Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
13-2239
"Supreme Cou.0 -of Pennsylvania Caufk CaiiAolt fleas For Prothonotarr 13e Onh•_ ,C�ai�s fir, She ,et Ciurlmbe`riancl� }, s J_ 1 T FJ l' The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service o fpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: THE BANK OF NEW YORK MELLON F/K/A THE PAMELA I. KUHN C BANK OF NEW YORK AS SUCCESSOR TO JP MORGAN CHASE BANK N.A. AS TRUSTEE FOR THE I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑Yes No (Check one) X outside arbitration limits N — — Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO 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'ofthe ONE case category =that most accurately describes your PRIMARY CASK. 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 o S ❑ Premises Liability ❑Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute: Other T ❑ Other: 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration Ei ❑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.RC.P. 205.5 Updated 1/1/2011 a D KML LA:W GROUP, P.C. SUITE 5000 -BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 1VWw.KM1.I AWGROUE CORD THE BANK OF NEW YORK MELLON F/K /A THE IN THE COURT OF COMMON PLEAS BANK OF NEW YORK AS SUCCESSOR TO JP MORGAN CHASE BANK, N.A. AS TRUSTEE, FOR THE OF Cumberland COUNTY ABFS MORTGAGE LOAN TRUST 2003 -2 MORTGAGE PASS- THROUGH CERTIFCATE, SERIES 2003 -2 CIVIL ACTION - LAW c/o 3415 Vision Drive Columbus, OH 43219 ACTION OF MORTGAGE FORECLOSURE Plaintiff �3 - �a39 �vil PAMELA I. KUHN vs. CIVIL ACT'I4�ib.MORTGA�Ir Mortgagor(s) and Record Owner(s) F���L�S�� 632 North West Street Carlisle, PA 17013 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 c2 �, 2 Liberty Avenue Carlisle, PA 17013s'� fin n r - r'a LEGAL SERVICES INC C:) �-n 8 Irvine Row p C-) = -� C) — ' C:) C Carlisle, PA 17013 D ' 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 ]a 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 ]as 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME aP4 ' 111 X75 (x�l 73Y94v� V 14 _r) S) a <'2/ 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 1 717- 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.ora /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: http://www.Dhiladelphiafed.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 home retentionna kmllawgroup com Call Seth at 215- 825 -6329 or fax 2.15- 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 113490FC. 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. I I Ii a y COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS SUCCESSOR TO JP MORGAN CHASE BANK, N.A. AS TRUSTEE, FOR THE ABFS MORTGAGE LOAN TRUST 2003 -2 MORTGAGE PASS - THROUGH CERTIFCATE, SERIES 2003 -2, c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and address(es) of the Defendant(s) is /are PAMELA I. KUHN, 632 North West Street, Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 27, 2003 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to AMERICAN BUSINESS CREDIT, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on April 01, 2003 as Book 1803, Page 2098. The mortgage has been assigned to: JPMORGAN CHASE BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2003, ABFS MORTGAGE LOAN TRUST 2003 -2 by assignment of Mortgage recorded on May 08, 2008 as Book 2008 Page 5102 . Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property ") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for January 05, 2008 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. S y 6. The following amounts are due to Plaintiff on the Mortgage as o f - �, 2013: Principal Balance .................. .... .....................$75,829.99 Interest from 04/18/2011 through 02/28/2013 ....................... .....................$38,320.56 E Accrued Late Charges ................................ ............................... ......................$2,407.24 scrow Advance ....................................... ............................... .....................$31,403.30 Property Inspections ......................... ................................... ............................... $454.25 Reasonable Attorney's Fee ................... ........................... ..................... $1,450.00 $149,865.34 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, 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. Y 8. 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. 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 $149,865.34, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW GROUP, C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 — Andrew F. Gomall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff 1 � , Pennsylvania Verification ` I hereby states that h sh is Vice President of JPMorg n Chase Bank, N.A. as Attorney -In -Fact for the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. A ent ate: Og �� JPMorgan Chase Bank, N.A. as Attorney -In -Fact for the Plaintiff Borrower: Pamela I. Kuhn Property Address: 632 N. W. Street, Carlisle, PA. 17013 County: Cumberland Last Four of Loan Number: 7515 Eyhibit.A a SAT A, ALL THAT CERTAIN TRACT OFLAND SnVATE IN THE FffgH W ARD OF THE BOROUGH OF CARLNLE, CUMBERLAND COUNTY, PENNSYLVAMA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH NOW OR FORMERLY ]BY THE FRIENDSHW FIRE CO,; ON THE LAST 1�Y NORTH WEST STREET ON THE SOUTH BY PROPERTY NOW OR FOR MERLY OF JOHN J" ENDERS AND WIFE; AND ON THE WEST BY PROPERTY NOW OR FORMERLY OF MRS. GEORGE WOODS= HAVING A FRONTAGE OF 25 FEET ON NORTH WEST STREET AND EXTENDING 139 FEET 4 INCHES IN DEPTH AND BEING A PROVED WITH A 2 ST BRICK STORE STRP. AND DWELLING HOUSE KNOWN AS NO. 632 NORTH WEST Ee �?T. Ey,hibit (B *Exhibit has been redacted to remove all personally identifiable information or non- ublic information E m ,age Corlsor( jjtaq EMC Mortgage Corporation 7104 5400 210 0 3198 8800 PO BOX 293150 Lewisville, TX 75029 -3150 07/28/2010 I IIIIII VIII VIII VIII IIII VIII VIIIVIIIVIIIVIII IIII IIII Pamela I Kuhn 632 N W St Carlisle, PA 17013 Acceleration Warning (Notice of Intent to Foreclose) Account: _7515 (the "Loan ") Property Addressl 632n W St Carlisle, PA 17013 (the 'Property") Dear Mortgagor(s): ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FOR_vCLOSU This is an official notice that the mort a e 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 HOMEOWNERS' 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 THIRTY -THREE 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 (800) 342-2397. (Persons with impaired hearing may call [7171780-1869.) 