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Home My WebLink About13-1512 r r f 'J ,.._. Leon P. I- laller, Esquire Purcell, Krug & Haller -�� 1 719 North Front Street ( Harrisburg, PA 17102 �, 717.2 34.4178 EN" I'SYLw, mtg'(�,pkh.com MIDFIRS"i BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW 1). BRANT COPELAND ACTION OF MORTGAGE FORECLOSURE Defendant 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. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and tiling 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 TO FIND OUT WHERE YOU CAN GFT I F.(JA1, 111,1,P. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVIS0 IT I IAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDF,RSE CONTRA LAS QLIEJAS PF,RF,SENTADAS. ES \BSOLI I'AMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO PARA DF,FF,NDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA. FL PU'v'TO DI: VISTA DF USTED Y CUALQUIER OBJECCION CONTRA LAS QLIEJAS EN ESTA DEMANDA. RIX UFRDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PAR HCIPACION. FNTONCF,S, I,A COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE, 1 STED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION. ES POSSIBLE QUE USTED 1 PF,RDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. I,LFVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI \0 CONOCE A UN ABOGADO, LLAME AL " LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE �BOG ADOSi_ (2 238 -6300_ CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717 -249 -3166 OP ��Qi &k. �3� F-47 � MIDFIIZST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW I). BRANT COPELAND, ACTION OF MORTGAGE FORECLOSURE Defendant THE FOI:LOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor it' different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW D. BRANT COPF,LAND. ACTION OF MORTGAGE FORECLOSURE Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff is MIDFIRST BANK, a corporation, whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. The Defendant, D. BRANT COPELAND, is an adult individual whose last known address is 829 YVERDON DRIVE, CAMP HILL, PA 17011. On or about. November 30, 1998, the Defendant executed and delivered a Mortgage Note in the sum of' 5108.1 15.00 payable to FIRST UNITED MORTGAGE SERVICES, INC., which Note is attached hereto and marked Exhibit "A ". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, the Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and (_;ommon\N on December 3, 1998 in Mortgage Book 1502, Page 917 conveying to original 'Mortgagee the subject premises. The Mortgage was subsequently assigned to NATIONAL CITY MORTGAGE CO. and was recorded on December 3, 1998 in the aforesaid County in Book 596, Page Ol . The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTFIMS, INC. and was recorded in the aforesaid County on September 2, 2003 in Book 701, Page 847, On May 30, 2006, the Plaintiff and Mortgage Electronic Registration Systems, Inc. as Nominee for the Plaintiff and the Defendant executed a Mortgage Modification Agreement changing the amount of the Unpaid Principal Balance to $102,392.56, changing the monthly payment amount and changing the Maturity Date. The Mortgage Modification Agreement was recorded July 26, 2006 in Book 729, Page 412 On .July 7, 2009, the Plaintiff and Mortgage Electronic Registration Systems, Inc. as Nominee for the Plaintiff and the Defendant executed a Loan Modification Agreement changing the amount of the Unpaid Principal Balance to $100,731.06 and changing the monthly payment amount. The Loan Modification Agreement was recorded July 31, 2009 as Instrument Number 200926745. The Mortgage was subsequently assigned to MIDFIRST BANK and will be sent for recording. which Assignment is attached hereto and marked Exhibit "B ". The said Mortgage, Assignments, Mortgage Modification Agreement and Loan Modification Agreement are incorporated herein by reference. >. The land subject to the Mortgage is: 829 YVERDON DRIVE, CAMP HILL, PA 17011 and is more particularly described in Exhibit "C" attached hereto. 6. The Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on November 01. 2012 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $93,208.31 Interest at $16.60 per day $3,020.96 From 10/01 /2012 To 04/01/2013 ( based on contract rate of 6.5000 %) Accumulated Late Charges $936.83 Good through 03/12/2013 Escrow Deficit $1,270.41 Corporate Advance $422.29 Suspense Credit ($846.62) Attorney's Fee at 5% of Principal Balance _ $4,660.42 TOTAL $102,672.60 * *Together with interest at the per diem rate noted above after April 01, 2013 and other charges and costs to date of Sheriffs Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. S. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated December 11, 2012 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the December 1 1.2012 Act 6 Notice is attached hereto and marked Exhibit "D ". 9. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non - active military duty is attached as Exhibit "E ". WHEREFORE. Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.5000% ($16.60 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By. - PURCELL, KRUG & HALLER Leon P. Haller, Esquire I.D. # 15700 Jill M. Wineka I.D. 458802 Attorneys for Plaintiff 1719 N. Front Street Harrisburg, PA 17102 (717- 234 -4178) Multistate NOTE 74 41-583970-0 Case No. LOAN NO. 601591 NOVEMBER 30 1998 loatel 829 YVERDON DR CAMP HILL, PA 17011 (Property Address] 1. PARTIES 'Borrower' means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means FIRST UNITED MORTGAGE SERVICES, INC. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED EIGHT THOUSAND ONE HUNDRED FIFTEEN AND 00 /100 Dollars (U.S. $ 108 , 115. 0 0 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX AND ONE :HALF Percent ( 6.500 %) per year until, the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on JANUARY 1 ,1999 . Any principal and interest remaining on the first day of' DECEMBER 1 2028 , will be due on that date, which is called the 'Maturity Date." (B) Place Payment shall be made at 4931 CARLISLE PIKE, MECHANICSBURG, PA 17055 by notice to Borrower. or at such place as Lender may designate in writing (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 683.37 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. ]] [Check applicable box] FIGraduated Payment Allonge ❑Growing Equity Allonge ❑Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. MIA Multistate Fixed Rate Note - 10195 t P.O. I Or 2 �nitlN6: �` t,. BORROWER'S FAILURE TU 1'A 1' (A) Late Charge for Overdue S If Lendter has not received IWMI monthly payment required by the Secur as described in Paragraph "4(C) this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR percent { 4.000' 90} of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require (..ender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Leander at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this :Vote against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants co `ue this Note. Dl=t; 17 1998 � :5: PAY TO THE ORDER OF "` {seal) ` w bffiM BANK D. BRANT CO AND - Borrower NAZI CITY MO GE (O. (Seal) -9 -Borrower �� (Seal) EMIUO P OVAN! - Borrower ASSIGNMENT SPECIALIST PAY TO�THE ORDER OF NATIONAL CITY MORTGAGE CO. WITHOUT (Seal) > R'E S 0th DAY OF NOV EMBER ,1998 MORT' E CES, INC. s O PR E ST5 EN Prepared by and Return to: Kendra Cowley MidFirst Bank 2730 !North Portland Avenue Oklahoma City, OK 73107 Loan 1 4 , 50458299 MIN No. 100025400002863851 'VIERS Phone: (888) 679 -6377 ASSIGNMENT OF MORTGAGE FOR VALUE RECEIVED, Mortgage Electronic Registration Systems, Inc., its successors and assigns, 1901 E. Voorhees Street, Suite C, Danville, IL 61834, (hereinafter called the "Assignor "), does hereby grant, convey, assign, iransfe.r and set over to MidFirst Bank, A Federally Chartered Savings Association, 999 NW Grand Blvd., Suite 100 Oklahoma City, OK 73118, (hereinafter called the "Assignee "), its successors and assign's, all to the Assignor's rights, title and interest in and to: The Mortgage dated 11/30/1998, executed by D. Brant Copeland, to First United Mortgage Services, Inc., recorded on 12/03/1998, in Book 1502, Page 917, modified on 7/07/2009, recorded on 7/31/2009, as Instrument Number - 200926745, in the Office of the Recorder, Cumberland County, State of Pennsylvania, and covers the following real property and all improvements: Mortgage Amount: $108,115.00 Property Address: 829 Yverdon Dr, Camp Hill, PA 17011 Parcel Number: 47181302170 Legal Description: See Attached for Legal Description. , In Witness Whereof, the undersigned corporation has caused this instrument to be executed - day of March, 2013. ATTEST: Mortgage Electronic Registration Systems, Inc., its successors and assigns Daniel Weir Vice President fl ✓ i STATE OF OKLAHOMA COUNTY OF OKLAHOMA Oil this day of March, 2013, before me, a Notary Public, in and for said county, personally appeared Daniel Weir, to me personally known, who being by me duly sworn did say that he is the Vice President of Mortgage Electronic Registration Systems, Inc., its successors and assigns, and that the within instrument was signed on behalf of said corporation by authority of its Board of Directors, and that they acknowledged the execution of said instnment to be the voluntary act and deed of said corporation, executed for the uses and purposes set forth. In testi y whereof, I have hereunto set my hand and official seal this day of March, 2013. Carol L. Harber Notary Public 1 - - -- b � -T- - q��y L H�3 My Commission Expires: 03/11/2014 se (Votary p� a State ° ° of Oklahoma ; Commissiono # 9 0002089 IEx ire! 03191/14.; I do hereby certify that the address of the assignee is: - MidFirst Bank, 999 NW Grand Blvd., Suite 100 Oklahoma City, OK 73118 rc Kendra Cowley BEGINNING at a point on the easterly line of Yverdon Drive said point . being located two hundred fifty -five and eighty -four one hundredths (255.84) feet measured southwardly along said line from the southern, extremity of the curve having a radius of ten (10) feet connecting the easterly line of Yverdon Drive with the southerly line of Hillside Drivel thence north sixty -two (62) degrees fifty -three (531 minutes east along the southerly line of property now or late of John E. Matey and wife, one hundred forty (140) feet to a point; thence South twenty -seven (21) degrees seven (7) minutes east along the westerly line of Lot No. 20, Section B, Riverview and beyond seventy -seven (77) feet to a point; thence south sixty -two (62) degrees fifty -three (53) minutes west through a portion of Lot 22 in Section A, Riverview, said line being parallel with