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Home My WebLink About13-2067 Supreme Court of Pennsylvania Coin a`f 0 Pleas \ll i SI}eel For Prorlwi�ofart��se Onlr: Cumb a }t l e aaitd a'� Counh Dacx�t *ro: ✓.� S' ^� r_ r� �UU1 The information collected on this farm is used solelyfar court administration purposes, This form does not Su lement or re lace th e filing and service o leadin s or other papers as required bylaw or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin R Lead Plaintiff Name: Lead Defendant's Name: C M &T BANK AMY GRAYBILL T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Employment dispute: ❑ Statutory Appeal: Other E mass tort) Discrimination ❑ Slander/Libel Defamation ❑ Other ❑ Employment Dispute: Other T ❑ Other: I Q . MASS TORT 1:1 Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration $ ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 111/2011 KML LAW GROUP, P.C. FILED-OFFICE p SUITE 5 000 -BNY MELLON INDEPENDENCE CENTEROF Ti1E QTil � QNO TARY 701 MARKET STREET t! 11 PHILAI)ELPHIA,PA 19106 2013 APR 16 Pty I , 5 (866) 413 -2311 L , LA D CDUftfHE COURT OF COMMON PLEAS M &TBANK PENNS LVANIA 1 100 Wehrle Drive OF Cumberland COUNTY Williamsville, NY 14221 Plaintiff CIVIL ACTION - LAW vs. AMY GRAYBILL LOS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FOREC I EFO EC I ✓I' 335 West Perry Street CIVIL, ACTION: MOR E Enola, PA 17025 FftE DSM Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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 ➢as 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 corte 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 0� SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR /G � AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. "I � SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFREC.ER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/bomeowners/real.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.ori.4/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 ankmllaweroup 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 11971517C. Para infonnacion en espanol puede communicarse con Loretta at 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M &T BANK, 1100 Wehrle Drive, Williamsville, NY 14221. 2. The name(s) and address(es) of the Defendant(s) is /are AMY GRAYBILL, 335 West Perry Street, Enola, PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 30, 2004 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR M &T MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 05, 2004 as Book 1853 Page 1158. A loan modification agreement was recorded on December 9, 2011 as Instrument #201134320.The mortgage has been assigned to: M &T BANK by assignment of Mortgage recorded on January 28, 2011 as Instrument #201103430. 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 October 01, 2012 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: PrincipalBalance ................................ ............................... .....................$71,559.49 Interest from 09/01/2012 through 02/01/2013 at 5.3000 % . ......................$1,580.25 Per Diem interest rate at $10.39 LateCharges ......................................... ............................... .........................$54.45 Monthly late charge amount at $18.15 ProRata MIP/PMI ................................ ............................... ........................$115.66 PropertyInspections ............................... ............................... .........................$56.00 Reasonable Attorney's Fee .................. ............................... ............ ..........$1.650.00 $75,015.85 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an " 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 and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $75,01 5.85, together with interest at the rate of $10.39, 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 Sheriffs Sale of the Property. By: KML LAW 6ROUPIJFC. _Michael McKee er 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 L Goldman Pa. ID 205047 _Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 XSalvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I, Evelyn - Wilson as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. Date: �A _�_ \3 Eve lyn meson Banking Officer #119715FC - AMY GRAYBILL 335 West Perry Street Enola, PA 17025 Ex t Fii6it A ALL that certain piece or parcel or land situate in the Township of East Peunsboro, County of Cumberland and Commonwealth of Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point at the Northeast comer of Peary Street and Zion Street thence Eetwardly along the Northern side of Perry Street, Forty -Eight (48) feet, more or less, to a point opposite