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Home My WebLink About13-2238 Supreme. Court of Pemisylvauia. Coui Mo oiniiion Pleas :0 1t,l C0 el� Sheet [F,,Pothonorarr Use Oniv. Cum �, berlAi County c1 �.��' =� Do;At Na: ;r, The information collected on thi orm i used lel r r T fo this form s s so y fo court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. - - Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BRUCE C. DOUPE C IN INTEREST TO NATIONAL CITY REAL ESTATE SHANNON M. DOUPE T SERVICES LLC SUCCESSOR BY MERGER TO 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 r1 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 s ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: C ❑ Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute: Other T ❑ Other: i� Q MASS TORT ❑Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory B ❑Other ❑ Eminent Domain/Condemnation Arbitration ❑ 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.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 — BNV MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 1V"' V- KIVnd.AWGROUP.COM PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN THE COURT OF COMMON PLEAS IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO OF Cumberland COUNTY NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE VS. BRUCE C. DOUPE 1.5 SHANNON M. DOUPE MM ACTIONNMOK1 hAG1 Mortgagor(s) and Record Owner(s) �Cj,OS 960 Alexander Spring Road Carlisle, PA 17015 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 A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue rn - M - Carlisle, PA 17013 .� CD -: C n LEGAL SERVICES INC � Z :_ Z3 CD 8 Irvine Row �' . rrt --f cn Carlisle, PA 17013 x- 717- 243 -9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la 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 provisiones 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME CAM s W �✓ �� s POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD's website www.hud. ov 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://"7xN,%A,.phfa.org/consumers/homeowners/real.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: littp://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentionk..kmllawgroup com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 12050217C. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 2. The name(s) and address(es) of the Defendant(s) is /are BRUCE C. DOUPE, 960 Alexander Spring Road, Carlisle, PA 17015 and SHANNON M. DOUPE, 960 Alexander Spring Road, Carlisle, PA 17015, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On May 28, 2004 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE CO, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on June 14, 2004 as Book 1868 Page 2697. A Loan modification agreement dated May 24, 2004 and recorded June 14, 2004 on Book 1868, Page 2697. The Mortgage, Assignment(s) (if any) and Loan modifications 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 July 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 as of 03/29/2013: PrincipalBalance ............................... ............................... ....................$211,443.02 Interest from 06/01/2012 to 03/29/2013 at 4.0000 % .......... ......................$6,992.10 Per Diem interest rate at $23.17 LateCharges ........................................ ............................... ......................$1,275.93 Escrow........................................................................... ............................$1, 789.14 NSFCharges .......................................... ............................... .........................$30.00 Fees........................................................ ............................... .........................$96.00 InspectionCosts ...................................... ............................... ..........................$9.00 Appraisal....................................................................... ............................... $425.00 CorporateAdvances .............................. ............................... ........... ._.........$4,384.99 $226,445.18 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. 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 $226,445.18, together with interest at the rate of $23.17, 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, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: c. KML LAW GROUP .