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HomeMy WebLinkAbout13-1669 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE — ID #16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE — ID #17616 EDWARD D. CONWAY, ESQUIRE — ID #34687 MARGARET GAIRO, ESQUIRE — ID #34419 ANDREW L. MARKOWITZ, ESQUIRE — ID #28009 HEIDI R. SPIVAK, ESQUIRE — ID #74770 MARISA J. COHEN, ESQUIRE — ID #87830 KEVIN T. McQUAIL, ESQUIRE — ID #307169 CHRISTINE L. GRAHAM, ESQUIRE — ID #309480 BRIAN T. LaMANNA, ESQUIRE — ID #310321 JOSEPH F. RIGA, ESQUIRE — ID #57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 123 South Broad Street Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 " CO t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA —~ Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: l 3 � v Steve Calaman and Kathy Calaman Defendants. CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, National Association, by its attorneys, McCabe, Weisberg & Conway, P.C. and files this complaint in Mortgage Foreclosure as follows: 0'�xj 'b/ b3.7�� 062-PA-V3 I . The Plaintiff is Wells Fargo Bank, National Association, 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendants, Steve Calaman and Kathy Calaman, are individuals whose last known address is 1085 Grahams Woods Road, Newville, PA 17241, respectively. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A," attached hereto and made a part hereof. 4. On or about March 11, 2008, Steve Calaman and Kathy Calaman, made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $173,190.00 on the premises described in the legal description marked Exhibit "B," attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 200808125. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. 6. Steve Calaman and Kathy Calaman are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due June 1, 2011. 062 -PA -V3 8. As of 03/13/ 2013, the amount due and owing Plaintiff on the mortgage is as follows: Principal $ 177,517.49 Interest from 05/01/2011 to 03/13/2013 $ 14,493.73 Property Inspections $ 45.00 Escrow Advance $ 6,287.41 Suspense Balance $ (93.48) TOTAL $ 198,250.15 Plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiffs attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendants. 10. This action does not come under Act 91 of 1983 because the mortgage is F14A insured. 062 -PA -V3 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendants, but reserves its right to do so in a separate legal action if such right exists. If Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $198,250.15, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. McCabe, Weisberg & Conway, P.C. By: l/ C [ ] T NCE J. McCABE, ESQU [ ARC S. WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE [ ] MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE [ ] JOSEPH F. RIGA, ESQUIRE [ ] JOSEPH I. FOLEY, ESQUIRE Dated: , 2013 062-PA-V3 VERIFICATION Sonya Moore, hereby states that he /(gAs Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he /gis authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his er 'nformation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Sonya Moore Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 03/19/2013 086 -PA -V2 CALAMAN EXHIBIT "Alt (- �f► ►T NOTE PHA Case No. Multistate � MARCH 11, 2008 l Datel 1085 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241 lProperty Addressl 1. PARTIES "Borrower" means each person signing al the end of this Note, and the person's successors and assigns. "Lender" means WELLS FARGO BANK, N.A. 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 SEVENTY THREE THOUSAND ONE HUNDRED NINETY AND 00 /100 I Dollars (U. S. $ * * * * * * * ), 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 SIR percent( 6.000 %) 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 MAY 01 , 2008 . Any principal and interest remaining on the first day of APRIL 2038 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ * * ** * 1 , 038 . 36 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 Notc. [Check applicable box] 00raduated Payment Allonge ❑Growing Equity Allonge ❑Other [specify) 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Nate, 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. (� ® •1R (gaol) FJ1A Multistate Fixed Rate Note - 10/95 VMPMORTGAGE FORMS - (800)521.7281 j4r•1i Page 1 of 2 1"itials_ 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of 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 %) 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 Lender to give notice to other persons that amounts due haver .. 8. GIVING OF NOTICES '�.5� ,)llgtt.� ,..�, ;• 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 t, property address above or at a different address if w r... .... -..�• Borrower has given Lender a notice of Borrower's different address"IFIR Any notice that must be given to Lender under this Note will be given by first class mail to Lender 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 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 lakes 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 Note 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 contained this Note, (Seal) (Seal) •Borrower KATHY - Borrower (Seal) (Seal) - Borrower 6TEVE C - Borrower (Seal) (Seal) Borrower -Borrower (Seal) (Seal) - Borrower - Borrower �® •1 R (9 eo 1) Pape 2 or 2 WITHOUT RECOURSE PAY TO THE ORDER OF WEL.L* FARGO BANK, N.A. .Y..