the center of a partition wall; thence Northwardly at right angles to Perry Street and through the center of the aforesaid partition wall and beyond One Hundred Twenty (120) feet to a point at line of Lot 9 on Plan No. 1 ofHoopy's Addition to Enola; thence Westwardly along the dividing line between Lots Nos. 8 and 9 on the aforesaid Plan Forty -Eight (48) feet, more or less, to a point on the Eastern side of Zion Street; thence Southwardly along the Eastern side of Zion Street One Hundred Twenty (120) feet to a point, the place of beginning. BEING the Western portions of Lots Nos. 6,7 and 8, Section A, Plan No. 1 of Hoopl's Addition to Each, recorded in Plan Book 1, page 7 Cumber County Record. BEING the same premises which William A. Higgins and Betty L. Higgins, his wife, granted and conveyed unto William A. Higgins, individually, by Deed dated 11/2611996 and recorded 12/6/1996 in the Recorder's Office of Cumberland County, Pennsylvania, in Deed Book 150 page 239. EXCEPTING thereout and thereftm. (if any) the premises as more fully described in the following deed: NONE END OP REPORT 12r30N3 ® 02:36 PM E.,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information REPRESENT I Jill H NT 7107 8381 6542 1718 1541 M &T Bank P.O. Box 619033 Dallas, TX 75261 -9033 9450 -02790 -0000052 -001 -01 -000 -009-000L00 AMY GRAYBILL 335 W PERRY ST ENOLA PA 17025 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 9- 7w427804000052n01 a2umn00a00 -000 APPENDIX A Date: December 5, 2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be 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 OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency, The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (7 780 -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. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 9a50- 627e0o000052u01o3a00 -000x00 -000 HOMEOWNER'S NAME(S): AMY GRAYBILL PROPERTY ADDRESS: 335 W PERRY STREET ENOLA PA 17025 LOAN ACCT. NO.: _5142 ORIGINAL LENDER: M &T Mortgage Corp CURRENT LENDERISERVICER: M &T Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT 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 (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP T O DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone n m r tL designated consumer credit counseling agencies or the county in which the pro is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (sec following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency YOU SHOULD FILE A BEMAP APPLICATION AS- SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT v- rsoanea OW052o 1�40"00aoa o00 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTAGAGE debt held by the above lender on your property located at: 335 W PERRY STREET ENOLA PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: October 1, 2012 through December 5, 2012 $1,874.37 Other charges (explain/itemize): $276.80 TOTAL AMOUNT PAST DUE: $2,151.17 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,151.17, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by-cash. cashier's check certified check or money order made payable and sent to M &T Bank P.O. Box 62182 Baltimore, MD 21264 -2182 Attn: Payment Processing IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends -tQ exercise Ai Lri h to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY you win 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. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 0- 750t278"00052o01 -05dN -0OG-0 OAN RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so ti�L paymg the total amoun then past due Plus any ate or other charges then due reasonable attorney's fees and costs_ connected with the foreclosure sale and any_other costs connected with the Sh eriff s Sale a s specified in writing 1?k tb�: en er and hy_ performing mother requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 10 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M &T Bank Address: P.O. Box 840 Buffalo, NY 14240 Phone Number: 1 -800- 724 -1633 Fax Number: 716 - 630 -4900 Contact Person: Evelyn Wilson E -Mail Address: ewilson@mtb-com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 9-7 0�2ES0a0000s2oorasn0040OA00 -000 i P Foreclosure Mitigation Counseling PENNSYLVANIA HOUSING F INANC E AGENCY- Initiative Agencies Agencias Participantes clue Aconsejan en Mitigaci6n contra la Ejecuci6n de una Hipoteca NOTICE: If you are a resident of Philadelphia, you must choose one of the Save Your Home Philly counseling agencies to be afforded the most punctual access to the Philadelphia Disposition process. Most of PHFA's Foreclosure Mitigation Counseling Initiative network agencies are also in the Save Your Home Philly network. To see a list: hft p:// www. phila.gov /OHCD /csigagencies.htm Cumberland County Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888 -511 -2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717 - 232 -9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York, PA 17401 717- 855 -2752 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717 - 762 -3285 - PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717- 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717- 780 -3940 800 - 342 -2397 NOTE: For more information, questions, or concerns regarding this list, contact PHFA at 1.800.822.1174. 