and eleven (!l.) feet distant souL•hwardly ; .from the southerly line of Lot No. 24, Section B, Riverview, one hundrec forty (1401 feet to a point on the easterly line of Yverdan drive; thence by the latter line north twenty -seven (27) degrees seven (7) minutes west seventy -seven (77) feet to the place of BEGINNING. BEING the southerly portion of Lot No. 24 on the Plan of Section B, Riverview, said Plan being recorded in Plan Book 10, Page 21, Cumberlani- County Records and the northerly eleven (11) feet of 'Lot 22 in Section A, Riverview, said Plan being recorded in Cumberland County Plan Book 10, Page 31. Tax Parcel No. 47-18-1302-170.. C_. NEENEZINE iD+i b)IC7tbIFlo1 Midland Mortgage A Division of Mid First Battle P.O. Box 268806 • Oklahoma City, OK 7.3126 Tel: 800.552.3000 * Fax: 405.767.5815 • MyMidlandMortgage . com 12!11/12 DO]I MD4411321 E2181 P I of 2 D BRANT COPELAND 829 YVERDON DR CAMP HILL PA 17011 1847 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO. 6 OF 1974 RE: 829 YVERDON DR CAMP HILL PA 17011 -1847 Loan Number 0050458299 Dear Mortgagor: The MORTGAGE held by MidFirst Bank (Lender), serviced by Midland Mortgage, on your property located at the address above IS IN SERIOUS DEFAULT because you have not made monthly payments totaling $6,048,92 for the months of 08/01/12 through 12/01/12. Late charges and other charges have also accrued to this date in the amount of $1,005.87. The total amount now required to cure the default (or in other words, to get caught up on your payments), as of the date of this letter, is $5,043.05. You may cure this default within THIRTY -FIVE (35) DAYS of the date of this letter, by paying to Midland Mortgage the above payment of $5,043.05, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made to Midland Mortgage at P.O Box 268888, Oklahoma City, OK 73126.8888, If you do not cure the default within THIRTY -FIVE (35) DAYS, the Lender intends to exercise Its right to accelerate the mortgage payments This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments, if full payment of the amount of default is not made within THIRTY -FIVE (35) DAYS, the Lender also intends to instruct its attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the Lender refers your case to Its attorneys, but you cure the default before before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe, which may also include reasonable costs. If you cure the default within the thirty -five day period you will not be required to pay attorney's fees The Lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 'if you have received a bankruptcy discharge of the debt secured by the Mortgage /Deed of Trust or you are currently in bankruptcy under the protection of the automatic stay, this letter is not an attempt to collect the debt, but any default will need to be cured to avoid foreclosure If your loan was in default at the time MldFirst Bank acquired the servicing of your loan and you have not filed bankruptcy or received a discharge of the debt secured by the Mortgage /Deed of Trust, we are required to advise you that this communication is from a debt collector, this is an attempt to collect a debt, and any Information obtained will be used for that purpose ! 0 u °<„axitxi of rx ux Midland Mortgage A Division of M&First Bank P.O. Box 268806 • Oklahoma Cite, OK 73126 Tel: 800.5.52 3000 • Fax: 40.5 767.S81-5 • MyMidlandMortga ;Ze.com If you have not cured the default within the thirty -five day period and foreclosure proceedings have begun, You still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus v, any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale, and by performinq any other requirements if any, under the mortgage it is estimated that ° ° xx the earliest date that such a Sheriff$ sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling Midland Mortgage at the following number: 1- 800 - 552 -3000 This payment must be made by cashier's check, certified check or money order and made payable to Midland Mortgage at the address stated above You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND ANY OTHER REQUIREMENTS UNDER THE MORTGAGE ARE: SATISFIED. CONTACT MIDLAND MORTGAGE TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST., YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year It is important that you call our office as soon as possible to discuss the options available to you. Our Loan Counselors may be reached toll -free at 1 -800 -552 -3000, Monday through Friday, 8:00 a.m. to 9:00 p.m. (Central Time). Sincerely, Delinquency Assistance Center Midland Mortgage, a Division of MidFirstBank Loan Number 0050458299 'If you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently in bankruptcy under the protection of the automatic stay, [his letter is not an attempt to collect the debt, but any default will need to be cured to avoid foreclosure if your loan was in default at the time MidFirsl Bank acquired the servicing of your loan and you have not fled bankruptcy or received a discharge of the debt secured by the MortgagelDeed of Trust, we are required to advise you that this communication is from a debt collector. this is an attempt to collect a debt. and any information obtained will be used for that purpose a 7 N v D =mz r' -i A O N o D z '-D f 4 N (31 ((A �0M r o z O � A Q J -D E100m.1O