�- vun In mutes jOM J. MILLS, VICE PRESIDE ", EXHIBIT "B" ALL THAT CERTAIN lot or place of ground situate in Upper Frankford Township, Cumberland County, Commonwealth of Pennsylvania, more particularly described as follows: TRACT NO. 1: BEGINNING at a white oak; therwe by lands now or formerly of Tobias Dewalt, South twenty (20) and one -half (1/2) degrees East, fifty -two (52) perches to stores; thence South four (4) degreas West twenty (20) and one - fourth (1/4) perches to a gum; thence North eighty -two (82) degrees West, forty -four (44) perched to a post; thence North twenty -one (21) degrees East, sixty-seven (67) perches to a white oak, the place of BEGINNING. CONTAINING 10 acres and 40 perches, more or less and being bounded on the West by Tract No. 2 herein and by lands formerly of J.A. Crider, Raudabeugh, Carl's helm and other. TRACT NO. 2: BEGINNING at a railroad spike In the center of a mountain road at the comer of other lands retained by the Grantor herein; thence in the center of said mountain road, North twenty-six (26) degrees fifty -four (54) minutes East, one hundred fifty -two and twenty -five hundredths (152.25) feet to an Iron pin In the center of the aforesaid road; thence by said center, North fifty -five (55) degrees thirty -four (34) minutes East, two hundred fifty -eight and fifty -nine hundredths (258.59) feet to an Iron pin; thence akwq lands now or formerly of Gene Rk hcreek and Tract No. 1 herein, South eight (06) degrees fourteen (14) minutes West, five hundred seventy and thirty -eight hundredths (570.38) feet to an iron pin at stones; thence along other lands of the Grantor herein, North thirty -five (35) degrees twenty -two (22) minutes West, three hundred fifty -six and forty -five hundredths (356.45) feet to an Iron pin on the aforesaid mountain road, the piece of BEGINNING. ' BEING THE SAME PREMISES which David B. McConeghle and Katherine R. McConaghle, husband and wife, by deed dated December 4, 2008 and recorded December 14, 2006 in the Cumberland County, Pennsylvania Recorder of Deeds Office in Deed Book 277, Page 4996, granted and conveyed unto Steve Coleman and Kathy Calaman, husband and wife. (08.0015.PFD/ "015120) FORM I Wells Fargo Bank, N.A., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYA.ANI/�,`t vs. r") co Steve Calaman and Kathy Calaman Civil Defendants = C:3 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 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 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. Resitt 1: � �! 1,6 pectfully subm 7 ltz'� Date [Signature of Counsel for Plaintiff] Si " 70531 Page 1 FORM 2 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: 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 on household: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Yea': 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. 2. 3. 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 Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & 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: 2 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 deliquency? Yes ❑No❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): _ Contact: Phone: I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: I Proof of income f Past 2 bank statements f Proof of any expected income for the last 45 days f Copy of a current utility bill f Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNj r- =M -c -- Ronny R Anderson =r' Sheriff `" r Jody S Smith Chief Deputy - �` Richard W Stewart T Solicitor Wells Fargo Bank, N.A. Case Number vs. 2013-1669 Steve Calaman (et al.) SHERIFF'S RETURN OF SERVICE 04/02/2013 05:08 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Steve Calaman at 1085 Grahams Woods Road, Upper Frankford Township, Ne `Ile, PA 17241. A TSHALL, PUTY 04/02/2013 05:08 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Kathy Calaman at 1085 Grahams Woods Road, Upper Frankford Township, Newyj e, PA 17241. TSHALL, DEPUTY SHERIFF COST: $56.00 SO ANSWERS, April 03, 2013 RON R ANDERSON, SHERIFF Apr. 30. 2013 11 : 04AM CCBA No. 4510 P. 1/4 FORM 3 WELLS FARGO BANK, N.A. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2 Plaintiff(s) rn • 73 '3c3 m vs. �f I_t ."n1 c..J STEVE CALAMAN and -r �-r KATHY CALAMAN n ss I • Defendant(s) NO. 2013-1669 Civ 2 = ��-. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 12 - L619 , 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. APRIL 30, 2013 Marcus A. McKn' •- t, I Signature of Defend-n s Counse IA,'ointed Date Legal Representativ wAk 111 APRIL 30, 2013 Signature of Defendant Date APRIL 30, 2013 Ra thy Ca aman Signature of Defendant Date Apr, 30. 2013 11 : 04AM MA No. 4510 P. 2/4 FORM 4 WELLS FARGO BANK, N.A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. STEVE CALAMAN and KATHY CALAMAN Defendant(s) NO. 2013-1669 Civil CASE MANAGEMENT ORDER AND NOW,this AA_0(_ day of ,2013 ,the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has ' complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on �[I � OZ61-3 at M. in a"1404 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At leas} twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. 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 Ap r. 30. 2013 11 : 05AM CCBA No. 4510 P. 3/4 Court of the defendant/borrower's failure to serve the completed Form 2 with 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 fo'r not contesting the matter; offering the lender a deed in lieu of foreclosure; A r; 30. 