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. Page Two _515 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 A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Pamela I Kuhn PROPERTY ADDRESS: 632n W St Carlisle, PA 17013 LOAN ACCT. NO.: 0002927515 ORIGINAL LENDER: AMERICAN BUSINESS CREDIT INC CURRENT LENDER/SERVICER: EMC Mortgage Corporation HOMEOWNERS' 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 HOMEOWNERS' 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 Agencies 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. T he names addresses and telephone numbers of designated Consumer Credit Counselin g Agencies for the county in which the Pro erty 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 i mmediately 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). AA Page 'Three _515 You have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Program ( "HEMAP "). To do so, you must fill out, sign, and file a completed HEMAP 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 ( "PHFA "). To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to the 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 THIRTY -THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE ACTION 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 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 INFORMATIONAL 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: 632n W St, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS starting 10/05/2007 through 07/28/2010, and the following amounts are now past due. If you have any questions about the amounts below, please contact us as soon as possible at (800) 723 -3004. Total Monthly Payments Past Due: $46,555.78 Late Charge(s): $ NSF Fees: 1,566.44 Other Fees and Advances *: $60.00 Amount Held in Suspense: $5,651.58 TOTAL AMOUNT DUE TO CURE DEFAULT: $930.00 $52,903.80 *Other Fees and Advances include those amounts allowed by your Note and Security Instrument. If you need additional information regarding the fees, please contact us at the number provided below. 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 $52,903.80, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) -DAY PERIOD. Payments must be made in the form of cash cashier's check money order, or certified check and sent to: Page Four �15 Regular Mail: EMC Mortgage Corporation PO BOX 660753 Dallas, TX 75266 -0753 Overnight Mail: EMC Mortgage Corporation 1010 West Mockingbird Lane Suite 100 Dallas, TX 75247 -5126 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 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 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. you cure the default within the THIRTY (30) -DAY period, you will not be required to pay attorney 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, y 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 asspecified 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 five to six (5 -6) 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: EMC Mortgage Corporation Address: PO BOX 660753 Dallas, TX 75266 -0753 Toll Free: (800) 723 -3004 Fax Number: (877) 601 -2677 Contact Person: Patricia Oliver Email Address: Patricia.L.Oliver @jpmorgan.com Contact Person: Catherine Pacheco Email Address: Catherine.X.Pacheco @jpmorgan.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. Page Five 515 ASSUMPTION OF MORTGAGE -- You may be eligible to 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. To determine eligibility, you must contact our office to verify the assumability of your Property. 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. Sincerely, Collections Department EMC Mortgage Corporation (800) 723 -3004 (800) 735 -2989 TDD / Text Telephone Enclosures 1. Federal Trade Commission Pamphlet 2. HEMAP Consumer Credit Counseling Agencies CERTIFIED MAIL: Return Receipt Requested and First Class Mail An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." EMC Mortgage Corporation offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at (888) 609 -2379 to discuss your options. The longer you delay the fewer options you may have. EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. BE860 r HEMAP CONSUMER CREDIT COUNSELING AGENCIES -- PENNSYLVANIA AGENCIES PHONE ADDRESS CITY ZIP CODE CCCS of Western PA 888 - 511 -2227 524 Franklin Avenue Aliquippa 15001 9 Beaver 15009 Housing Opportunities of Beaver County 724- 728 -7511 320 College Avenue Unit 1 Housing Opportunities of Beaver County, Inc. 724 - 728 -7511 282 East End Avenue Beaver 15010 Mon Valley Initiative 412 -464 -4000 303 -305 E 8th Avenue Homestead 15120 CCCS of Western PA 888 - 511 -2227 2403 Sidney Street River Park Pittsburgh 15203 Commons Action - Housing Inc. 412- 281 -2102 425 6th Avenue - Suite 950 Pittsburgh 15219 Neighborworks Western PA, formerly Neighborhood 412 - 281 -9773 710 5th Avenue - Suite 1000 Pittsburgh 15219 Housing Services Inc. PA Housing Finance Agency 412 -429 -2842 2275 Swallow Hill Road Bldg 200 Pittsburgh 15220 Three Rivers Center for Independent Living 412 - 371 -7700 900 Rebecca Avenue Pittsburgh 15221 Fair Housing Partnership of Greater Pittsburgh, Inc. 412 - 391 -2535 2840 Liberty Avenue - Suite 205 Pittsburgh 15222 Urban League of Greater Pittsburgh 412 - 227 -4163 610 Wood Street Pittsburgh 15222 Garfield Jubilee Associates 412 - 665 -5200 5138 Penn Avenue Pittsburgh 15224 Nazareth Housing Services 412 - 931 -6996 301 Bellevue Road Pittsburgh 15229 CCCS of Western PA 888 - 511 -2227 41 E Chestnut Street Washington 15301 Community Action Southwest 724-255 -9550 150 W Beau StreetSuite 304 Washington 15301 Southwestern PA Legal Services, Inc 800 - 846 -0871 10 W Cherry Avenue (Central Washington 15301 Office Southwestern PA Legal Services, Inc. 800 - 846 -0871 63 S Washington Street Waynesburg 15370 Fayette County Community Action Agency 724 -437 -6050 140 N Beeson Avenue Uniontown 15401 Southwestern PA Legal Services, Inc 800 - 846 -0871 132 E Catherine Street Somerset 15501 CCCS of Western PA 888- 511 -2227 1 Northgate Square Greensburg 15601 Westmoreland Community Action 724- 834 -1260 