residence of the Defendant(s)to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found* By handing a copy at the residence of the Defendant(s)to the clerk or manager of the hotel,inn,apartment house or other place of lodging at which he/she resides By handing a copy at the office or usual place of business of the Defendant(s)to the Defendants(s)agent or to the person for the time being in charge thereof i By posting a copy of the original process on the most public part of the property pursuant to an order of court *Name: Relationshipffitle/Position: idlhl<r Remarks: I Description:Approximate Age 4LJ Height Weig Race Sex I.V1 Hair VI7WV,1" Defendant was not served because: 7Moved rUnknown nNoAnswer rVacant F-1 Other: Service was attempted on the following dates/times: I} 2) 3) 1 � � Commonwealth/Stateof 7 )SS: County of l�(^ 1 XJ f1J ) Before me,the undersigned notary public,this day,personally,appeared I `L �t to me known,who being duly sworn according to law, deposes the following: tby swear of af�fi m a facts set forth in the foregoing Affidavit of Service are true and correct. Sub crt t for (Sign. of Affiant) _ this da}uf L \20 \ I Pile Number.11269SPC _ , � Case ID#:3578150 _ Notary Public r. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING,LLC;et seq. CASE and/or DOCKET No.:1224 Plaintiff(Petitioner) i 06/05/207 3 �. Sherffs Sale Date: i I i V. i ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO;et A. ! Defendant(Respondent) I i AFFIDAVIT OF SERVICE nComplaint F7 mmons FV OtLer. Notice of Sale 1 t �1 t�, 1 d 1 of -Certify that I am eighteen years of a it older rd that I am not a paTV to the action por an employee nor relative of a party, and that I attempted to serve KENNETH P.URSIN the above process on the day of 114 1 20 at dclock,-KM,2117 LAMAR AVENUE ASHEVILLE,NC 28803 / �� Manner of Service: By handing a copy to: 0 An officer,partner,trustee,or registered agent of the Defendant organization who is not a plaintiff in the action* 0 The manager,clerk,or other person for the time being in cbarge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action« n An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action" By handing a copy to the Defendants) El By handing a copy at the residence of the Defendant(&)to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found+ r7 By handing a copy at the residence of the Defendant(s)to the clerk or manager of the hotel,inn,apartment house or other place of lodging at which he/she resides [] By handing a copy at the office at usual place of business of the Defendant(s)to the Defendant's(e)agent or to the person for the time being in charge thereof+ n By posting a copy of the original process on the most public part of the property pursuant to an order of court *Name: KQ4lY1�. k �• �`��11/1 Relationship/Title/Position: Remarks Description Approximate Age Height Weight Sex Hair - Defendant was not served because: nMoved FUnknown I. INo Answer F Vacant n Other. Service was attempted on the following dates/times: 2) 3) Communwealth/State of County of SS: Before me,the undersigned notary public,this day,personally,appeared —!vin S('�4 l 1 ��� to me known,who being duly sworn according to law, deposes the following: �—r by swear or affirm the facts se�(orth in the foregoing Affidavit of Service are true and correct. t3Sub! aaii _ to re,ta� (Si attire f Affiani) this y ti L-4 j File Number.i 12695FC Case ID 4:3578150 = Notary Public KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff GREEN TREE SERVICING,LLC IN THE COURT OF COMMON PLEAS 7360 S.Kyrene Road Mail Stop: T-208 of Cumberland County Tempe,AZ 85283 Plaintiff CIVIL ACTION-LAW vs. ADRIANNE DEL TORO A/K/A ADRIANNE ACTION OF MORTGAGE FORECLOSURE DELTORO KENNETH P.URSIN Term Mortgagor(s)and Record Owner(s) No. 13-224 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING,LLC,Plaintiff in the above action,by and through an authorized employee of its attorneys,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 1.Name and address of Owner(s)or Reputed Owner(s): ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO 17 Lamar Avenue Asheville,NC 28803-8608 KENNETH P.URSIN 17 Lamar Avenue Asheville,NC 28803-8608 2.Name and address of Defendant(s)in the judgment: ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO 17 Lamar Avenue Asheville,NC 28803-8608 KENNETH P. URSIN 17 Lamar Avenue Asheville,NC 28803-8608 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker&Associates, P.C., 520 Fellowship Road, C306 Mount Laurel,NJ 08054 TOWNSHIP OF HAMPDEN 230 S. Sporting Hill Road Mechanicsburg,PA 17055 TOWNSHIP OF HAMPDEN C/o Keith O.Brenneman,Esquire 44 W.Main Street,P.O.Box 318 Mechanicsburg,PA 17055 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. COURTS AT BRANDYWINE 5020 Mendenhall