2013 11 :05AM CCBA No. 4510 P. 4/4 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 A. ESS, P.J. J. Cl a � x caw �� WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-1669 CIVIL STEVE CALAMAN and KATHY CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE Present.at a conciliation conference held June 21, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Marcus McKnight, III, Esquire, attorney for the defendants. This is the first conference scheduled in this matter. Mr. McKnight has received the forms necessary for review of this matter by the bank. The completed forms will be submitted within two weeks. A continued conciliation conference is set by order of even date herewith. ORDER AND NOW, this Z/ ` day of June, 2013, continued conciliation conference in the above matter is set for Friday, August 23, 2013, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Kev' A. V. P. J. , Aathan Wolf, Esquire Y For the Plaintiff ...�� w ati c.. Aarcus McKnight, I1I, Esquire For the Defendants -< °-+t'� :rlm `� =cc.') WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-1669 CIVIL STEVE CALAMAN and KATHY CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held August 23, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Marcus McKnight, 111, Esquire, attorney for the defendants. A few documents remain to be submitted in this matter, primarily having to do with income verification. They will be forthcoming within fourteen days. A continued conciliation conference is set by order of even date herewith. ORDER AND NOW,this 'Z "7,' day of August, 2013, continued conciliation conference in the above matter is set for Thursday, October 24, 2013, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevin A ess, P. J. �-�"'Nathan Wolf, Esquire C-; C::�' For the Plaintiff Zo M C= ,,,- rcus McKnight, 111, Esquire =X 17� For the Defendants G"' :rlm :I>C= %A? WELLS FARGO BANK,N.A., • IN THE COURT OF COMMON PLEAS OF Plaintiff •• CUMBERLAND COUNTY, PENNSYLVANIA vs. ▪ CIVIL ACTION—LAW • NO. 13-1669 CIVIL STEVE CALAMAN and KATHY : CALAMAN, • Defendants IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held October 24, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Marcus McKnight, III, Esquire, attorney for the defendants. The final documents necessary for review of this matter are being submitted. It is hoped that the plaintiff will complete its review within sixty(60) days. A continued conciliation conference is set by order of even date herewith. ORDER AND NOW,this 2 `'f + day of October, 2013, continued conciliation conference in the above matter is set for Monday, December 16, 2013, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, z_V1 Kevin ; . ess, P. J. ‘than Wolf, Esquire For the Plaintiff Marcus McKnight, III, Esquire n For the Defendants ry •rlm CO I'fS << to a JTn�) WELLS FARGO BANK,N.A., • IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA • vs. • CIVIL ACTION—LAW • NO. 13-1669 CIVIL STEVE CALAMAN and KATHY : CALAMAN, Defendants • IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / 7' day of December, 2013, the conciliation conference set for December 16, 2013, is continued to Wednesday, January 15, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Kev'. A . Hess, P. J. Nathan Wolf, Esquire F r the Plaintiff Marcus McKnight, III, Esquire For the Defendants :rlm ,,- 11 J r�- . ,1 WELLS FARGO BANK,N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • vs. : CIVIL ACTION—LAW : NO. 13-1669 CIVIL STEVE CALAMAN and KATHY : CALAMAN, • Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / 9• day of December, 2013,the conciliation conference set for January 15, 2014, at 3:30 p.m. is rescheduled for January 15, 2015, at 4:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin 7. Hess, P. J. 1I<lathan Wolf, Esquire For the Plaintiff /Iarcus McKnight, III, Esquire For the Defendants • :rlm ' ' 7 ' 1 y c WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-1669 CIVIL STEVE CALAMAN and KATHY CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / G day of January, 2014, on agreement of the parties, the defendants are given twenty (20) within which to submit an updated loan modification packet. Continued conciliation conference is set for Friday, March 21, 2014, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, /a/ Kevi A. Hess, P. J. .//Nathan Wolf, Esquire For the Plaintiff ✓Marcus McKnight, III, Esquire For the Defendants Am .� �h �y , t .7 WELLS FARGO BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 13 -1669 CIVIL STEVE CALAMAN and KATHY : CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 f A day of March, 2014, on agreement of the parties, the conciliation conference set for March 21, 2014, is continued to Friday, May 23, 2014, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, 4 Kevin • Hess, P. J. Nathan Wolf, Esquire For the Plaintiff Marcus McKnight, III, Esquire For the Defendants :rim co i.es t Lt 3 a,0y WELLS FARGO BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 13-1669 CIVIL STEVE CALAMAN and KATHY : CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this - day of May, 2014, on agreement of the parties, the conciliation conference set for May 23, 2014, is continued to Friday, August 29, 2014, at 1:30 p.m. in Chambers of the undersigned. ✓ Nathan Wolf, Esquire For the Plaintiff 4/Marcus McKnight, III, Esquire For the Defendants :rlm e .es py 7 BY THE COURT, CD WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-1669 CIVIL STEVE CALAMAN and KATHY CALAMAN, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW,this Z9 day of August, 2014, on agreement of the parties, the conciliation conference set for August 29, 2014, is continued generally pending the receipt by the bank of executed permanent modification documents from the borrowers. BY THE COURT, Kevin Hess, P. J. Nathan Wolf, Esquire For the Plaintiff ✓Marcus McKnight, III, Esquire For the Defendants :rlm its.S /nt*� "'D —