226 S Maple Avenue Greensburg 15601 Indiana County Community Action Program, Inc. 724 -465 -2657 827 Water Street P.O. Box 187 Indiana 15701 The NORCAM Group 814-948 -4446 4200 Crawford Avenue Suite 200 Northern 15714 Northern Tier Community ction Corporation Cambria ty P 814 486 -1161 135 W 4th Street Emporium 15834 CCCS of Western PA 888 - 511 -2227 112 Hollywood Drive -Suite 101 Butler 16001 Housing Authority of Butler County 724- 287 -6797 114 Woody Drive Butler 16001 Lawrence County Social Services, Inc. 724 -658 -7258 241 W Grant Street P.O. Box 189 New Castle 16103 Shenango Valley Urban League 724- 981 -5310 601 Indiana Avenue Farrell 16121 CCCS of the Midwest 800 - 355 -2227 734 Stambaugh Avenue Sharon 16146 Community Action Partnership of Mercer County 724 - 342 -6222 75 S Dock Street Sharon 16146 Armstrong County Community Action Agency 724- 548 -3405 124 Armsdale Road - Suite 211 Kittanning 16201 CCCS of Western PA 888 - 511 -2227 312 Chestnut Street - Suite 227 Meadville 16335 Center for Family Services, Inc. 814 - 337 -8450 213 W Center Street Meadville 16335 Warren Forest Counties EOC 814 - 726 -2400 1209 Pennsylvania Avenue W Warren 16365 P.O. Box 547 Greater Erie Community Action Agency 814- 459 -4581 18 W 9th Street Erie 16501 Booker T. Washington 814 453 -5744 1720 Holland Street Erie 16503 Saint Martin Center, Inc. 814- 452 -6113 1701 Parade Street Erie 16503 Voices for independence 814 - 874 -0064 1107 Payne Avenue Erie 16503 Bayfront Nato, Inc. 814 -459 -2761 312 Chestnut Street Erie 16507 CCCS of Western PA 888- 511 -2227 4402 Peach Street Erie 16509 Blair County Community Action Agency 814- 946 -3651 2100 6th Avenue - Suite 102 P.O. Altoona 16602 Box 1833 CCCS of Western PA 888- 511 -2227 917 A Logan Boulevard Altoona 16602 CCCS of Northeastern PA Ro al /Remax Plaza 814 - 238 -3668 202 W Hamilton Avenue State College 16801 The Trehab Center of Northeastern PA 570 - 724 -5252 144 E East Avenue Wellsboro 16901 Pennsylvania Housing Finance Agency 717 - 780 -3907 211 N Front Street Harrisburg 17101 CCCS of Western PA 888 - 511 -2227 2000 Lin lestown Road g Harrisburg 17110 Fair Housing Council of the Capital Region, Inc. 717 - 238 -9540 2100 N 6th Street Harrisburg 17110 Loveship, Inc. 717 - 232 -2207 2320 N 5th Street Harrisburg 17110 PHFA 717- 780 -3940 211 N Front Street Harrisburg 17110 Maranatha 717 - 762 -3285 43 Philadelphia Avenue Waynesboro 17268 CCCS of Western PA 888 - 511 -2227 55 Clover Hill Road Dallastown 17313 Adams County Interfaith Housing Authority 717 - 334 -1518 40 E High Street Gettysburg 17325 American Red Cross - Hanover Chapter 717 - 637 -3768 529 Carlisle Street Hanover 17331 Housing Alliance of York 717 - 854 -1541 35 S Duke Street York 17401 Opportunity, Inc. 717 -424 -3645 301 E Market Street York 17403 SACA Development Corp. 717- 399 -4292 453 S Lime Street Suite B Lancaster 17602 Base, Inc. 717 - 392 -5467 447 S Prince Street Lancaster 17603 Tabor Community Services, Inc. 717 - 397 -5182 308 E King Street Lancaster 17608 CCCS of Northeastern PA 570- 323 -6627 201 Basin StreeF Suite 600 Williamsport 17701 Lycoming - Clinton Counties Commission for Community 570 - 326 -0587 2138 Lincoln Street P.O. Box Williamsport 17703 Action 3568 CCCS of Northeastern PA 800 - 922 -9537 217 S Center Street Sunbury 17801 CCCS of Northeastern PA 800 - 922 -9537 702 Sawmill Road Bloomsburg 17815 Schuylkill Community Action 570 - 622 -1995 225 N Centre Street Pottsville 17901 Community Action Committee of Lehigh Valley, Inc. 610 -691 -5620 1337 E 5th Street Bethlehem 18015 El Shaddai Bethlehem Ministries 610- 625 -3500 529 E Broad Street Bethlehem 18018 CCCS of Lehigh Valley, A Division of MMI 800- 220 -2733 306 Spring Garden Street Easton 18042 CCCS of Lehigh Valley, A Division of MMI 800 - 220 -2733 3671 Crescent Court E Whitehall 18052 Alliance for Building Communities 610 -439 -7007 830 Hamilton Mall Allentown 18101 Neighborhood Housing Services of the Lehigh Valley 610 - 437 -4571 239 N 10th Street Allentown 18102 Catholic Charities Diocese of Allentown 610 -435 -1541 530 Union Boulevard Allentown 18109 CCCS of Northeastern PA 800-922 -9537 81 S Church Street Hazleton 18201 Opportunity, Inc. 570 - 236 -7642 West End Plaza Unit No. 10 Brodheadsville 18322 CCCS of Northeastern PA 570 -420 -8980 411 Main Street -Suite 102 Stroudsburg 18360 CCCS of Northeastern PA 800 - 922 -9537 232 Sunrise Avenue Route 191 Honesdale 18431 The Trehab Center of Northeastern PA 570 - 253 -8941 1225 Main Street Honesdale 18431 Catholic Social Services 570- 558 -3019 Saint Catherine Manor 5 Knox Scranton 18505 Road Catholic Social Services, Diocese of Scranton 570 - 207 -2283 516 Fig Street Scranton 18505 United Neighborhood Centers of Northeastern PA 570 - 346 -0759 425 Alder Street Scranton 18505 Neighborhood Housing Services of Lackawanna County 570- 558 -2490 709 E Market Street Scranton 18509 Opportunity, Inc. 570 - 236 -7642 Aharts Plaza /Key Real Estate Blakeslee 18610 Route 115 and 940 The Trehab Center of Northeastern PA 570- 928 -9667 German Street P.O. Box 389 Dushore 18614 American Credit Counseling Institute 888 468 -8847 212 Berwick- Hazelton Highway Nescopeck 18635 f CCCS of Northeastern PA 570 - 602 -2227 401 Laurel Street The Trehab Center of Northeastern PA Pittston 18640 570 - 836 -6840 115 SR 92S Tunkhannock 18657 CCCS of Northeastern PA 570- 821 -0837 77 E Market Street, 7th Floor Wilkes Barre 18701 Commission on Economic Opportunity of Luzerne County 570 - 826 -0510 165 Amber Lane P.O. Box 1127 Wilkes Barre 18703 The Trehab Center of Northeastern PA 570 - 278 -5227 10 Public Avenue Montrose 18801 The Trehab Center of Northeastern PA 570 - 888 -0412 703 S Elmer Avenue Suite M.6 Sayre 18840 Bucks County Housing Group 215 - 598 -3566 2324 2nd Street Pike - Suite 17 Wrightstown 18940 CCCS of Lehigh Valley, A Division of MMI 800 - 220 -2733 127 S 5th Street Quakertown 18951 Credit Counseling Center 215 - 396 -1880 832 2nd Street Pike 18954 American Credit Counseling Institute 215 -444 -9429 530 W Street Road - Suite 201 Warminster 18974 Opportunity, Inc. 610 -660 -6687 Two Bala Plaza Suite 300 Philadelphia 19004 CCCS of the Delaware Valley 215 - 563 -5665 1230 New Rogers Road - Suite F1 Bristol 19007 American Red Cross of Chester 610 - 874 -1484 1729 Edgemont Avenue Chester 19013 CCCS of the Delaware Valley 215 - 566 -5335 130 E 7th Street Chester 19013 American Financial Counseling Services 267 - 228 -7903 871 N Easton Road Glenside 19038 CCCS of the Delaware Valley 800 - 989 -2227 261 Old York Road Pavilion Suite Jenkintown 19046 CCCS of the Delaware Valle 401 y 215 - 563 -5665 280 N Providence Road Media 19063 Media Fellowship House 610- 565 -0434 302 S Jackson Media 19063 CCCS of the Delaware Valley 215- 566 -5335 240 N Bishop treet P Springfield 19064 American Credit Alliance 215 - 295 -7195 2 S Delmorr Avenue Morrisville 19067 Advocates for Financial Independence 215 - 389 -2810 202 E Hinkley Avenue Ridley Park 19078 American Credit Counseling Institute 610 - 971 -2210 175 Strafford Avenue - Suite 1 Wayne 19087 Housing Association of Delaware Valley 215- 545 -6010 1500 Walnut Street Suite 601 Philadelphia 19102 Unemployment Information Center 215 - 557 -0822 112 N Broad Street 11th Floor Philadelphia 19102 CCCS of the Delaware Valley 215 - 563 -5665 1608 Walnut Street 10th Floor Philadelphia 19103 PA Council For Community Advancement 215 - 567 -7803 100 N 17th Street Suite 600 Philadelphia 19103 Philadelphia Council for Community Advancement 215 - 567 -7803 1617 JFK Boulevard - Suite 1550 Philadelphia 19103 Urban League of PA 215 - 985 -3220 1818 Market Street 20th Floor Philadelphia 19103 Intercultural Family Services, Inc. 215- 386 -1298 4225 Chestnut Street Philadelphia 19104 The Partnership CDC 215 -662 -1612 4027 Market Street Philadelphia 19104 Liberty Resources 215 634 -2000 714 Market Street Suite 100 Philadelphia 19106 CCCS of the Delaware Valley 215 - 563 -5665 901 A Wood Street Philadelphia 19107 [American hiladelphia NHS 215- 988 -9879 121 N Broad Street #502 Philadelphia 19107 rban League of PA 215 - 985 -3220 121 S Broad Street 9th Floor Philadelphia 19107 Financial Counseling Services 267 - 228 -7903 1917 Welsh Road Philadelphia 19115 T. Airy, USA 215- 844 -6021 6703 Germantown Avenue - Suite Philadelphia 19119 200 Korean Community Development Services Center 215 - 276 -8830 6053 -55 N 5th Street Philadelphia 19120 APM 215- 235 -6788 2147 N 6th Street Philadelphia 19122 Association De Puertorriquenos En Marcha 215- 235 -6070 600 W Diamond Street Philadelphia 19122 Housing Association of Delaware Valley 215 - 978 -0224 1528 Walnut Street Philadelphia 19123 NACA Philadelphia, PA 215 - 531 -5221 1341 N Delaware Avenue - Suite Philadelphia 19125 New Kensington Community Development Cor 312 P 215427 -0350 2515 Frankford Avenue Philadelphia 19125 Carroll Park Community Council, Inc. 215- 877 -1157 5218 Master Street Philadelphia 19131 Hispanic Alliance for Community Advancement 215- 667 -8932 2740 N Front Street Philadelphia 19133 CCCS of the Delaware Valley 800 - 989 -2227 7340 Jackson Street Philadelphia 19136 West Oak Lane Community Development 215 - 224 -0880 7300 -02 Ogontz Avenue Philadelphia 19138 CCCS of the Delaware Valley 215 - 566 -5335 4400 N Reese Street Philadelphia 19140 Hispanic Association of Contractors and Enterprises 215 -426 -8025 167 W Allegheny Avenue, Suite Philadelphia 19140 Nueva Esperanza 200 215 - 324 -0746 4261 N 5th Street Philadelphia 19140 FOB CDC 215 - 549 -8755 1201 W Olney venue Y Philadelphia 19141 Northwest Counseling Service 215- 324 -7500 5001 N Broad Street Philadelphia 19141 West Oak Lane 215 - 224 -0880 6259 Limekiln Pike Philadelphia 19141 Southwest Community Development Corp. 215 - 729 -0800 6328 Paschall Avenue Philadelphia 19142 Germantown Settlement 215- 849 -3104 5538 Wayne Avenue Building C Philadelphia 19144 Advocates for Financial Independence 215 - 389 -2810 1806 S Broad Street - Suite 1B Philadelphia 19145 Esperanza 215 - 336 -3511 1920 S 20th Street Philadelphia 19145 South PA H.O.M.E.S. 215- 334 -4430 1444 Point Breeze Avenue Philadelphia 19146 Universal Companies 215 - 732 -6518 800 S 15th Street Philadelphia 19146 Philadelphia Senior Center 215 -546 -5879 509 S Broad Street Philadelphia 19147 United Communities Southeast PA 215 -467 -8700 2029 S 8th Street Philadelphia 19148 American Credit Counseling Institute 888 - 212 -6741 229 E Chestnut Street 1st Floor Coatesville 19320 CCCS of the Delaware Valley 215 - 563 -5665 1001 E Lincoln Highway Suite 102 Coatesville 19320 Housing Partnership of Chester County 610- 518 -1522 41 W Lancaster Ayenue Downingtown 19335 Alliance for Better Housing, Inc. 610 - 925 -1880 648 Buena Vista Drive Kennett 19348 American Credit Counseling Institute S uare 888- 212 -6741 21 S Church Street West Chester 19380 CCCS of the Delaware Valley 800 - 989 -2227 790 E Market Street - Suite 170 West Chester 19382 American Credit Counseling Institute 601 - 971 -2210 526 -528 Dekalb Street Norristown 19401 CCCS of the Delaware Valley 215 - 563 -5665 113 E Main Street - 2nd Floor Norristown 19401 Consumer Credit Counseling Service of Delaware 610- 272 -0578 190 Germantown Pike, Suite 140 Norristown 19401 Genesis Housing Corp. 610- 275 -4357 208 DeKalb Street P.O. Box 1170 Norristown 19401 American Financial Counseling Services 267 - 228 -7903 405 W Germantown Pike Norristown 19403 CCCS of the Delaware Valley 800- 989 -2227 1777 Sent Parkway West �Y Y Blue Bell 19422 American Financial Counseling Services 267- 228 -7903 2880 Bergey Road - Suite 4 Hatfield 19440 American Credit Counseling Institute 888 - 212 -6741 937 N Hanover Street Pottstown 19460 CCCS of Lehigh Valley, A Division of MMI 800- 220 -2733 1954 E High Street Pottstown 19464 PA Interfaith Community Programs, Inc. 610- 562 -2288 22 Willow Road Hamburg 19526 Budget Counseling Center 610- 375 -7866 247 N 5th Street Reading 19601 Neighborhood Housing Services of Reading, Inc. 610- 372 -8433 213 N 5th Street - Suite 1030 Reading 19601 American Rev. 10/09 Financial Counseling Services 267- 228 -7903 906 Penn Avenue Wyomissing 19610 BE860 An important message from the Federal Trade Commission A note to H omeowntNz., Facing foreclosure? Scammers are targeting Some claim to be able to "rescue" hoeowe s e from forec osures e others prmisealoan modifications — for a fee. The Federal Trade Commission , worse. the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to Don't Get Hit by a Pitch. Imitations = Frustrations. "We can stop your foreclosure!" Some con artists use names, "97% success rate!" S phone numbers, "Guaranteed to save your home!" and websites to