Rti m R—Ipl Raq -M,d d r m Code: 50458299 71791000164267869048 Electronic Return Receipt Requested D BRANT COPELAND 829 YVERDON DR CAMP HILL, PA 17011 -1847 Delinquency Assistance Center Midland Mortgage PO Box 266806 Oklahoma City, OK 73126 �, Department of Defense Manpower Data Center Results as of Fob - 252013 09;51;50 SCRA 2 3 - a . . Status Resort Pursuant to Servicemembers Civil Relief Act Last Name: COPELAND First Name: . D BRANT Middle Name: Active Duty Status As Of: Feb -25 -2013 On Active Duty On Aglva Duty Stalu s Data v � AcIlve Duly Start Data Active Duly End Date Status - Service Component No' NA This response reflects the Individuals' acllve duty status based an the Active Duty Status Data -Aloft AcWo Duty Wllhln 387 Days of Active Duty Status Date - - Active D S t a r t D ale - Aceva Duty End Data Status Sorvko Component - - - -- -- NA C" N A N o ' NA This response roaotis wh am the Individual loft active duty status vd 387 days procedinp the Active Duty Status Data - -•- - The Mombor or H is/Ho r Urrl Was Notfiod of a FutlAra Coll -Up to Activa Duly on Active Duly Status Data Order Notificatio S tan Dete Order N ot6eallon End Date r, - `:> Status S Component - NA NA. No :: NA This response reflects whether the Individual or Nsftr . urct he received early notrttation to report for active duly 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 hisfier unit receiving notification of future orders to report for Active Duty Mary M Snavely- Dixon. Director Department of Defense - Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington. VA 22350 i j COMPANY NAME: MIDFIRST BANK VERIFICATION T verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge and upon information and belief. T 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 By Title IN THE COURT OF COMMON PLEAS 01= MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) V5. D. BRANT COPELAND / c Defendant(s) Civil �- NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE: DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court - 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 the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectf u ' e 3/21/13 _ Date Leon P. Haller / Jill M. Wineka Attorney for Plaintiff Purcell, Krug and Haller 1719 North Front Street Harrisburg PA 17101 1 ID 1570a / 58802 IN THE COURT OF COMMON PLEAS OF MIDFIRST BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. D. BRANT COPELAND Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28 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. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMERIPRIMARY APPLICATION Borrower name (s): Property Address: _ City: State: Zip: is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: _ Borrower Occupied: Yes ❑ No ❑ Mailing Address (if different) _ City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? C O-BORRO WER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: _ # of people in household: How long? FINANCIAL INF ORMATIO N First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: _ Loan Number: Total Mortgage Payments Amount: $ Included Taxes and Insurance: _ Date of Last Payment: _ Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number 84 attorney: Asset Amount Owed: Value: Home: $ $ _ Other Real Estate: Retirement Funds: Investments: $ $ Checking: $ $ _ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: _ Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: _ Year: _ Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net _ 2• Monthly Gross Monthly Net _ 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. _ 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 Mortgage Food 2 Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: _ Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH ORIZATIO N I /We, authorize the above named to use /refer this information to my lender /servic:er for the sole purpose of evaluating my financial situation for possible mortgage optiions. [/we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;� , Sheriff �..; THEE PROTNG,. ( ,.',i k ��111"�0t�CUtfib�C[,} Jody S Smith " ? � � �(j: j Chief Deputy �w` Richard W Stewart CNt - ' 1 Y Solicitor Of FiCE OF TmE SRERIFF PENNSYLVANIA Midfirst Bank Case Number V& D. Brant Copeland (et al.) 2013-1512 SHERIFF'S RETURN OF SERVICE 03/26/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states this Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon defendant D. Brant Copeland is returned not served per request from attorney Haller. 03/26/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states this Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon defendant Tenant/Occupant is returned not served per request from attorney Haller. SHERIFF COST: $53.00 SO ANSWERS, March 26, 2013 RONIrY R ANDERSON, SHERIFF (c}CountySutte Sheriff,7e1eosoti inc, AFT -3 El 2: AND S Y LVA H!A Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller@pkh.com MIDFIRST BANK, • IN THE COURT OF COMMON PLEAS Plaintiff • CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW • vs. • No. 13-1512 Civil • D. BRANT COPELAND, • Defendant IN MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY: Please mark the above action settled and discontinued, without prejudice. PURCELL, KRUG & .• - R By Leon P.Haller ID #15700 Attorney for Plaintiff Date: March 27, 2013