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 ew F. Gornall Pa. ID 92382 lyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I, Dona F. Penn , as a Authorized Signer , of PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, 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 falsification to authorities. Date: l�yJ PNC MORTGAGE, A DIVIS N OF PNC BANK, NATIONAL ASSOCIATION NAME: bhft F. Ponr*l&n TITLE: Authorized Si gner #120502FC - BRUCE C. DOUPE and SHANNON M. DOUPE 960 Alexander Spring Road Carlisle, PA 17015 Ey,hibit.X s t l PROPERTY DESCRiPTION i The land referred to in this Commitment is described as follows: t ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described in accordance with Subdivision Plan for Barton S. Carpenter prepared by Stephen G. Esher, Registered Surveyor, dated February 29, 1980, a copy of which is recorded in the hereinafter named Recorder's Office in Plan Book 37, Page 18 as follows: 3 BEGINNING at an iron pin in the original centerline of 33 feet wide Township Road T-467, known as Alexander Spring Road at the dividing line between the within described Lot No. 9 and Lot No. 1; thence from said iron pin at the Place of BEGINNING in said Township Road T-467 Eddie L. Hurley, North 21 degrees 54 minutes 30 seconds West a distance of 392.78 feet to an iron pin at the dividing line between the within described Lot No. 9 and Lot No. 9A; thence along the southern line of Lot Nos, 9 -A, 9 -B, and .9 -C North 65 degrees 28 minutes 50 seconds East, a distance of 1,128.78 feet to an iron pin at the southeastern comer of said Lot No. 9-C; thence along a portion of the western fine of Lot No. 8 -A, South 24 degrees 31 minutes 10 seconds l=ast, a distance of 237.60 feet to an iron pin at the dividing line between Lot Nos. 8 -A and 7; thence along the northern line of Lots 7, 6 and a portion of Lot No. 5, South 31 degrees 21 minutes 40 seconds West, a distance of 269.30 feet to an iron pin; thence still along a portion of the northern line of said Lot No. 5 and continuing along the nor ,hem line- of Lot Nos. 4, 3, 2 and 1, South 65 degrees 15 minutes West, a distance of 923.74 feet to an iron pin in the original centerline of 33 feet wide T -467, known as Alexander Spring Road, at the Place of BEGINNING. E.x.hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information (= )PNC Attention Collection Department MORTGAGE ( B6 - 11407 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 SHANNON ti DOUTE 960 ALEXANDER SPRING RD CARLISLE, PA 17013 Please find enclosed the ACT 91 NOTICE for Loan Number: 756 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. DR672 A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 800 -822 -5626 3232 Newmark Dr Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 2/12/201 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 yrou have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1 -800- 342 -2397 (Persons with impaired hearing can call (717) 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS 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. HOMEOWNER'S NAME(S): SHANNON M DOUPE BRUCE C DOUPE PROPERTY ADDRESS: 960 ALEXANDER SPRING RD CARLISLE, PA 17013 LOAN ACCT. NO.: =1756 ORIGINAL LENDER: NIA CURRENT LENDEWSERVICER: PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE A.ND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU CODZPLV 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, • IIF 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 TO 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 numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowners 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 fling 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 HEMAP 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 ". 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 MORTGAGE debt held by the above lender on your property located at: 960 ALEXANDER SPRING RD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: From 7/1/2012 through 12/1/2012 at $1,560.95 per month, From 1/1/2013 through 2/1/2013 at $1,584.77 per month Monthly Payments Accrued: $12,535.24 Late Charges Accrued: $1,149.15 Non - Sufficient Funds: $30.00 Fax Fees: $20.00 Property Inspections: $72.00 Speedpay Fees: $15.00 TOTAL AMOUNT PAST DUE: $13,821.39 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 $13,821.39, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P_�ments must be made either by cash, cashier's check, certified check or money order made payable and sent to PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 IF YOU DO NOT CURE THE DEFAULT —If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights 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 550.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgag e . Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - -It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 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: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 288 -3974 Contact Person: Collections Center E- 11'Iail Address: LossMitigation @pncmortgage.