make it look like they're part These kinds of claims are the tell -tale signs of of the government. If you want to contact a a foreclosure rip -off. Steer clear of anyone g g Y, type the web address who offers an easy out. Y directly into your browser and look up any address you aren't sure about. Use phone Don't Pay for a Promise. numbers listed on agency websites or in other Don't pay any business, organization or reliable sources, like the Blue Pages in your person who promises to prevent foreclosure or any attachm nets n unexpected emails. or open get you a new mortgage. These so- called "foreclosure rescue companies" claim they Talk to a HUD - Certified Counseling can help save your home, but they're out to 9 make a quick buck. Some may request heft Agency - For Free. fees in advance — and then stop returnin Y If You're having trouble paying your mort age g calls. Others may string you along before your or you've already gotten a delinquency notice, s if disclosing their charges. Cut off all dealin free help is a phone call away. Call 1-888 - someone insists h a fee. g 995 -HOPE for free personalized advice from housing counseling agencies certified by the Send Payments Directly. U.S. Department of Housing and Urban Some scammers offer to handle financial Development (HUD). This national hotline — arrangements for you, but then just pocket open 24/7 — is operated by the ' our Payment. Send our mortgage Payment a e Pa nonprofit member of the HOPE NOW ion, a Y pY Y gg PY ONLY to your mortgage servicer. Alliance of mortgage industry members and Don't Pay for a Second Opinion. g idaan e visit ling hopenow.comr. Have you applied for a loan modification and For free information on the President's plan to been turned down? Never pay for a "second help homeowners, visit opinion." www.maki ngbomeaffordable.gov. Federal Trade Commission #tc.gov /MoneyMatters Call 1-888- 995�HOPC for free personalized guidance from housing counseling agencies by the U.S. Department of Housing and Urban Development. certified Homeowner's HOPETM Hotline The e - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit m HOPE NOW Alliance of mortgage industr ember of the ry members and HUD - certified counseling agencies. Or visit www. ho e p now.corn For free information on the President's plan to help homeowners visit vww VV makin g ble. gov Support & Guidance For Monleowners sm MAKING HOME A.FFO�DABLE.c ©v E .,xhifiit * Exhibit has been redacted to remove all personally identifiable information or non-public p information 1 / PrePared $y and Return To: Bent Qradei GOLD13RCK McCAFFERTY & MCKEEVLP, L Mellon Independence Center - Suite 5000 701 Market Street Pbilad4hia, PA 19105 -1532 215 -6127 -1322 _ S1S GAM File NUmber: ERIC - 0715 Parcel 11D#: 06-20-1798-014 �rnuTGAiC;E MORTGAGE ELWIrRONIC REGISTRATtoN SySTEI�IS INC. {Ass,'g�z3 for and 'a eontideratiOn of the MIR Of Tva Dollars ($ I O.Obj and other food _ and valuable a sd'. d n rati ozx the reccapt of wblclt is acknowledged, does grant, bsrgain, sell, assign and transfer to JYMQIEZGAN , CRASE BANK, AS TRUSTEE UN])F'R. THE FOOLINGr AND SERVICING AGARLZIN I DAM AS 01F OCTOBER 1, 2003, ABP'S MORTGAGE LOAN DUST 2003 -2. SERVICING AGEF:IVJENT DATED AS F p �U$T�+� UIyAER THE YOOX 7lYGA-D �t.L'S7c 2003,2, OCTOBER 1, 2003, AEFS MORTGAGE LOAN (Assignee), all o£itS title and into, as holder of, in, and to the following described r»art a described and the indebtedness seeured by the mortgage: $ g n the roperrY Executed PAMELA 1.1CMN , Mortgag%(s); to AMERICAN BLTSMSS CREDIT ,iNC., H date of March 27, 2003; Atlaount Secured: $77,000.00; Recorded on April 01, 2003; in B"X 1S #3 P 2098; in the Recorder of Deeds Office of Cumberland Courtty, Comnwmvealth of perites lvaxia (' A�lortgage ") Propelly; 632 N. West Streat, Carnsle pA 17013 AS FUR NEP, DESCRIBED IN EX1llDIT "A ", ATTACHED AND b 1CORPORATF IN 7)D "I�IfB ASSIGNmE—NT. Together with the note or Obligation described in the Mortgage endorsed to the Assignee,( °Nob,-" and all ri�oneys due and to become due on the Note and Mortgage, with interest. Assignee its successors legal z?pzesental3vcs and assiims shall hold all rights under the Note and Mortgage forever, subject howcvcr, to the night acrd equity of redcruption, if any, of the make*) of the Mortgage, their heirs and assigns forever. Assigwr, by its appropriate Gorporate officers b e ce�ex ed aAd sealed with its Lozporata seat tM® Asd9tzmept of Mortgage on this day Of t t 200$_ a y a ,MORTGAGE BI, R XC REGXSTRATIO SYS MS INC'. (Affix Corporate Seal) Nxmc: Gn a i Otlr' �! — (SEAL) Title: Nom ins T l ®rsort Title, v &r: ff STAVE OF COUNTY OF�� BE IT REP EMBEM, that oar W.5 shay of --- � — 2008 Notary Public pemonally appeared > ire me, the suhscriber a _i uenda A#lotev :� �, rR to erso ofC rs of Assignor, Who Ism satisfied are i thu p sc s v who sign the withi p k 7 y `s $sox�Iedged that they sigtaad, sealed '4th '4th the II in smuzaent aqd th aforesaid' 80 d that the within instrument is the vq terry act and and of such same as such office" a Resoltt 0A of its Board of Uixeetors. r p rporatiom mach �y virtue Notary public My Commission expires I hereby certify the address of the Assignee is: / "9 Ridden Ridge D e, S 'te 200 J .A Ag,TX 75038 q t1F$O =515 Case M. EMC-4071 5 All that certain tract of land situate in the Fifth Ward of the Borough; of Carlisle, Cumberland Coup Pcrunsylvania, bounded mid described as follows- tY, On the North now or formerly by the Friendship Fire Co-; on the East by North West Street on the you' by PX'OPertY now or formerly of John J. Ender and wife; and on the west by ofltdrs +George Woods; having a frOatage of 25 feet on the inches an depth NOW west Streepand extcrndi o 139 feet 4 North W est Stre et. t. being linpzoved with A 2 Story brick store and dwelling house known as o. 632 Nort TAX PARCET -4 06-20 -179$ -014 BRING KNOWN AS — 632 N. Nest street, Carlisle, pA 17013 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY THOUSE SQUARE CARLISLE, PA 17013 7 17- 240 -6370 Instrument Number - 200875102 Recorded On 5/8/2008 At 10:43:13 AM * Instrument Tpe - ASSIGNMENT OF MORTGAGE Total Pages 4 Invoice Number - 20433 * Mort a or - User ID - RAK g g MORTGAGE Homage- - ELECTRONIC REGISTRATION SYSTEMS INC * JPMORGAN' C HASE' DANK N A FEES * Customer - GOLDBECK ET AL STATE WRIT TAX STATE JCS /ACCESS To $0.50 $10.00 Certification Page JUSTICE RECORDING FEES $11.50 DO NOT DETACH RECORDER OF DEEDS COUNTY ARCHIVES FEE $2 .00 ROD ARCHIVES FEE This page is now part TOTAL, PAID $ 7.00 $27.00 of this legal document. 