Drive Mechanicsburg,PA 17050 TENANTS/OCCUPANTS 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 COURTS AT BRANDYWINE 4712 Smith Street Harrisburg,PA 17109 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: May 9, 2013 K , La r p-/P.C. BY: Rboert Mteray Legal Assistant ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ��extn of Cuumber, Jody S Smith ti Chief Deputy OCT 2: 5 t" C Kj T 1 tf l.?1J� �iJ ��1 L W�.. d" Richard W Stewart UMBERLiM Solicitor r ENNSYLVA ii A Green Tree Servicing, LLC vs. Case Number Adrianne Del Toro (et al.) 2013-224 SHERIFF'S RETURN OF SERVICE 04/03/2013 02:11 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 5020 Mendenhall Drive Unit 150, Hampden Township, Mechanicsburg, PA 17050, Cumberland County. 06/04/2013 As directed by David Fein, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/7/2013 08/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle PA on August 7, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney David Fein, on behalf of Federal National Mortgage Association , being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,202.39 SO ANSWERS, August 30, 2013 RONNY ANDERSON, SHERIFF tK. Ou Pd .act pd -CO L[ oaf, iott ;96 3 9c Cc)CouniySulte Sheriff,Telecsoft,Inc. KML'Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING,LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Mail Stop: T-208 Tempe, AZ 85283 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO KENNETH P.URSIN (Mortgagor(s)and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 5020 Mendenhall Drive, Unit 150 Mechanicsburg,PA 17050 Defendant(s) No. 13-224 AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING,LLC,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 1.Name and address of Owner(s)or Reputed Owner(s): ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO 17 Lamar Avenue Asheville,NC 28803-8608 KENNETH P.URSIN 17 Lamar Avenue Asheville,NC 28803-8608 2.Name and address of Defendant(s)in the judgment: ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO 17 Lamar Avenue Asheville,NC 28803-8608 KENNETH P.URSIN 17 Lamar Avenue Asheville,NC 28803-8608 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker&Associates,P.C., 520 Fellowship Road,C306 Mount Laurel,NJ 08054 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. COURTS AT BRANDYWINE 5020 Mendenhall Drive Mechanicsburg,PA 17050 TENANTS/OCCUPANTS 5020 Mendenhall Drive,Unit 150 Mechanicsburg,PA 17050 COURTS AT BRANDYWINE 4712 Smith Street Harrisburg,PA 17109 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unswom falsification to authorities. DATED: #3 By: APP. _ KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 /David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gomall Pa.ID 92382 Attorneys for Plaintiff 13-224 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff GREEN TREE SERVICING,LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Mail Stop: T-208 Tempe,AZ 85283 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO ACTION OF MORTGAGE KENNETH P.URSIN FORECLOSURE Mortgagor(s) and Record Owner(s) 5020 Mendenhall Drive, Unit 150 Mechanicsburg,PA 17050 Docket No. 13-224 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DEL TORO,ADRIANNE A/K/A ADRIANNE DELTORO ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO 17 Lamar Avenue Asheville,NC 28803-8608 Your house at 5020 Mendenhall Drive,Unit 150,Mechanicsburg,PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday,June 05,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$247,438.83 obtained by GREEN TREE SERVICING,LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to GREEN TREE SERVICING,LLC,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 13-224 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 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 pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 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 within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-224 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 112695FC. Para informacion en espanol puede communicarse con Loretta al 215-825-634-4. 