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 X may or _ may not (CHECK ONE) 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 DEPAULT 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY HEMAP Consumer Credit Counseling Agencies Cumberland County Advantage Credit Counseling PHFA Service/CCCS of Western PA 211 North Front Street 2000 Linglestown Road Harrisburg, PA 17110 Harrisburg, PA 17102 717- 780 -3940 800 - 342 -2397 888 -511 -2227 Community Action Commission of Advantage Credit Counseling Capital Region Service/CCCS of Western PA 1514 Derry Street 2000 Linglestown Road Harrisburg, PA 17104 Harrisburg, PA 17102 717- 232 -9757 888 -511 -2227 Housing Alliance of York/Y Housing Community Action Commission of Resources Capital Region 290 West Market Street 1514 Derry Street York, PA 17401 Harrisburg, PA 17104 717- 855 -2752 717- 232 -9757 Maranatha Housing Alliance of York/Y Housing 43 Philadelphia Avenue Resources Waynesboro, PA 17268 290 West Market Street 717- 762 -3285 York, PA 17401 717- 855 -2752 PA Interfaith Community Programs Inc Maranatha 40 E High Street 43 Philadelphia Avenue Gettysburg, PA 17325 Waynesboro, PA 17268 717- 334 -1518 717 -762 -3285 A PNC Attention: Collection Department MORTGAGE" (86-1- M07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 • - 7196 9008 '111 8685 2614 - -� BRUCE C DOlPE 960 ALEXANDER SPRING RD CARLISLE, PA 17013 Please find enclosed the ACT 91 NOTICE for Loan Number: 756 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. DR673 A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 80D- 822 -5626 3232 Newmark Dr Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 2/12/2013 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 Counseline 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 (717) 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 NOTIFICACION 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. HOMEOWNER'S NAME(S): SHANNON M DOUPE BRUCE C DOUPE PROPERTY ADDRESS: 960 ALEXANDER SPRING RD CARLISLE, PA 17013 LOAN ACCT. NO.: _1756 ORIGINAL LENDER: N/A CURRENT LENDER/SERVICER: PNC Mortgage 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 TO 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 numbers of designated consumer credit counseling agencies for the cou y in which the prMgy is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WIT]JIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. 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 MORTGAGE debt held by the above lender on your property located at: 960 ALEXANDER SPRING RD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: From 7/1/2012 through 12/1/2012 at $1,560.95 per month, From 1/112013 through 2/1/2013 at $1,584.77 per month Monthly Payments Accrued: $12,535.24 Late Charges Accrued: $1,149.15 Non - Sufficient Funds: $30.00 Fax Fees: $20.00 Property Inspections: $72.00 Speedpay Fees: $15.00 TOTAL AMOUNT PAST DUE: $13,821.39 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 $13,821.39, 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 PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 IF YOU DO NOT CURE THE DEFAULT - -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights 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 mortgag=ed 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 period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES —The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE --if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, You still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sal and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE —It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 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: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 288 -3974 Contact Person: Collections Center E -Mail Address: LossMitigation @pncmortgage.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 X may or _ may not (CHECK ONE) 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY F EMAP Consumer Credit Counseling Agencies Cumberland County Advantage Credit Counseling PHFA Service/CCCS of Western PA 211 North Front Street 2000 Linglestown Road Harrisburg, PA 17110 Harrisburg, PA 17102 717 -780 -3940 800- 342 -2397 888 -511 -2227 Community Action Commission of Advantage Credit Counseling Capital Region Service/CCCS of Western PA 1514 Derry Street 2000 Linglestown Road Harrisburg, PA 17104 Harrisburg, PA 17102 717- 232 -9757 888 -511 -2227 Housing Alliance of York/Y Housing Community Action Commission of Resources Capital Region 290 West Market Street 1514 Derry Street York, PA 17401 Harrisburg, PA 17104 717- 855 -2752 717- 232 -9757 Maranatha Housing Alliance of York/Y Housing 43 Philadelphia Avenue Resources Waynesboro, PA 17268 290 West Market Street 717- 762 -3285 York, PA 17401 717- 855 -2752 PA Interfaith Community Programs Inc Maranatha 40 E High Street 43 Philadelphia Avenue Gettysburg, PA 17325 Waynesboro, PA 17268 717- 334 -1518 717 -762 -3285 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE M SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY Case No. �? c�i� r) KNOWN AS NATIONAL CITY MORTGAGE CO Plaintiff < C) vs. BRUCE C. DOUPE SHANNON M. DOUPE Defendant(s) 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 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: (Sig tore of CoumX for Plaintiff) 4/19/2013 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 leader must consider your C ! rcumstances to determine possible options while working with your Please provide the following information to the best of your knowledge- CUST APPLICANT ,Borrower name(s): Property Address;. City: _ State: Zip: Is the property for sale? Yes EJ No Lj Listing date; _ _ _ - Price: $ Realtor Name: _ Realtor Phone: Borrower Occupied? Yes M 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: Zip: Phone Numbers: Home: Office: Cell: Other: Email; # ofpeople in household: How long? FINANCIAL IN�1;61ZXIATION First Mortgage Lender: Type of Loan; Loan Number: Tate You Closed Your Loan: Second Mortgage Lender: Type of Loan: -- -- -- Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance. Date of Last Payment: PrimaEy Reason _for Default: is the loan in Bankruptcy? Yes E] No n If yes, provide names, location of court, Case number & attorney: Assets Aniotutit (awed Value: Dome; S - -- — - -- - Other Rzal Estate: $ - $ Retirement Funds: $ Investments: $ Checking: $ Savings: $ $ Other: $ $ Automobile #l: Model: Year: Amount owed: Value: Automobile #2 : Model: "Fear: Amount owed: Value: Other transportation (automobiles, boats, matorcvciesj 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 E xgLr' s ess (Please only include expenses you are currently paying) ENPENSE AMOUNT EXPENSE A 40 NT Mo a - Food 2 M a e Utilities Car l'a ens Condo/Neigh. Fees Auto Insurance Med. not covered Auto fueJfre irs Other pro payment Install, Loan Payment Cable TV Child Su , t/Alim. Spending Money !Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? 'Y'es EJ No El If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Hor wieners 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? 'ices ❑ 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 (frame): Phone: Servicing Company (Name): Contact: Phone: IdWe, , authorize the above named to use /refer this :information to my lenderrlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. We 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:: Proof of income V Past 2 bank statements �Yg Proof of any expected income for the last 45 days V Copy of a current utility hill Y 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 RAnderson -v w 3C ' Sheriff ten rrl _40,ve couribtr4�y Jody S Smith ct?� c Chief Deputy Richard W Stewart c-s r; G Solicitor E,x. _ r ''Z C., c&� ) PNC Bank, National Association vs. Case Number Bruce D. Doupe, Jr. (et al.) 2013-2238 SHERIFF'S RETURN OF SERVICE 04/25/2013 04:06 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage oreclosure by "personally" handing a true copy to a person representing themselves t7te the 0 endant, to wit: Bruce D. Doupe, Jr. at 960 Alexander Spring Road, Dickinson Township, Carfsl-, •/17115. 444.44 SH WN HARRISON, DEPUTY 04/25/2013 04:06 PM- Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Bruce Doupe, Jr., husbany• if defendant, who accepted as"Adult Person in Charge"for Shannon M. Doupe at 960 Al- -flier p ng Road, Dickinson Township, Carlisle, PA 17015. bit S •WN H•'RISON, DEPUTY SHERIFF COST: $50.78 SO ANSWERS, April 29, 2013 RONNY R ANDERSON, SHERIFF ;r,urt iu-3hcHf osoP KML LAW GROUP, P.C. s Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL IN THE COURT OF COMMON PLEAS CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL OF CUMBERLAND COUNTY CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO No. 13-2238 Plaintiff vs. BRUCE C. DOUPE SHANNON M. DOUPE (Mortgagor(s) and Record owner(s)) am T 960 Alexander Spring Road Carlisle PA 17015 ^a :;u:`? CZ) i Defendant(s) �r-r 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: e-1; ✓— Michael McKeever Pa. ID 56129 Jay E.Kivitz Pa. ID 26769 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 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 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL IN THE COURT OF COMMON CITY REAL ESTATE SERVICES, LLC, PLEAS SUCCESSOR BY MERGER TO NATIONAL OF CUMBERLAND COUNTY CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CIVIL ACTION - LAW CO Plaintiff ACTION OF MORTGAGE Vs. FORECLOSURE BRUCE C. DOUPE No. 13-2238 SHANNON M. DOUPE (Mortgagor(s) and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE Angela M.S mith , 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 0 �� /✓ BRUCE C. DOUPE 960 Alexander Spring Road Carlisle, PA 17015 SHANNON M. DOUPE 960 Alexander Spring Road Carlisle, PA 17015 KML LAW GROUP,P.C. F/K/A GOLD ECK McCAFFER & McKEEVER By: Angela M.S mith , Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone)