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HomeMy WebLinkAbout13-0771KML LAW GROUP, P.C. ._ , SUITE 5000 - BNY MELLON INDEPENDENC~`CEI~- ~-~ ' rJi ~ r^ •:' t ~,,,,-_ 701 MARKET STREET ~ ~ ' ~ ~ ~ t ~ ~ ! ~ ~~~~ ~ r , , PHILADELPHIA,PA 19106 ~~~~' ~ (s66) a13-2311 2~'3 FE3 ~ S ~ f~ It?: ~. ~ WWW.KMLLAW(:ROIlP.('OM _ I 1 04 ArboFSRe FINANCIAL LP I`~'-i~'~` ~+~~'~~ ~~1~ Suite 200 Omaha, NE 68144 Plaintiff vs. JILL A. COWOSKI CHRISTOPHER J. COWOSKI Mortgagor(s) and Record Owner(s) 6 Spring Valley Lane Mechanicsburg, PA 17055 Defendant(s) ~, Y IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW NOTICE ACTION OF MORTGAGE FORECLOSURE )3-~>> l,~l~1) GML A~,1TON: MORTGAGE FORECL03LTRE 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 Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la cone 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 Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la Corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO~ SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAM S POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA g Ib~ 7S ~ AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. (~W1~ 950 ~~~ ? ~ ~~a~~ Sad 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 maybe 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: httn://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(cr~kmllawgroua 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 117780FC. Para informacion 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 MIDWEST FIRST FINANCIAL LP IV, 11904 Arbor Street, Suite 200 Omaha, NE 68144. 2. The name(s) and address(es) of the Defendant(s) is/are JILL A. COWOSKI, 6 Spring Valley Lane, Mechanicsburg, PA 17055 and CHRISTOPHER J. COWOSKI, 6 Spring Valley Lane, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 09, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MADISON EQUITY CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 27, 2006 as Book 1944, Page 2627. The mortgage has been assigned to: MIDWEST FIRST FINANCIAL LP IV by assignment of Mortgage recorded on Apri123, 2007 as Book 0736, Page 1342. 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 January O1, 2009 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 ..................................................................................$131,128.90 Interest from 12/01/2008 through 02/28/2013 at 10.0000% ...................$55,784.42 Per Diem interest rate at $36.42 Late Charges ............................................................................................$2,581.04 Monthly late charge amount at $58.65 Escrow ............................................. Suspense ............................ Reasonable Attorney's Fee ...........$10,925.30 ........... ($1,022.36) .............$1,650.00 $201,047.30 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, Plaintifl'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. Plaintiff is not seeking a judgment of personal liability (or an "in nersonam" 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 has been sent to Defendants by certified mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $201,047.30, together with interest at the rate of $36.42, 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 Sheriffls Sale of the Property. By: /~~ KML LAW GROUP, P Michael McKeever a. 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 ~C Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION 1, as the representative of the Plaintiff corporation within named do hereby verify that I am thorized 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: ~ r ~'~ ~ # 117780FC -JILL A. COWOSKI and CHRISTOPHER J. COWOSKI 6 Spring Valley Lane Mechanicsburg, PA 17055 Partner for Mi~WBSt First Financial Lior~ited Partnersh;pllt E~FiiditA THE FOLLOWING DESCRIBED REAL PROPERTY SITUATE IN THE TOWNSHIP UPPER ALLEN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA, TO WIT: ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, SHOWN AS LOT #76, PHASE II, BOWMAN'S HILL AS DESCRIBED IN ACCORDANCE WITH THE FINAL SUBDIVISION PLAN OF BOWMAN'S HILL PHASE II RECORDED IN CUMBERLAND COUNTY PLAN BOOK 68, PAGE 15, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE, A 50 FOOT RIGHT-OF-WAY, AT THE SOUTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN, THENCE ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF SPRING VALLEY LANE SOUTH 65 DEGREES 05 MINUTES 43 SECONDS WEST A DISTANCE OF 85.46 FEET TO A POINT AT THE SOUTHEASTERN CORNER OF LOT #75 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #75 NORTH 24 DEGREES 54 MINUTES 17 SECONDS WEST A DISTANCE OF 116.12 FEET TO A POINT AT THE 50UTHERN LINE OF LANDS NOW OR FORMERLY OF KEENETIi R, WHITE AND MARTHA C. WHITE; THENCE ALONG SAID LANDS NOW OR FORMERLY OF WHITE NORTH 63 DEGREES 53 MINUTES 50 SECONDS EAST A DISTANCE OF 85.48 FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT #77 ON THE AFOREMENTIONED PLAN; THENCE ALONG SAID LOT #77 SOUTH 24 DEGREES 54 MINUTES 17 SECONDS EAST A DISTANCE OF 117.91 FEET TO A POINT AND PLACE OF BEGINNING. CONTAWING 10,000 SQUARE FEET. TAX ID #: 42-29-2454-255 BY FEE SIMPLE DEED FROM DAVID R THOMPSON AND DENISE P. THOMPSON, HIS WIFE AS SET FORTH IN DEED BOOK 187, PAGE 501 AND RECORDED ON lOrL0/1998, CUMBERLAND COUNTY RECORDS. THE SOURCE DEED AS STATED ABOVE iS THE LAST RECORD OF VESTING FILED FOR THIS PROPERTY. THERE HAVE BEEN NO VESTING CHANGES SINCE THE DATE OF THE ABOVE REFERENCED SOURCE. 1801778 E.