'Other locations available to serve you; inquire with agency for more information. INTERNET REPRINT INS Prepated By and To: Referral neni L'iOLDBECIC MaGAFF CAFFERTY & McKEEVEEEVER Mellon Independence Center - Suite 5000 701 Market street mcliv Philadelphia, PA 19106 -1532 215- 825 -6344 0010145142 GMM File Number: 106464FC Parcel ID#: 09- 14-0832 -215 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR M &T MORTGAGE CORPORATION (Assignor), _ for and in consideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to M &T BANK M &T BANK (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed AMY GRAYBILL, Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR M &T MORTGAGE CORPORATION. Beating date of: January 30,2004; Amount Secured:-; Recorded on February 05, 2004; in Book 1853 Page 1158; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pentsylvamis ( "Mortgage') I'll t Sco. oo Property: 335 West perry Street, Enola, PA 17025 AS FURTHER DESCRIBED IN EXHIBIT "A ", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT_ Together with the note or obligation described in the Mortgage endorsed to the Assigne0.("Note ") and all moneys due and to become due on the Note and Mortgage, with interest Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigus forever. Assignor, by its appropriate c e officers, has executed and sealed with its corporate seal this Assignment of Mortgage on this day of , JCMUgnT, 2011. 0010/45142 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FORM &T MORTGAGE CORPORATION (Affix Corporate Seal) 2{.f. (SEAL) Name: Baurie Abramo Ttl Assistant Vice President 2 � (S Nam14 Emily W1tt Title: Banking Officer ss: STATEOF NEW YOR 1 COUNTYOOF ER k BE IT REMEMBERED, that on this�"�day of -rR7 (Car - 2011, before me, the subscriber, a Notary Public personally appeared fauna AVP Fmtly llll t �7 MORTGAGE ELECTRONIC REGISTRATION SYS znrr A- arna,nnraa r:no asst arrw :nr:c CORPORATION officers of Assignor, who lam satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue of a Resolution of its Board of Directors. J U4 ' otary Public My commission expires: 1 011 1 5 1 hereby certify the address of the Assignee is: J��M. C;terlx>«.rtlu 1100 Wehrle Drive, Williamsville, NY 14221 Jar Pa A& tack c Aft, rr - ,Mad o. Eris i85 Que r li6ad M Erie Cormty NI'�aadsarion Fruim50rlohpi31. 20 0010145142 Case tr: 106464FC COMOTMENT SCIMULE A (oonNoaal) A111hat cerminpixe or parcel or land situate in fire Township of East Peonsboro, County of Cr mbaland and Commonwealth of Pcnosylvema, bans more particalarty boundedaad de= as follows: BEGINNING at a point at the Northeast cam cr ofPecy Strad. and Zion Street tbeoce Eastwardly aloasthe Nw1bern side of Proxy Street, Forty�Eighit (48) feet, more or less, to a point opposite the cadet of &Partition WA% &MM NorrhWardly at dirt angles to Peat' Street and though the oft1W of the &fnressid partition wall and beyond One 1LmdmdTwwiy (120) fed to a point at rime of Lot 9 - on Plan No. I ofHoopl+s Addition to Eno* dwom WcatwwxUy along dm dividing linebetwem Lots Nos. 8 and 9 on &a afaawsaid Plan Forty -Eight (48) feet, more or less, to apoint on the Eastern aide ofZion Sheet; dmm Southwadly along the Eastern side of Zion Sheet One Hundred Twenty ( 120) Seat to apoint, the place ofbeginsiag. BEING the Weatem portions of Lots Nos. 6, 7 and % Sect A, Plan No. l ofHoopys Addition to Boole, recorded in Plan Book 1, pago 7 G'lnnber County Record. BEING the same prises which Wdkmn A HiMms and Betty L Wymm hiswifr, gantai and conveyed into Wi'Uism A- Higgim individually, byDood dated 11126 /1996 and ncorded 12'b/1996 in 9fe Reeordees Office of Cumberland County, Pennsylvania, in need Boot 150 page 239. OCC EPTM d=00rn and tbdnfrom (if any) the pranises as mare$dly desmdbcdin the follovibW dad: NONE END OF RSPOW iZ3Mkt ®8131 PD4 �anroregla te +��PW'maa✓lF- Lara° awargi m svrsprnrOrcracaiwadlp- nk.dtr� rer.+CaT.A orga�myrirr 1 Certify this to be recorded In CUn1ber1and County PA Recorder ofDeeds Fee ML HARII5-1Gn C N N rt o � IC"14 qp p r S1,ekcaseaao�ert4Farva 0� .7 fUi 1 Ir} aa&*vddAwdom aeacbed ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE - CARLISLE, PA 17013 = 717 - 240 -6370 Instrument Number - 201103430 Recorded On 1/282011 At 1125.25 AM • Total Pages - 4 * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number -31216 User lD -KW *Mortgagor - GRAYBML, AMY "Mortgagee - M &T BANK * Customer - GOLDBECK MCCAFFERTY & MCKEEVER * FEES STATE WRIT TAR $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 I Certify this to be recorded in Cumberland County PA o o v� i rsm • - Information denoted by an asterisk may change during the verification process and may not be reflected on this pages o"jv Il�lllli�l[�I�II� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c c _ - v 3 w Z M &TBANK rri- Plaintiff Zr VS. Case No. ) 9 -9b 7 _N> p� o vr*t ff' r -z -+o .<O 'b _-n AMY GRAYBILL = C:) o c Defendant(s) DZ _4 c NOTICE OF RESIDENTIAL MORTGAGE FORECLOSfYRL+ 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 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. Respectfully submitted: (Signature of Couns fr Plaintiff) 1 !3 Dat Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland Counly 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: Ct.)STONIER/PIMMARY APPLICANT 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 F No ❑ Mailing Address (if different): City: State:Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address; City: State: Phone Numbers: Home: Office: Cell: Other: Email; # ofpeople in household: How long? FINANCIAL EN�1 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 & 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 41: Model: Year: Amount owed: Value: Automobile tt2 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): I . 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 Mortgagr Food 2 Mortgage Utilities Car Pa ens Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop, payment Install. Loan Pa ment Cable TV Child Su rt/Alim. S ndin Mone Da /Child Carefruit. 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: 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? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: 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: We, authorize the above named to use /infer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. Ywe understand that Uwe am/are under no obligation 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: Y Proof of income V Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFF fC—L Jody S Smith Qkt�xt mitt 7�r rJF THE PROTHONOTAR Chief Deputy r 201`3 APR 29 PH I-. .c Richard W Stewart -A . Solicitor OFF;CCz OFTPE'v4,6PtF- CUMBULAND COUNTY PENNSYLVANIA M&T Bank vs. Case Number Amy Graybill 2013-2067 SHERIFF'S RETURN OF SERVICE 04/18/2013 07:48 PM- Deputy Jason Kinsler, 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:Amy Graybill at 335 West Perry Street, East Pennsboro, Enola, PA 17025. JKSON KINSLER, DEPUTY SHERIFF COST: $44.50 SO ANSWERS, April l N 22, 2013 61�- RON ' R ANDERSON, SHERIFF (C)CountySulto Sheriff,Tolaosoft.Inc. Wayne M.Pecht,Esquire PA ID 38904 .Pecht&Associates,PC 650 North Twelfth Street,Suite 100 Lemoyne,PA 17043 (717)691-6808 M & T BANK IN THE COURT OF COMMON PLEAS OF 1100 Wehrle Drive CUMBERLAND COUNTY PENNSYLVANIA Williamsville,NY 14221 Plaintiff V. NO. 2013-2067 CIVIL TERM Zy ---i [z7 - ? AMY GRAYBILL Mortgagor and Record Owner vii ry 335 West Perry Street Enola, PA 170025 ?,C -- "F-6 Defendant 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 false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Wayne M. P cht Date Attorney for Defendant Amy GrayW Date CERTIFICATE OF SERVICE I, Wayne M. Pecht, Esquire, the attorney for Defendant, hereby certify that I have served the foregoing document this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Alyk L. Oflazian, Esquire KML Law Group, P.C. BNY Mellon Independence Center Suite 5000 701 Market Street Philadelphia, PA 19106 June 26, 2013 Wayne M. kcht Wayne M. Pecht,Esquire PA ID 38904 Pecht&Associate,,, PC 650 North Twelfth Street, Suite 100 Lemoyne, PA 17043 (717)691-6808 M & T BANK IN THE COURT OF COMMON PLEAS OF 1100 Wehrle Drive CUMBERLAND COUNTY PENNSYLVANIA Williamsville,NY 14221 Plaintiff V. NO. 2013-2067 CIVIL TERM AMY GRAYBILL Mortgagor and Record Owner 335 West Perry Street -oz 4, Enola, PA 170025 �'' ' C-- - _x c r; a Defendant A� MIN `Yk CASE MANAGEMENT ORDER Q f AND NOW, this a7 4 day of , 2013, the Defendant in the above_ captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the Defendant 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 quAL� /G, '7-0 13 at o2. :,50 in &4.1A at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the Defendant must serve upon the Plaintiff 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. 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'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 and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the Plaintiff 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 who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the Plaintiff must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the Plaintiff 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 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 schedule Conciliation Conference. BY THE COURT, J. 1944-Y 4��S�i3 M& T, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-2067 CIVIL AMY GRAYBILL, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a mortgage conciliation conference held August 16, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff; Wayne M. Pecht, Esquire, attorney for the defendant; and the homeowner, Amy Graybill. We were advised that all necessary documents appear to have been provided to the bank so that they can complete their review of this matter for a loan modification. It appears, for the moment,that the bank is communicating directly with the homeowner. Should a different method of communication be required, counsel for the plaintiff will notify counsel for the defendant forthwith. A continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this !l.' day of August, 2013, continued conciliation conference is set for Thursday, September 26, 2013, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, 4L c s-:-, „ Kevin . Hess, P. J. r r t m :- r-x; Xi _.. Nathan Wolf, Esquire , ; For the Plaintiff c C-h .. ,/Wayne M. Pecht, Esquire �•For the Defendant - ; C", M&T, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION—LAW NO. 13-2067 CIVIL AMY GRAYBILL, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z I-` day of September, 2013, at the request of the parties,the conciliation conference set for September 26, 2013, is continued to Monday, December 16, 2013, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin A ess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff Wayne M. Pecht, Esquire For the Defendant :rlm c0 m w rn 4 M -G C-' �..9 co C-, c n =� M& T, • IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA • vs. • CIVIL ACTION—LAW • NO. 13-2067 CIVIL AMY GRAYBILL, • Defendant • MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this /?' day of December, 2013, at the request of the parties, the conciliation conference set for December 16, 2013, is continued to Friday, February 14, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevi . Hess, P. J. Nathan Wolf, Esquire Fo•the Plaintiff Wayne M. Pecht, Esquire For the Defendant :rlm LcL. r s /Z�I 3 - f..%� M & T, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-2067 CIVIL AMY GRAYBILL, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this z ^," day of January, 2014, at the request of the parties,the conciliation conference set for February 14, 2014, is continued to Friday, February 21, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, /v/ Kevin Hess, P. J. � Nathan Wolf, Esquire For the Plaintiff --- Wayne M. Pecht, Esquire For the Defendant :rlm i E.S 172a, •- vz C ,fr co KML LAW GROUP, P.C. i‘;4_E -t�� • _ Suite 5000—BNY Mellon Independence C teiH P10TH0,, �A}`,f 701 Market Street ZQt4 JAN -9 Philadelphia, PA 19106-1532 A f I; 1 2 215-627-1322 , PEN SYLVANJA T), • M&T BANK 1100 Wehrle Drive IN THE COURT OF COMMON PLEAS Williamsville,NY 14221 Plaintiff OF CUMBERLAND COUNTY vs. AMY GRAYBILL (Mortgagor(s) and Record owner(s)) No. 13-2067 335 West Perry Street Enola, PA 17025 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERTY& McKEEVER By: Michael McKeever P 56129 Jay E.Kivitz Pa. ID 6 69 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa. ID 312912 X Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff M&T BANK Plaintiff IN THE COURT OF COMMON vs. PLEAS OF CUMBERLAND COUNTY AMY GRAYBILL (Mortgagor(s) and Record Owner(s)) CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 13-2067 CERTIFICATE OF SERVICE Angela M. Smith, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on ) I—/ AMY GRAYBILL 335 West Perry Street Enola, PA 17025 KML LAW GROUP,P.C. F/K/A GOLD ECK McCAFFERTY& McKEEVER By: An:- a M. Smith, Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone) M & T, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION—LAW NO. 13-2067 CIVIL AMY GRAYBILL, Defendant : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 ? day of January, 2014, the conciliation conference set for February 21, 2014, is continued to Wednesday, February 26, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, _Agt Key' A. Hess, P. J. Nathan Wolf, Esquire For the Plaintiff Wane M. Pecht, Esquire � uire q For the Defendant :rlm ;r• Cet i eS I LccL `''ry z -cy r,; VelA//ef. N �y Wry �y