1 Certify this to be recorded in Cumberland County PA o f cu, y8F9 . o � c RECORDER O D EDS »so "- Information denoted by an asterisk may change during the verification process and may not be reflected on this page. III�IIIIII 111111111111111111 KDWrd ` gc Kejraxr't' o: t;:��l� a g AC e P Ll:'t Macgn{, Mo rt CorDOrar r Midge Il P09 Hidden Ridge lY1 : ,• � . lr "62, T),. 75038 Attr, cariotn"t rasna g&uXrrt 2R�5 APR ti A 9`16 i['ranaUnloo Settleanont Santos$, tna 1174) Luccut Eb d S Fluor la"ietoxt, CO 80129 -2386 (3113) 978 -1139 Tracklts Nw 0t "2751_ 1 423GLU SSIGNME OF MORTGA,GIE 538 prgieO, A8FS 6RRENMONTI 'Assi P01( vA.CUE RF.(,'E�T), > �ersesp Hrtsiiueas Cwt ["C 'he uadcrs igned twtaec' O z (n) l�tr>pt srwrY whose address is 111 P12 In nt, assign, trans and cpavcY% "told Tcc BLS' SUITE 1 ?7, g h C� &sbc (lAetcin V STS,11�rC, -1, QUS®=s and aau ourae unto h�O)RTGAGA: ELEC W PA 19004 does hereb �1ErtN�Vn 2Z 182 without rccout� x e#acat3iioa or at a whose y� 95 $p IUNG H7U ROAD_ �rRA�TIO y ry that the abova adtlrfte or the p for all interest udder a cettalth 14orpse Gated ®3✓27 L1<I'rDut bUP1CAN W Whit h Mode rs td recwxd en s uattde and executed by 8 orrowars:.PAM>r� p ttne6a B- 0VVolatnc: ]863 KUMq lnsir.'Ref �° No.: 2098 8 +a1 Lenrkr: A 8 te: 4/12UO3 P(o No: 06-2(479"14 O ri8ina 11 -oan Ararat,(: 57?,OD9�t�� Cred;y.Tna In tho C.ommnnwr�t> ok P.Tt Property. Addtess: 632 tig" A won Crum a¢satibit;g land thaOn as (aElows BOrOvOr CARLISLE T Strum Cale, PA 170)3 MAL DESC•k.7rTION: NOT ou u11,'t�p wa rd: �Jfi C o=y; CUMg16D TOGETHER with th rW or bond 6ecuted thereby, t4c Me ttanskrred t08e4l- with A- '4Por's right, title d rth or p O td hndebtedm h„� d:js date said �V -nty, the pXopertY hct t described and the indebtedness il in a nd secured. gage. al l withmt re," tS w C -,a other exhsnng legal ox Equitable rigftts, interests a d h 4azatd proceeds tdkneof inclndjng, but ooh )itr»tcd to em d or it h retpccr to t)te Mo tngrtce policies, as we ll as ca cP sr s< axisting title ipsttrp a and/r�, (fie None ux of action and judg-cuts related ther<M, policies and TO NAVE AN TO HOID the same -to Asti¢ neeril assigns fore Ghat coaditioAS of, the above- a cubed Mortgage. , its successo a vex, subject ool %o the tarats 12 wa s v►�I1E1FF?OF, Asnf3nor Ices ceuyed ibis Assigotnent to be executed and. delirened, ef3f ct1 12lOE✓2003. ve Amer{eat, )3usinese Oti Ldit, Inc. maker Tlrrrlaiug fOB Penn Square ' Eaet,$th Floor Phitedelpp(a PA ]9167 _ NY; B_2� c �Pmxl)ENII STATE OF COLORADO) COUNTY OF UCUG1.AS) Oa ()3/1012W:5. More me, t1u Und" ;igaed No�.Pubtic in and for said Stte a, P��U Gtt hecto a VICE PR E the p ofAmerican Bugfge=s Credit, Ina, known to me or my satisfactory �''iddrxe) to be the y aDpearcd I1ECICY bcfshe is the au moo whose dame is subst:n to the i P `d to nee on the in sit of Building I DO VICE PRSSZDrkNT of Amcrjtcan 1) nsinesa ' Credit, 'rte„ and WbO acknowledged nowledged that iuc in hielborS gxwr Eesc8th Floor PhiladclpAWa PA (9107, and who m is Vlaatartmker behalf of which the h' riredwpecity and twat by his✓hor sllguattue on ; jnS lodged to t 6e ✓spe e ed, executed the 1 xeouhtd person acf naRtrment. � ant � patted, or rite etrfity M Witness MY Hand and 0fri.-iai Sea!_ [ ] LEKESHA .Na u "cUIc, L EKESHA ScA i Eg M Y c° tA 7 °'tgfoa Expired: I a'FartQQs b4I"1t l0002210opz9z75153 !leFERS my �Ortmdsef m &0" 111✓sivm YRU TELEPHONB # 1- 888 - 679-6377 �E '71f: i4L� Y BF;� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS SUCCESSOR TO JP MORGAN CHASE BANK, N.A. AS TRUSTEE, FOR THE ABFS MORTGAGE LOAN - 0 t s TRUST 2003 -2 MORTGAGE PASS - THROUGH Case No. ` �,� CERTIFCATE, SERIES 2003 -2 � 1 �_ r . Plaintiff CD r PAMELA 1. KUHN�'- -� 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. Respect By submitted. (Signature of Co nsel for Plaintif fl 4/18/2013 Date Cumberland Cotinty Residential Mortgage roreciosure Divers -on Prograin Date F inancial Worksheet Cumberland County Court of Common Pleas Docket # BORROWER REQC "FST FOR HARDSHlP ASSISTANGB TO complete•your request for hardship assistance, your lender must consider your circurnsta.nces to determine possible options while working with .your Please provide the following information to the best of your knowledge: INEU Borrower name(s); - - - Property Address;. City: - - - Is the property for sa -- - -_ State: - z - Realtor Name: EJ No ❑ Listing date: p` — �I'rice: Borrower Occupied? Yes Realtor Phone: Mailing Address (if different ): No [] City. Phone Numbers: State: Zip: .Bole: Office: Email: Ceti: Other: # ofpeople in household: How longs - -- Mailing Address; City. Phone Numbers: Home: State: Zi Cell: Office: Ernaff, Other: # ofpeople in Household; - Haw long? - First. Mortgage Lender: Type of Loan: Loan. Number: Second Mortgage Lender: ]date You Closed `Your Uan: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Included Taxes & Insurance: I'rirnary Reason for Default Is the loan in Bankruptcy? Yes ❑ No ❑ , 1 yes, provide names, location of court, case nuanber & attorney ALsets' Antot1_ _ r_ r per; - - i�ome; � Value: Other Rea! P-state: Retirement Funds. � ---- - Investments: —- $ Checking: Savings $---- --- ---- -- $ Other: $°---- ---- -: $ Automobile #1: Model: Amount owed: Year: Automobile #2: Model: Value; Amount owed: Value: Fear: Other #rarzs ortation automobiles boats m ��— Y Amount owed: tom cles • Model: Value Month -ome Name of F_mployers: 1. 2. 3. Additional Income Description (not wages }; I. monthly amount: 2 '- - -- --- monthl Borrower Pay Days: Y Found: Co- Borrower Pay Days Monthly �xrenses• (Please only include expenses you are curren paying) EXP SE Mo e C3UNT E ENSE - Food O CTNT 2 M $ e - Car Pa ens Utilities Auto Insurance Condo(Net - , lees - Auto fuel/re irs Med. not cove Install. Loan Pa meet Other ro . a ment Child Su rt/Alim. Cable TV Da IChild o a rruit: S ndin Morse Other Ex nses Amount Available for Monthly Mortgage Payments Based on Mcome & Ex penses: Have you been working with a Housing Counseling Agency? Yes EJ No El rf Yes, please provide the following information: Counseling Agency: Cour isejor: Phone (Office): Fax: r + Email, Have you made application for .Homeowners (H MAP) assistance? Emergency Mortgage Assistance Program Yes No 0 If Yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's to resolve your delinquency? loan servicing compa Yes [] No El If yes, please indicate the status of those negotiations: Please provide the following information, if l{rtow, regarding Your Ian servicing company, Tier or lender's loa Lender's Contact (Name): .Phone, Servicing Com Contact: pany (Name); named to usefrefer this information to my lenderC ervc auth for the sole a p�pose of evaluating my financial situation for possible mortgage option If or understand that Uwe rn/are under no obligation to use the services provided b the named e Y above Borrower Signature Date Co- Borrower Signature - - - - - Date Please forward this docum along with the lender's counsel: following information to lender and Proof of incom Past 2 bank statements Y Proof of any expected inconxe for the last 45 days y _ P Copy of a current utility bill Y Letter explaining reason for del'in uen (hardship letter) 9 ' e any supporting documentation Listing agreement (if property is current! oh the, -Y .. c market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY .n Ronny R Anderson c Sheriff Jody S Smith !k -mot C7 Chief Deputy cxs Richard W Stewart Solicitor -1. C't „� The Bank of New York Mellon f/k/a The Bank of New York Case Number vs. Pamela I Kuhn 2013-2239 SHERIFF'S RETURN OF SERVICE 05/01/2013 02:29 PM- Deputy Ronald Hoover, 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: Pamela I Kuhn at 632 North West Street, Borough of Carlisle, Carlisle, PA 17013. RONALD HOOVER, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, D .., May 02, 2013 R-ONO R ANDERSON, SHERIFF Inc, THE BANK OF NEW YORK MELLON IN THE COURT OF COMMON PLEAS OF f/k/a The Bank of New York, as Successor : CUMBEERLAND COUNTY,PENNSYLVANIA to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust 2003-2 Mortgage Pass-Through Certificate, Series 2003-2 Plaintiff ACTION OF MORTGAGE FORECLOSURE CD vs rncD =M =-,rl =rn X_ PAMELA I. KUHN cnr N :;a CD CD Defendant c �? DOCKET NO 13-2239 CIVIL C REQUEST FOR CONCILIATION CONFERENCE `- ' Pursuant to the Administrative Order 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. Respectfully submitted, LAW OFFICES OF MARK K. EMERY By: " Mark K. Emery, Esquire Supreme Court I.D. No. 72787 410 North Second Street Harrisburg, PA 17101 (717) 238-9883 Attorney for Defendant Pamela I. Kuhn DATE: May 28, 2013 CERTIFICATE OF SERVICE AND NOW this 28th day of May 2013, I, Mark K. Emery, Esquire do hereby certify that I have served the foregoing Request for Conciliation Conference by mailing a true and correct copy via United States first class mail, addressed as follows: Alyk L. Oflazian, Esquire KML LAW GROUP, P.C. Suite 5000-BNY Mellon Independence Center Philadelphia, PA 19106 LAW OFFICES OF MARK K. EMERY By: — Mark K. Emery U s THE BANK OF NEW YORK IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, Plaintiff C= '' -oz ZZ ._: .rrn ( r VS. CIVIL ACTION 7>.--�o _-=_ Cn r-- _.. NO. 13-2239 CIVIL PAMELA I. KUHN . :1 CD Defendant >cz e.s _f p,> CASE MANAGEMENT ORDER AND NOW, this &,k day of June, 2013, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on dO45 , at a?,od ,g, m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendantiborrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duty authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage;proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage;paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, � Alyk L. Oflazian, Esquire Kevin . Hess, P.J. KML LAW GROUP, P.C. Suite 5000-BNY Mellon Independence Center Philadelphia, PA 19106 For the Plaintiff ✓/Mark K. Emery, Esquire Y q 410 North Second Street Harrisburg, PA 17101 For the Defendant :rlm (20 1 LAW 4� 12 THE BANK OF NEW YORK IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New CUMBERLAND COUNTY, PENNSYLVA York,as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust m m C_ 2003-2 Mortgage Pass-Through r— --o�-;-' Certificate, Series 2003-2, Plaintiff CD VS. CIVIL ACTION 77 ry NO. 13-2239 CIVIL PAMELA I. KUHN Defendant IN RE: CONCILIATION CONFERENCE Present at a'conciliation conference held on July 19, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff; Mark Emery, Esquire, attorney for the defendant; and the homeowner, Pamela Kuhn. The bank has indicated that there are a few documents which remain to be submitted. These items will be forthcoming within ten(10) days. It is hoped that the bank will conclude its review by the time of the next conciliation conference. Same is scheduled by order of even date herewith. ORDER AND NOW this Z J day of July, 2013, continued conciliation conference in this matter is set for Friday, August 30, 2013, at 9:30 a.m. in Chambers of the undersigned. BY THE COURT, Kevin Hess, P. J. <\ i/ Nathan Wolf, Esquire For the Plaintiff Mark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant Am THE BANK OF NEW YORK IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, Plaintiff VS. CIVIL ACTION NO. 13-2239 CIVIL PAMELA I. KUHN Defendant ORDER AND NOW, this 2 day of August, 2013, at the request of counsel for the parties, the conciliation conference set for August 30, 2013, is continued to Friday, October 11. 2013, at 11:30 a.m.in Chambers of the undersigned. BY THE COURT, Kevin Hess, P. J. ,/Nathan Wolf, Esquire For the Plaintiff ,/Mark K. Emery, Esquire -4 � n, rn� s• 410 North Second Street / �(=., ` Harrisburg, PA 17101 �r- For the Defendant : zC) :rlm O , c.n THE BANK OF NEW YORK IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, Plaintiff VS. CIVIL ACTION NO. 13-2239 CIVIL PAMELA I. KUHN Defendant ORDER AND NOW, this 2- `0 day of September, 2013, at the request of counsel for the parties, the conciliation conference set for October 11, 2013, is continued to Thursday, October 24, 2013, at 10:30 a.m. in Chambers of the undersigned. BY THE COURT, ---; t //,// Kevin A. ess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff ark K. Emery, Esquire c7 410 North Second Street Harrisburg, PA 17101 For the Defendant r- y' cCn :rlm Oz 1'es c.