~Fii6it ~ *Exhibit has been redacted to remove all personally identifiable information or non public information . ACT 91 NOTICE Tp-~{E ACTION TO SAVE YOUR HOME FROM DATE : June 7 , 2 012 FO~ C ~ O IJ URE To: Christopher J. Cowoski Jill A. Cowoski 6 Spring VaIIey Lane Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED.FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, This is an official notice that the mortgage on your home is in default and the lender intends to foreclosure. Specific information about the nature of the default is provided in the atta.ched~a~es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM !H_FMAPI matibe able to help to 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 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with you when you meet the Caunselin~ 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 oy u may call the Pennsylvania Hausine Finance Agency toll flee at 1-800-342 2397 Persons with impaired hearin¢ can calf 1717) 784-1869 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. Yau may also want to contact an attoxney in your area. The Local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJiJNTO ES DE SUMA IMPORTANCIA, PUEDE 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 ELIIGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. STATEMENTS OF POLICY HOMEOWNER'S NAME(S): Christopher J. and Jill A Cowoski PROPERTY ADDRESS: b S ring Valley Lane Mechanicsburg, PA 17055 LOAN ACCT. NO.: ~3PA ORIGINAL LENDER: Madison Equity LLC CURRENT LENDER/SERVICER: Midwest First Financial Limited Partnership IV HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTLTRF 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 HAS 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 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 three (33) days from the date of this Notice. During that time you must arrange and attend aface-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 (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HO W 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 thi tluee(33~ 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 otice. 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 a 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 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 three {33) 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 (50) days to make a decision after it receives your application. During that time, na 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 PURPOSE 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 HOW TO CURE YOUR MORTGA E DEFAULT Bring it up to date NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 318 North Felton Street Philadelphia, PA 19139 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS fox the following months and the fallowing amounts are now past due: Start/End: 6/1/09 thin 6/I/IZ at 51,173.13 per month. Monthly Payments Plus Late Charges Accrued $2,111.76 NSF: $0.00 Accrued Late Fees: $0.00 Escrow Advances: $12,364.16 (Suspense}: ($1,022.361 Total amount to cure default $S6,SS9.49 1=IOW TO CURE THE DEFAULT-You may cure the default within THIRTY THREE (33}DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $56,859.49, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY THREE (33) DAY PERIOD. As of the date of this letter, you owe the amount specified above. Because of interest, late charges, and other charges that may vary fiom day to day, the amount due on the day that you pay may be greater. Hence, if you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned ar call {402) 330-2274 and ask for the Aaron Whaley. Payments must be made either by cash, cashier's check certified check or money order made payable and sent to: Midwest First Financial Limited Partnership IV, 11904 Arbor Street Suite 200, Omaha, NE 68144. You can cure any other default by taking the following action within THIRTY THREE (33}DAYS of the date of this letter. IF YOU DO NOT CURE THE DEFAULT-If you da not cure the default within THIRTY THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the martga e debt The means that the entire outstanding balance of this debt will be considered due inunediateiy and you may lase the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY THREE {33) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure upon your mortgage pro e~rty,, IF THE MORTGAGE IS FORECLOSED UPON- The mortgage 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 lender 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 attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount to the lender, which may also include other xeasonable costs. If you cure the default within the THIRTY THREE (33) 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 THREE (33} DAY period and foreclosure proceedings have begun, ~~ still have the right to cure the default and prevent the sale at env time un to one hour before the Sheriff's Sale You may do so by paving the total amount then ast due lus an late or other char es then d e re a attorne 's fees and costs connected with the foreclosure sale and env other costs connected with the Sheriff s Sale as specified in wrsting by the lender and by.~performin~ 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 mortgage property could beheld would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER' Midwest First l~nancial Limited Partnership TV 11904 Arbor Street Suite 200 Omaha, NE 68144 (402) 330-2274 Contact Person: Aaron Whaley $FFECT 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 Sheriff's 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 sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cast are paid prior to or at the sate 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 NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT 1N 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 1S ATTACHED If this is the first notice that you have received from this office, be advised that: You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty three (33) days from the date of this letter, this firm will obtain and provide you with written verification thereof; otherwise the debt will be assumed to be valid, Likewise if requested within thirty three (33) days from the date of this letter, the firm will send you the name and address of the original creditor if different from above. Very truly yours, Aaron Whaley Vice President Account No.: ~3PA Mailed by 1ST Class wail and by certified Mail No: 70080150000314112030 & 70080150000310112047 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~' MIDWEST FIRST FINANCIAL LPN •-~f~ w ~;~' -~, Plaintiff ^~ ~ ~ ~ '' '~ ~ ` ~ F:. 1 ~ -? vs. Case No. ~ I j - ~ ~ ~ ,~ ~ .. JILL A. COWOSKI ~ ~ ~~: CHRISTOPHER J COWOSKI ~'' ~ ~ ~' . Defendant(s) ~, c ~? ~~ .r- ~> „r NOTICE OF RESIDENTIAL MORTGAGE FORECLO~U~Ef` 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 STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respect ly s bmitted: (Signature of Counsel amtiff) 2/13/2013 Date Cumberland County Residential Mortgage Foreclosure Diversion Program ll+inancial WarksF-eet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST P"OR HARDSHIP ASSISTANCE To complete•your request far hardship assistance, your lender must consider your circumstances to determine passible options while working with your _ Pleaso provide the following information to the best of your knowledge: Borrower names}: Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Ivlailing Address (if different) Cify: Phone Numbers: Email: ofpeople in household: State: Zip: Ycs ^ No Q Listing date: Price: $ Realtor Phone: Ye.~ No Home: Cell: Offcce: _ Other: How long? Mailing Address: City; State: Zip: Phone ?Vuanbers: Home: Geil: Email; # ofpeople in household: First Mortgage Lender; Type of Loan: Office. Other: How long? _ -__.._. . aan urn er: Date You Closed Your Loan: _ Second Mortgage Lender: Type of Loan: Loan Number: • Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for 1~efault: Is the loan Xn 8ar~krupfcy? 'Yes ^ No if yes, provide names, location of court, case number & attorney: Assets Amounr Owed: Walue: i-iome: $ --- - - $ Other Real Estate: $_ $ Retirement Funds: $ $ investments: Checking: ~ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: ~.. Value: Antic mobile #2: Model Year: Amount owed; Value: Other transportation fautomobiles,~boats. motorcycles): Model: Year: Amount owed: Value lVlanthty Income Name of Employers: 1. ~. 3. Additional Income Description (nat wages}: .- monthly amount: 2. monthly amount: Borrower Pay Days:. Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying,} EXPENSE AMOUNT EXPENSE AMOUNT Ma a Food 2 M c Utilities Car Pa .ens Cando/Nei .Fees Auto Insurance Med. not covtrcd Auto fuel/re irs Qther ra . a ment Install. L©an F'a ment Cable TV Child Su rrlAtirn. S ndin Mone Da iChild CarClTuit. Other Ex nses Arnaunt Available for Monthly Mortgage Payments Based on Income 8t Expenses: Have you been working with a Housing Counseling Agency? Yes (~ No If yes, please provide the following information: Caux~seling Agency: Counselor: Pt~onc (Office): Fax;T ) :mail;. Have you made application for Homeowners 1/rnergency Mortgage Assistance Program (HEMAI') assistance? Yes Q Na (~ if yes, please indicate tlac status of the application: Have you had any prior negotiations with your tender or lender's loan servicing company fo resolve your delinquency? Yes ^ No ;f yes, please indicate the status of those negotiations. )'lease provide the following nforrnatian, if know, regarding your Iendcr or lender's loan servicing carnpany: Lender's Contact (Name): Servicing Company (Name}:r Contact: Phone: Phone: T/We, , authori2e the above named _ _ to use/refer this infomnation to my lender/servicer far the sole purpose of evaluating my financial situation for passible mortgage options. IIWe understand that Ilwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Ca-Borrower Signature Date Flease forward #his document slang with the fallowing information to Mender and lend--errr's counsel: Y .Proof of income ~Y Past 2 bank statements V Proof of any expected income far the last ~5 days Copy ofa current utility bill . Letter explainiing reason far deliuquer~cy and any supporting documentation l r (hardship letter} Y Listing agreemeett (if property is currently on the market) FORM 3 MIDWEST FIRST FINANCIAL LP IV : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA c- Plaintiff(s) _ `� ti ' rpl _, VS. -.73 r�- - t C "t . JILL A. COWOSKI rte- r_ CHRISTOPHER J. COWOSKI 13-771 Defendant(s) Civic -'- �' REQUEST FOR CONCILIATION CONFERENCE : ;_ Pursuant to the Administrative Order dated February 2 8 , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. , The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. //14/"/ S /1/8 Z6C Wayne . � Date Attorney I . D. No. 208078 Reager & Ad r, P.C. r b y dvi3 J 1/ )42 owoski / Date r ' 614/0.1.' L Chri stoph1 J. Cowoski Date I CERTIFICATE OF SERVICE I, Alana L. Souders, Paralegal to Wayne S. Martin, Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing Request for a Conciliation Conference, to be served upon the following counsel of record via First Class U.S. Mail, postage prepaid, addressed as follows: David Fein, Esquire KML Law Group, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Dated: April 18, 2013 N C cLA-f Q% ' 3 MIDWEST FIRST FINANCIAL IN THE COURT OF COMMON PLEAS OF LP IV CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION NO. 13-0771 CIVIL JILL A. COWOSKI and CHRISTOPHER J. COWOSKI Defendants CASE MANAGEMENT ORDER AND NOW, this qa day of 2013, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on ,Q-02, owl-3 , at 3,36 ,,2, m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendantiborrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. 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 may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement;paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage;paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, Kevin . Hess, P.J. /avid Fein, Esquire KML Law Group, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 For the Plaintiff ,,Wayne S. Martin, Esquire 2331 Market Street J i�� Camp Hill, PA 17011 0` For the Defendant �� 0 :rlm C�z C, -9 A� tc 57>4=: FM co i MIDWEST FIRST FINANCIAL IN THE COURT OF COMMON PLEAS OF LP IV CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff C= 4, VS. CIVIL ACTION va w rncu Y NO. 13-0771 CIVIL . .� SAr JILL A. COWOSKI and CHRISTOPHER J. COWOSKI c7) Defendants C CD IN RE: CONCILIATION CONFERENCE _7? Present at a conciliation conference held June 21, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Wayne S. Martin, Esquire, attorney for the defendants. The order entered of even date herewith is the subject of a stipulation of the parties. ORDER AND NOW,this a4 ` day of June, 2013, continued conciliation conference is set in this matter for Friday, July 26, 2013, at 4:00 p.m. in Chambers of the undersigned. Pending further conciliation, the defendants will pay the outstanding real estate tax liabilities for 2012 and 2013, and pay to the bank the difference between those total tax liabilities and the sum of$5,000. Said payments will be made within thirty (30) days. If the aforementioned payments have been made prior to the conciliation conference set on July 26, 2013,that conciliation conference will be cancelled. By way of further understanding, it is directed that the defendants pay the sum of $10,925.30 to the plaintiff, together with their tax obligation for the years 2012 and 2013 within 60 days. BY THE COURT, Kevin Hess, P. J. /Nathan Wolf, Esquire For the Plaintiff /Wayne Martin, Esquire 'For the Defendants :rlm a'Z �9 - i MIDWEST FIRST FINANCIAL IN THE COURT OF COMMON PLEAS OF LP IV Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION NO. 13-0771 CIVIL JILL A. COWOSKI and CHRISTOPHER J. COWOSKI : Defendants ORDER AND NOW, this 30` day of July, 2013, the conciliation conference set for July 26, 2013, is continued to Friday, August 30, 2013, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. /Nathan Wolf, Esquire For the Plaintiff ✓Wayne Martin, Esquire For the Defendants M :rlm Q 2 MIDWEST FIRST FINANCIAL IN THE COURT OF COMMON PLEAS OF LP IV CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION NO. 13-0771 CIVIL JILL A. COWOSKI and CHRISTOPHER J. COWOSKI Defendants ; ORDER AND NOW, this 2&V day of August, 2013, the within matter is removed from the Cumberland County Mortgage Conciliation Program and the stay entered in this case is VACATED. The conciliation conference set for Friday, August 30, 2013, is cancelled. BY THE COURT, "Ok Kevin ess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff ./Wayne Martin, Esquire For the Defendants :rlm C= Mat LL Cl��' ra co ; -� " --ate ZJ:n' . ::7� CDC" :Z Cn In the Court of Common Pleas of Cumberland County MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha,NE 68144 No. 13-771 Plaintiff VS. JILL A. COWOSKI �• CHRISTOPHER J.COWOSKI Mort a or s and Record Owner (s) 6 Spring Valley Lane := Mechanicsburg,PA 17055 - - , .' Defendant(s) c_�° '1 © PRAECIPE FOR JUDGMENT tv THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A b�BT=1 OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against JILL A.COWOSKI and CHRISTOPHER J.COWOSKI by default for want of an Answer. Assess damages as follows: $211,007.93 Debt - Interest from 11/15/2013 to Date of Sale per diem at$36.42 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or de ivered o the party against whom judgment is to be entered and to his attorney of record,if any,after the default o d !d at le t ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.237.1 By: KNIL LAVG %bkT, _Michael McKeever Pa,I 6129 _Jay E.Kivitz Pa.ID 26769 =Lisa Lee Pa.u ID 78020 a.I ^„�� c ) a Ny Kristina Murtha Pa.ID 61858 (J`'"`' � t' _David Fein Pa.ID 82628 q Thomas Puleo Pa.ID 27615 l.�ug 7 5 s ! Joshua I.Goldman Pa.205047 r�4 el �/ Jill P.Jenkins Pa.ID 306588 11C _Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff ��1� •`� AND NOW 1 �bj? ,Judgment is entered in favor of. MIDWEST FIRST FINANCIAL LP IV and against JILL A. COWOSKI and CHRIST R J�GOW y default for(rf want of an Answer and damages assessed in the sum of$211,007.93 as per the above cerotication. r Prothon Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha,NE 68144 Plaintiff No. 13-771 VS. JILL A.COWOSKI CHRISTOPHER J.COWOSKI (Mortgagors and Record Owner(s) 6 Spring Valley Lane Mechanicsburg,PA 17055 Defendant(s) 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. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square,, Carlisle,PA 17013 Prothonotary By: 1 11q �13° _--Deputy I If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 117780FC 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. DATE OF THIS NOTICE: October 30,2013 TO: JILL A.COWOSHI COWOSKI,JILL A. 6 Spring Valley Lane Mechanicsburg,PA 17055 In the Court of MIDWEST FIRST FINANCIAL LP IV Common pleas 11904 Arbor Street of Cumberland County Suite 200 Omaha,NE 68144 Plaintiff CIVIL ACTION-LAW vs. JILL A.COWOSKI Action of CHRISTOPHER J.COWOSKI a Mortgage ForecIosure ' (Mortgagor(s)and Record Owner(s)) 6 Spring Valley Lane No. 13-771 Mechanicsburg,PA 17055 Defendant(s) TO: JILL A.COWOSKI 6 Spring Valley Lane Mechanicsburg,PA 17055 IMPORTANT NOTICE 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 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 