13-224 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff • GREEN TREE SERVICING,LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Mail Stop: T-208 Tempe,AZ 85283 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. ADRIANNE DEL TORO A/K/A ADRIANNE DELTORO ACTION OF MORTGAGE KENNETH P.URSIN FORECLOSURE Mortgagor(s) and Record Owner(s) 5020 Mendenhall Drive, Unit 150 Mechanicsburg,PA 17050 Docket No. 13-224 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: URSIN,KENNETH P. KENNETH P. URSIN 17 Lamar Avenue Asheville,NC 28803-8608 Your house at 5020 Mendenhall Drive,Unit 150,Mechanicsburg,PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday,June 05,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$247,438.83 obtained by GREEN TREE SERVICING,LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to GREEN TREE SERVICING,LLC,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 13-224 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 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 pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 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 within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-224 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 112695FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-224 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREEN TREE SERVICING,LLC Plaintiff(s) From ADRIANNE DEL TORO A/K/A ADRIANEE DELTORO,KENNETH P. URSIN (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: $247,438.83 L.L.: $.50 Interest from 2/27/2013 to Date of Sale per diem at$37.02 Atty's Comm: Due Prothy: $2.25 Atty Paid: $212.75 Other Costs: Plaintiff Paid: Date: 2/28/2013 Davi D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: DAVID FEIN,ESQUIRE Address: KML LAW GROUP,P.C. 701 MARKET STREET SUITE 5000-BNY INDEPENDENCE CENTER PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 82628 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at arlisle, Pa. This_ ,day of ,20 /e �� n Prot n tary CUMBERLAND LAW JOURNAL Writ No. 2013-224 Civil MUNICIPALITY HAMPDEN TOWN- SHIP. GREEN TREE SERVICING,LLC BEING PREMISES:5020 Menden- vs. hall Drive,Unit 150,Mechanicsburg, ADRIANNE DEL TORO PA 17050. SOLD Adrianne Deltoro, SOLD as the property of KEN- Kenneth P. Ursin NETH P. URSIN AND ADRIANNE DEL TORO, ADULT INDIVIDUALS, Atty.: David Fein AS JOINT TENANTS WITH RIGHT OF ALL THAT CERTAIN Unit, being SURVIVORSHIP. Unit No. 150 (the "Unit"), of The TAX PARCEL #10-15-1282-005. Courts at Brandywine,A Townhome U150. Condominium(the"Condominium"), located in Hampden Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of The Courts at Brandywine,A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds in Miscellaneous Book 721, Page 4798 and Right of Way Plan Book 13, Page 119 respectively, to- gether with any and all amendments thereto. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid Declaration of Condomini- um, as last amended. TOGETHER with the right to use the Limited Common Elements ap- plicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to any and all covenants,conditions,restric- tions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration of Condominium, and matters which a physical inspection or survey of the Unit and Common Elements would disclose. IMPROVEMENTS consist of a residential dwelling. 27 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 12, April 19 and April 26, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r C✓ a Marie CoynejEditor SWORN TO AND SUBSCRIBED before me this -6 da of A s ril 2013 / •_- Q. �i./ _ � Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 i T The Patriot-News Co.2020 Technology Pkwy patriotaXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 91 ( 2013-224 CIvII 04/16/13 GREEN TREE SERVICING,LLC vs. 04/23/13 ADRIANNE DEL TORO, a 04/30/13 Adrienne Deltoro Kenneth P.Drain • Atty: David Fein YR, ALL THAT CERTAIN Unit,being Unit j No. 150 (the "Unit"), of The Courts at Brandywine, A,Townhome Condominium Sworn to and su•scribed before me thi 13 day of May, 2013 A.D. I (the "Condominium"), located in Hampden Township,Cumberland County, . Pennsylvania,whichUnitisdesignated inthe t o / ' j' Dec Declaration of Condominium of The Courts �+ - - - at Brandywine,ATbwnhome Condominium "u bl Ic , (the"Declaration of Condominium")and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds in Miscellaneous Book 721,Page 4798 and Right of Way Plan Book 13,Page COMMONWEALTH OF PENNSYLVANIA 119 respectively,together with any and all Notarial Seal amendments thereto. TOGETHER with the undivided Holly Lynn Warfel,Notary Public percentage interest in the Common Washington Twp.,Dauphin County Elements appurtenant to the Unit as My Commission Expires Dec.12,2016 more particularly set forth in the aforesaid MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES Ilerlaratinn of (`nnrinminium "a _1.w._ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Assoc is the grantee the same having been sold to said grantee on the 7th day of August A.D., 2013, under and by virtue of a writ Execution issued on the 28th day of February, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 224, at the suit of Green Tree Servicing LLC against Adrianne Del Toro A/K/A Adrianne Deltoro and Kenneth P. Ursin is duly recorded as Instrument Number 201332724. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 3.-J day of , A.D. , . 0 /3 .. 4 a�. s My