= _ THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan : Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust : `=`i r, ? _ 2003-2 Mortgage Pass-Through : , �� Certificate, Series 2003-2, r;� Plaintiff • vs. : CIVIL ACTION :. : NO. 13-2239 CIVIL PAMELA I. KUHN • Defendant IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held October 24, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff; Mark Emery, Esquire, attorney for the defendant; and the homeowner, Pamela Kuhn. A requested tax form and documentation of rental income will be forthcoming within five (5) days. This should enable the bank to conduct its review. A continued conciliation conference is set by order of even date herewith. ORDER AND NOW, this Z Y day of October, 2013, continued conciliation conference is set for December 5, 2013, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevin • . Hess, P. J. athan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff rk K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant •rlm CT CS PaLLc.1 /0 aria THE BANK OF NEW YORK IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, Plaintiff tTl s`ri vs. CIVIL ACTION z r 0.1 CD NO. 13-2239 CIVIL ~ PAMELA I. KUHN �_ :u�= Defendant == E5 IN RE: CONCILIATION CONFERENCE ' Present at a conciliation conference held December 5, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff; Mark Emery, Esquire, attorney for the defendant; and the homeowner, Pamela Kuhn. For reasons which we will not belabor, a new package will be submitted in this case within sixteen days. A continued conciliation conference is set by order of even date herewith. i ORDER AND NOW, this (o- day of December, 2013, continued conciliation conference is set for Friday, February 21, 2014, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevi A. Hess, P. J. d athan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff - �IGlark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant. Am 1 , k t' THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan : Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust : 2003-2 Mortgage Pass-Through . Certificate, Series 2003-2, • Plaintiff • vs. : CIVIL ACTION : NO. 13-2239 CIVIL PAMELA I. KUHN • Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this ..2.2t1 day of January, 2014, continued conciliation conference set for February 21, 2014, is continued to Wednesday, February 26, 2014, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, 41- Kevi, . Hess, P. J. ✓Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 -� For the Plaintiff fc-, rn Mark K. Emery, Esquire N 410 North Second Street < � "PiHarrisburg, PA 17101 2IC F. For the Defendant >2C fr&t.1-C-CL) c.3 7� THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan : Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust : 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, • Plaintiff • • vs. : CIVIL ACTION cnar _ z rr NO. 13-2239 CIVIL - �' �=` PAMELA I. KUHN Defendant • c? IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 `1 ` day of February, 2014, on agreement of the parties, the conciliation conference scheduled in this matter is continued until Friday, April 4, 2014, at 1:45 p.m. in Chambers of the undersigned. The purpose of the continuance is to allow additional documents to be submitted. Said submission shall be made within one week. BY THE COURT, Kevin al Hess, P. J. t Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff ✓ Mark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant ao-p ES 02:2-1.6.4_ Q f s/iy THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank, N.A., as Trustee, for the ABFS Mortgage Loan Trust : 2003-2 Mortgage Pass-Through Certificate, Series 2003-2, Plaintiff VS. PAMELA L KUHN Defendant : CIVIL ACTION : NO. 13-2239 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 3' day of April, 2014, on agreement of the parties, the conciliation conference scheduled for April 4, 2014, is continued to Friday, May 16, 2014, at 2:00 p.m. in Chambers of the undersigned. Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff .Xrk K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant 041 `="117 BY THE COURT, THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f /k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank, N.A., as Trustee, for the ABFS Mortgage Loan Trust : 2003 -2 Mortgage Pass - Through Certificate, Series 2003 -2, Plaintiff vs. PAMELA I. KUHN Defendant : CIVIL ACTION : NO. 13 -2239 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this /S. day of May, 2014, on agreement of the parties, the conciliation conference scheduled for May 16, 2014, is continued to Friday, June 27, 2014, at 1:45 p.m. in Chambers of the undersigned. Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff Mark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant i e.s I12.3; lid.. s �sliy BY THE COURT, 4 Kevin Hess, P. J. (1 —o THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The 13ank of New . CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank,N.A., as Trustee, for the ABFS Mortgage Loan Trust : 2003-2 Mortgage Pass-Through . Certificate, Series 2003-2, Plaintiff vs. : CIVIL ACTION : NO. 13-2239 CIVIL PAMELA I. KUHN Defendant • IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this S f' day of June,2014, on agreement of the parties, the conciliation conference scheduled for June 27, 2014, is continued to Friday, July 18, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, / KevinA. ess. " Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff Xark K. Emery, Esquire nim 410 North Second Street Harrisburg, PA 17101 • z=' For the Defendant "'r r`r VI S' / 'aiVl r�yy� Lr ICS THE BANK OF NEW YORK : IN THE COURT OF COMMON PLEAS OF MELLON f/k/a The Bank of New : CUMBERLAND COUNTY, PENNSYLVA York, as Successor to JP Morgan Chase Bank, N.A., as Trustee, for the ABFS Mortgage Loan Trust : c-, r- 2003-2 Mortgage Pass -Through : Certificate, Series 2003-2, rncn Plaintiff zr= vs. : CIVIL ACTION mac _o '• c-; r c, : NO. 13-2239 CIVIL �=-. "' • c- ry PAMELA I. KUHN Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 15` day of July, 2014, on agreement, the conciliation conference in this case is continued generally. The matter may be relisted by either party. BY THE COURT, Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff Mark K. Emery, Esquire 410 North Second Street Harrisburg, PA 17101 For the Defendant :rlm loopi es LL f 7// 4/i4' Kevin A. " ess, P. J.