ME 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 WC 8 hvine Row Carlisle,PA 17013 717-243-9400 Dy. KML LAW OUP,P-C. Michael McKeever Pa.ID 56129 - Lisa Lee Pa.ID 73DZO _Krisfina Murtha Pa.ID 61558 _David Feiu Pa.ID$2628 on¢as Paleo Pa.ID 27615 P.Jenkins Pa.ID 306588 Alyk L.Ortaaan Pa.ID 312912 _Wvatorc Fdippc%Pa.ID 313897 _Michael I Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff - I 117780FC 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 i PURPOSE OF COLLECTING THE DEBT. i I' DATE OF THIS NOTICE: October 30,2013 I_ I I. I TO: _ CHRISTOPHER J COWOSE1 COWOSKI,CHRISTOPHER J. 6 Spring Valley Lane Mechanicsburg,PA 17055 In the Court of MIDWEST FIRST FINANCLkL LP IV Common Pleas 11904 Arbor Street of Cumberland County Suite 200 Omaha,NE 68144 Plaintiff CIVIL ACTION-LAW Vs. JILL A.COWOSKI Action of CHRISTOPHER J.COWOSKI Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 6 Spring Valley Lane No. 13-771 Mechanicsburg,PA 17055 I- Defendant(s) TO: CHRISTOPHER J.COWOSIG 6 Spring Valley Lane Mechanicsburg PA 17055 i IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FARED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITJNG 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}TEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TARE 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 HRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WHH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 21abedyAvenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Twine Row Carlisle,PA I7013 717-243-9400 By: 10tL LAW GROYIP,P.C. MicLad McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 _Kristin Murtha Pa.ID 61858 _David Fein Pa.ID 82628 Z omas Puleo Pa.ID 27615 Jenkins Pa.ID 306588 yk L.Oflaziau Pa.ID 312912 _Salvatore Filippella Pa.ID 313897 _Michael J.Coskey Pa ID 311835 215427-1322 AttomeyS for Plaintiff 117780FC 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. DATE OF THIS NOTICE: October 30,2013 TO: Wayne S.Martin Esq Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 In the Court of MIDWEST FIRST FINANCIAL LP IV Common Pleas 11904 Arbor Street of Cumberland County Suite 200 Omaha,NE 68144 Plaintiff CIVIL ACTION-LAW VS. JILL A.COWOSKI Action of CHRISTOPHER J.COWOSKI Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 6 Spring Valley Lane No. 13-771 Mechanicsburg,PA 17055 Defendant(s) TO: Wayne S.Martin Esq 2331 Markct Strcct Camp Hill,PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FA1IZD TO ENTER A WRrr EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN W MIN('WITH THE COURT YOUR DFFFKSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU UNI FSS YOU ACT WITHIN YETI(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGARNT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LASE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 W1IH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE- CUMBERLAND COUNTY BARASSOCIATION 2 Libuty Avenue Cadtisle,PA 17013 LEGAL SERVICES INC 8Irvine Row Carlisle,PA 17013 717-243-9400 BS"• -. . KML LAW GR UP,P.C. Michael McKeever Pa.10 56129 _Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 _David Fein Pa_ID 82628 _Thomas Pukro Pa.ID 27615 AH P.Jenkins Pa.ID 306588 Alyk L Onazian Pa.m 312912 _Salvatore Fdippello Pa.ID 3LM97 _Michael J.Coskey Pa ID 311835 215.627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MIDWEST FIRST FINANCIAL LP IV Plaintiff vs. JILL A.COWOSKI NO. 13-771 CHRISTOPHER J.COWOSKI Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): JILL A. COWOSKI, has a last known residence of c/o Wayne S. Martin, Esquire/Reager & Adler, P.C., 2331 Market Street, Camp Hill, PA 17011. The following information was used to search the DMDC(check all that-apply): X_Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. A1004 lating to unsworn falsification to authi iti s. Date �3 By: ' KML LAW GRO ,P. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Aji11 P.Jenkins Pa. ID 306588 lyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Nov-14-2013 12:51:48 SCRA 3.0 Stag Report .. f' Pursuant t4 Sery eemembers Civil Relief Act. �a Last Name: COWOSKI First Name: JILL Middle Name: A. Active Duty Status As Of: Nov-14-2013 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 Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date t r. The Member or HislHer 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 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. y6_ 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.htmi. 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: 0501G02AJ04AH2O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA MIDWEST FIRST FINANCIAL LP IV Plaintiff vs. JILL A.COWOSKI NO. 13-771 CHRISTOPHER J.COWOSKI Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): CHRISTOPHER J. COWOSKI,has a last known residence of c/o Wayne S. Martin, Esquire/Reager & Adler, P.C., 2331 Market Street, Camp Hill, PA 17011. The following information was used to search the DMDC(check all that apply): X Last Name X First Name X_Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4 04 r ating to unsworn falsification to authori,' Date J l� By: KML LAW GROUP, .C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa.ID 313897 Jill P.Jenkins Pa. ID 306588 lyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Nov-14-201312:50:32 SCRA 3.0 �I Status. R Cir't Pursuant to Servicemembers (civil Relief Act Last Name: COWOSKI First Name: CHRISTOPHER Middle Name: J. Active Duty Status As Of: Nov-14-2013 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 Start Dale Active Duty End Date Status Service Component NA NA _:. - No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date x The Member or His/Her Unit Was Notified of a Future CalWp 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 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. fit 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.htmi. 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(NOAH 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: F51APOFABO49130 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street IN THE COURT OF COMMON PLEAS Suite 200 Omaha,NE 68144 of Cumberland County Plaintiff vs. CIVIL ACTION LAW JILL A.COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s)and Record owner(s) ACTION OF MORTGAGE FORECLOSURE 6 Spring Valley Lane Mechanicsburg,PA 17055 Defendant(s) No. 13-771 ORDER FOR JUDGMENT Please enter Judgment in favor of MIDWEST FIRST FINANCIAL LP IV,and against JILL A.COWOSKI and CHRISTOPHER J.COWOSKI for failure to file an Answer in the above tion vithin 0)day : om the date of service of the Complaint,in the sum of$211,007.93. By: KML LAW UOUP,P. 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 IJill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 Omaha,NE 68144 and that the names)and last known address(es)of the Defendant(s)is/are JILL A. COWOSKI,c/o Qne,,S.Martin,Esquire/Reager&Adler,P.C.2331 Market Street Camp Hill,PA 17011 and CHRISTOPHER J.COWOS /o yne .Mart' ,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011; By: KML LAW Michael McKe ver 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 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $131,128.90 Interest from 12/01/2008 through $65,217.20 11/14/2013 Reasonable Attorney's Fee $1,650.00 Late Charges $3,108.89 Escrow $10,925.30 Suspense ($1,022.36) $211,0 7.93 By: KML LAW ftOuir, Michael McKeever Pa.ID 56129 _ Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa.205047 17Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff AND NOW,this day of ) r DV' 2013 damages ar ssesse4.iLs aboVasm w Pro Prothy 13-771/117780FC " PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 .1y ,.;q,... - v f r l� KML Law Group,P.C. Suite 5000-BNY Independence Center ? +3 No, g � 701 Market Street Pt1 2: Philadelphia,PA 19106 (. e ,�F t�� *dD COUNTY 215-627-1322 PE P01S Y VA N I A Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street Suite 200 IN THE COURT OF COMMON PLEAS Omaha,NE 68144 Plaintiff of Cumberland County vs. CIVIL ACTION—LAW JILL A.COWOSKI CHRISTOPHER J.COWOSKI ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 6 Spring Valley Lane Mechanicsburg,PA 17055 No. 13-771 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $211,007.93 Interest from 11/15/2013 to Date of Sale per diem at $36.42 (Costs to be added) a B ag � y: �( i • C.� K1% LAW UP,P.C. `-1 Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 tt t� Lisa Lee Pa.ID 78020 1 s O Kristina Murtha Pa.ID 61858 1 David Fein Pa.ID 82628 a Thomas Puleo Pa.ID 27615 .oLt k Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff P* V z z a 0 w o ¢ ° o _ r - ° z o a � � U d �" d'� a � N rq � p d � O a 55 O o � V ti F o a. � w w > 3w � > aw 0 o � N ' 0 N Q �p O d a O O .� V (]a ti F+ bb w po p 3 U o Pi t' z � � a All That Certain Tract Of Parcel Of Land Situate In Upper Allen Township, Cumberland County, Pennsylvania, Shown As Lot#76, Phase II, Bowman's Hill As Described In Accordance With The Final Subdivision Plan Of Bowman's Hill Phase II Recorded In Cumberland.County Plan Book 68, Page 15, More Particularly Described As Follows, To Wit: Beginning At A Point On The Northern Right-Of-Way Line Of Spring Valley Lane, A 50 Foot Right-Of-Way, At The Southwestern Corner Of Lot#77 On The Aforementioned Plan, Thence Along Said Northern Right-Of-Way Line Of Spring Valley Lane South 65 Degrees 05 Minutes 43 Seconds West A Distance Of 85.46 Feet To A Point At The Southeastern Corner Of Lot#75 On The Aforementioned Plan; Thence Along Said Lot #75 North 24 Degrees 54 Minutes 17 Seconds West A Distance Of 116.12 Feet To A Point At The Southern Line Of Lands Now Or Formerly Of Keeneth R. White And Martha C. White; Thence Along Said Lands Now Or Formerly Of White North 63 Degrees 53 Minutes 50 Seconds East A Distance Of 85.48 Feet To A Point At The Northwestern Corner Of Lot#77 On The Aforementioned Plan; Thence Along Said Lot #77 South 24 Degrees 54 Minutes 17 Seconds East A Distance Of 117.91 Feet To A Point And Place Of Beginning. Containing 10,000 Square Feet. Tax Id#: 29-2454-0255-0000000-42 IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Upper Allen Township BEING PREMISES: 6 Spring Valley Lane,Mechanicsburg,PA, 17055 SOLD as the property of Christopher J. Cowoski and Jill A. Cowoski TAX PARCEL#29-2454-0255-0000000-42 BEING the same premises which David R. Thompson and Denise P. Thompson, his wife by deed dated 10/13/1998 and recorded 10/20/1998 in Cumberland County in Deed Book Volume 187 at Page 501 granted and conveyed unto Christopher J. Cowoski and Jill A. Cowoski, his wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-771 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDWEST FIRST FINANCIAL LP IV Plaintiff(s) From JILL A. COWOSKI,CHRISTOPHER J.COWOSKI (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: $211,007.93 L.L.: $.50 Interest FROM 11/15/2013 TO DATE OF SALE PER DIEM AT$36.42 Atty's Comm: Due Prothy: $2.25 Atty Paid: $202.75 Other Costs: Plaintiff Paid: Date: 11/19/13 r David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.306588 y KML Law Group,P.C. Suite 5000—BNY Independence Center I - '' 701 Market Street ;;f;- 4,,-- rr iu, _,i 0iii11 ' Philadelphia,PA 19106 iii 'fi 215-627-1322 �� , Attorney for Plaintiff PPP 2. 56 MIDWEST FIRST FINANCIAL LP IV PEbyNS`�f�.�r,� AA 1 Y 11904 Arbor Street IN THE COUR 6KOMMON PLEAS Suite 200 Omaha,NE 68144 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW JILL A. COWOSKI CHRISTOPHER J. COWOSKI (Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 6 Spring Valley Lane Mechanicsburg,PA 17055 Defendant(s) No. 13-771 AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV,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: 6 Spring Valley Lane Mechanicsburg,PA 17055 LName and address of Owner(s)or Reputed Owner(s): JILL A.COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 CHRISTOPHER J.COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 2.Name and address of Defendant(s)in the judgment: JILL A.COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 CHRISTOPHER J.COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 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 MIDWEST FIRST FINANCIAL,LIMITED PARTNERSHIP IV 11904 Arbor Street, Ste 200 Omaha,NE 68144 UPPER ALLEN TOWNSHIP 100 Gettysburg Pike 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION,INC. 2411 Rolling Hills Drive Mechanicsburg,PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg,PA 17055 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 unsworn falsification to author ies. DATED: 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 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff it 13-771 KML Law Group,P.C. Suite 5000-BNY Independence Center '" ' �++ A,O Tr- -t 701 Market Street .n �v 0 V 19 P� 2' 3 Philadelphia,PA 19106 L 113 (215)627-1322 CUIMMERL ND�;{) NTY Attorney for Plaintiff s ill E� f MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street IN THE COURT OF COMMON PLEAS Suite 200 Omaha,NE 68144 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. JILL A. COWOSKI ACTION OF MORTGAGE CHRISTOPHER J. COWOSKI FORECLOSURE Mortgagor(s)and Record Owner(s) 6 Spring Valley Lane Mechanicsburg,PA 17055 Docket No. 13-771 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: COWOSKI,JILL A. JILL A. COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 Your house at 6 Spring Valley Lane,Mechanicsburg,PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday,March 12,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$211,007.93 obtained by MIDWEST FIRST FINANCIAL LP IV 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 MIDWEST FIRST FINANCIAL LP IV,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. 13-771 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 13-771-- 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 117780FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-771 KML Law Group P.C. Suite 5000-BNY Independence Center 701 Market Street G'ii 13 �vv 19 pm, Philadelphia,PA 19106 2: 56 '13-PRLAND C (215)627-1322 -;U� oUt4.1_ Attorney for Plaintiff PENN'S j, - Y MIDWEST FIRST FINANCIAL LP IV 11904 Arbor Street IN THE COURT OF COMMON PLEAS Suite 200 Omaha,NE 68144 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. JILL A. COWOSKI ACTION OF MORTGAGE CHRISTOPHER J. COWOSKI FORECLOSURE Mortgagor(s)and Record Owner(s) - 6 Spring Valley Lane Mechanicsburg,PA 17055 Docket No. 13-771 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: COWOSKI,CHRISTOPHER J. CHRISTOPHER J. COWOSKI c/o Wayne S.Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 Your house at 6 Spring Valley Lane,Mechanicsburg,PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday,March 12,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$211,007.93 obtained by MIDWEST FIRST FINANCIAL LP IV 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: I. The sale will be cancelled if you pay to MIDWEST FIRST FINANCIAL LP IV,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. 13-771 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 13-771 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 117780FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML LAW GROUP,P.C. 117780FC Suite 5000 CF: 02/15/2013 'rk' riir9)6 J "of �" SD: 03/12/2014 BNY Mellon Independence Center -� �-1__#�. � ; 701 Market Street j `� f' i it f s $211,007.93 215 627p1322 PA 19106-1532 ���(��'�� �'� Attorne for Plaintiff CLI' ` . • - MIDWEST FIRST FINANCIAL LP IVPENNS YL ,A nR F '1' IN THE COURT OF COMMON PLEAS 11904 Arbor Street Suite 200 of Cumberland County Omaha,NE 68144 Plaintiff CIVIL ACTION—LAW vs. ACTION OF MORTGAGE FORECLOSURE JILL A. COWOSKI CHRISTOPHER J. COWOSKI Term Mortgagor(s)and No. 13-771 Record Owner(s) 6 Spring Valley Lane Mechanicsburg,PA 17055 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Veronica Cosme, 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: ( ) Personal Service by the Sheriffs Office/competent adult(copy of return attached). ( ) Certified mail by KML Law Group,P.C. (copy of green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. (X) Ordinary mail by KML Law Group,P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs 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. (copy of 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, Vbierna B Veronica Cosme Legal Assistant I Name and Address of Sender Check type of mail or service; Affix Stamp Here ' ' KML LAW GROUP,P.C. (If Issued asa SUITE 5000 ❑Certified ❑Recorded Delivery(International) certificate d mailing, ' 701 MARKET STREET ❑COD ❑Registered or for additional copes PHILADELPHIA, E ❑ Delivery Confirmation ❑ Return Receipt for Merchandise of this bill) ❑Express Mall ❑ Signature Confirmation Postmark and 19106-1532 ❑Insured Date of Receipt Arficte Number Addressee(Narriq Sreat,pry,Slate,&DP Code) Postage Fee Handing Actual Value Insured Due Sender DC SC SH RD RR ' Charge If Registered Value NC00 Fee Fee Fee Fee Fee "- 1. COWOSKI,JILL A. BOWM N'S HILL OMEOWVERS •••r do Wayne S.Martin,Esquire/Reager&Adler,P.C. ASSOCI TION,IN . i 2331 Market Street 2411 R ling Hills rive ' Camp Hill,PA 17011 Mechanl sburg,P 17055 2. COWOSKI,CHRISTOPHERJ. TENAN S/OCCUP NTS Py do Wayne S.Martin,Esquire/Reager&Adler,P.C. a O M ;i: 2331 Market street 6 Spring Valley Lae .r4.,f.+ � �''�.��i. i '<• Camp Hill,PA 17011 Mechanl burg,P• 17055 ;�i;. {{' .,,,��..,,o 3. DOMESTIC RELATIONS OF CUMBERLAND k . : 0 2 1M $ 0680 COUNTY t 0009285957 DEC 11 2013 PO Box 320 MAIIED FROM ZIPCODE 7 8106 Carlisle,PA 17013 4. PA DEPARTMENT OF PUBLIC WELFARE- Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 • P.O.Box 2675 ><.' 5. -arns.urg, •• 1 - MIDWEST FIRST FINANCIAL,LIMITED PARTNERSHIP IV IIIII • 11904 Arbor Street.$ 6. Omaha,NE 68144 UPPER ALLEN TOWNSHIP 100 Gettysburg Pike Milli•': •.4 8. ' Total Number of Pieces Total Number of Pieces Postmaster,Per(Name of receiving employee) ' ' •.i j,3 ___�. listed by sender Received at Post Ofr�ce t.'" p See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page 1 of 2) • Complete by Typewriter,i k, 'orr EMILPoint Pen 117780FC Cumberland County Sale Date:03/12/2014 • • JILL A.COWOSKI&CHRISTOPHER J.COWOSKI t l��5 KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff MIDWEST FIRST FINANCIAL LP IV IN THE COURT OF COMMON PLEAS 11904 Arbor Street Suite 200 of Cumberland County Omaha,NE 68144 Plaintiff CIVIL ACTION-LAW vs. JILL A. COWOSKI ACTION OF MORTGAGE FORECLOSURE CHRISTOPHER J.COWOSKI Mortgagor(s)and Record Owner(s) Term No. 13-771 6 Spring Valley Lane Mechanicsburg,PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 MIDWEST FIRST FINANCIAL LP IV,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: 6 Spring.Valley Lane Mechanicsburg,PA 17055 1.Name and address of Owner(s)or Reputed Owner(s): JILL A. COWOSKI c/o Wayne S. Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 CHRISTOPHER J. COWOSKI c/o Wayne S. Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 2.Name and address of Defendant(s) in the judgment: JILL A. COWOSKI c/o Wayne S. Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 ` CHRISTOPHER J. COWOSKI do Wayne S. Martin,Esquire/Reager&Adler,P.C. 2331 Market Street Camp Hill,PA 17011 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 MIDWEST FIRST FINANCIAL,LIMITED PARTNERSHIP IV 11904 Arbor Street, Ste 200 Omaha,NE 68144 UPPER ALLEN TOWNSHIP 100 Gettysburg Pike 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. BOWMAN'S HILL HOMEOWNERS ASSOCIATION, INC. 2411 Rolling Hills Drive Mechanicsburg,PA 17055 TENANTS/OCCUPANTS 6 Spring Valley Lane Mechanicsburg,PA 17055 4 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 unsworn falsification to authorities. DATED: February 17,2014 L L Group,P.C. BY: Veronica Cosme Legal Assistant • J' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFIC'E OF 2HES„•ERWF O;F.THE PROTHONOTARY 2Ci4MAY -6 PM 2:01 CUMBERLAND COUNTY PENNSYLVANIA Midwest First Financial LP IV vs. Jill A Cowoski (et al.) Case Number 2013-771 SHERIFF'S RETURN OF SERVICE 01/09/2014 03:23 PM - Deputy Dennis Fry, 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 6 Spring Valley Lane, Upper Allen - Township, Mechanicsburg, PA 17055, Cumberland County. 03/12/2014 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 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 125,000.00 to Attorney Karl Ledebohm, on behalf of Midfirst First Financial Limited Partnership IV, being the buyer in this execution, paid to the Sheriff the sum of $ 04/11/2014 Proposed Schedule Of Distribution Posted SHERIFF COST: $3,663.38 SO ANSWERS, May 01, 2014 RONNY R ANDERSON, SHERIFF tvStnte SheritP, Te eosoft, Inc. 9/�' '60 3 ©5 JS- On December 20, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 6 Spring Valley Lane, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: December 20, 2013 By: Real Estate Coordinator b0 :fl V OZAON[102 dd `,11hRLJ u'y''i 163: r11J JjI23]HS AHI 3JIJJO LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2013-771 Civil Term Midwest First Financial LP IV vs. Jill A. Cowoski Christopher J. Cowoski Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 6 Spring Val- ley Lane, Mechanicsburg, PA 17055. SOLD as the property of JILL A. COWOSKI and CHRISTOPHER J. COWOSKI. TAX PARCEL # 42-29-2454-0255. 25 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: January 24, January 31, and February 7, 2014 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)/1/1:\^... , Marie oyne Editor SWORN TO AND SUBSCRIBED before me this day of February, 2014 Notary A••••=_ _ NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot -News Co. 2b20 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 be patriotNews Now you know 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 the Assistant Controller 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 2013-771 Civil Term Midwest First Financial LP IV Vs Jill A Cowoski Christopher J Cowoski Atty: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 6 Spring Valley Lane Mechanicsburg, PA 17055 SOLD as the property of JILL A. COWOSICI and CHRISTOPHER J. COWOSKI TAX PARCEL # 42-29-2454-0255 This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Sworn to and ubscribed before me t s 18 day of February, 2014 A.D. U• C COMMONWEALTH OF PENNSYLVANIA NotariaHolly Lynn Warfel, Seo/ Notary Public hp,, D MY Com!m( nptres Dec. 12 2016 MEMBER, PENNS-hi/ANA At—Oct/MON 0" F ES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Midwest First Fin L P IV is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 19th day of November, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 771, at the suit of Midwest First Fin LP IV against Jill A & Christopher J Cowoski is duly recorded as Instrument Number 201409326. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this rat day of , A.D. (90AALe /2 Recorder of Deeds Reco Deeds, Cumberland County, Carlisle, PA My C mission Expires the First Monday of Jan. 2018