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Home My WebLink About13-2290 Supreme Co iof� -ennsylvania CollPrtof CO mm on , Pleas For Prothonotary Use Only: Civittow r Slieet r .•. , Docket No: ' 4� Cumberland County The information collected on this form. is used solely court administration purposes. This fibrin does not supplement or replace the, filing and service of pleadings or other papers as required by lam or rules of court. Commencement of Action: S Z Complaint 0 Writ of Summons 0 Petition . Transfer from Another Jurisdiction Q Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: PNC Bank, National Association Ellen Deaso a /k/a Ellen Marie Deaso et al T Dollar Amount Requested: Dwithin arbitration limits I Are money damages requested? ❑-i Yes ED No .(check one) x, outside arbitration limits O N Is this a Class Action Suit? Yes R No Is this an MDJAppeal? [] Yes El No A Name of Plaintiff /Appellant's Attorney: HARRY B. REESE, .ESQUIRE 0 Check here if you have no attorney (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 APPEALS 0 Intentional El Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution El Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection: Other Board of Elections E] Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other S E] Product Liability (does not include mass tort) E] Employment Dispute: E Discrimination 0 Slander/Libel /Defamation C El Other: El Employment Dispute: Other r_1 Zoning Board Other: T I p Other: O MASS TORT Asbestos N [] Tobacco 0 Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS El Toxic Waste Ejectment M Common Law /Statutory Arbitration Other: B � Eminent Domain/Condemnation E] Declaratory Judgment Q Ground Rent 0 Mandamus 0 Landlord/Tenant Dispute E] Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial Quo Warranto 0 Dental Q Partition El Replevin Legal Q Quiet Title 0 Other: Medical 0 Other: E] Other Professional: Updated 1/112011 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s ' udren.com PNC Bank, National Association 3232 Newmark Drive, Miamisburg, OH 45342 Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso 1509 Paul Spring Parkway, Alexandria, VA 22308 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County r .= r-33. �- cp MORTGAGE FORECLOSURE NO. 13-2290 PRAECIPE FOR JUDGMENT BASED ON COURT ORDER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO pursuant to the Court's Order dated 02/26/2014 (in accordance with the Complaint) and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Court Order $ 109.258.53 TOTAL $109,258.53 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above . e and correct copy of the Praecipe has been mailed pursuant to Pa.R.C.P. Rule 237. DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 11,11011 MJU#: 13020679 CASE#: 13020679-1 ten, Esquire PAID 104252 PRO PROTHY PNC BANK, NATIONAL ASSOCIATION : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ELLEN DEASO, A/K/A ELLEN MARIE DEASO, A/K/A ELLEN M. DEASO :,73 r;c43 -ri =r-ri Defendant : No. 13-2290 Civil na """4 IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMEN cf? BEFORE GUI DO, J., EBERT, J., AND PECK, J. ORDER OF COURT AND NOW, this 26th day of February, 2014, upon consideration of the Plaintiff's Motion for Summary Judgment, the Defendant's Response thereto, the brief filed by the Plaintiff, and the Court noting that the Defendant did not file a brief or appear for oral argument in the matter; IT IS HEREBY ORDERED AND DIRECTED that the Plaintiffs Motion for Summary Judgment is GRANTED, and that Judgment, in rem shall be entered in favor of the Plaintiff and against Defendant, Ellen Deaso, a/k/a Ellen Marie Deaso, a/k/a Ellen M. Deaso in the amount of $109,862.05, together with ongoing per diem interest, escrow advances, and any additional recoverable costs to date of Sheriffs Sale; and for foreclosure and sale of the mortgaged property. By the Court, UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 JORDAN DAVID, ESQUIRE - ID#311968 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com. PNC Bank, National Association C/O PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO 1509 PAUL SPRING PARKWAY ALEXANDRIA, VA 22308 ATTORNEY FOR PLAINTIFF COPY COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. �w_"!0 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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 this 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 claimed in the Complaint or 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. PNC Bank, National Association, et al., Plaintiff(s) vs. Ellen Deaso aka Ellen Marie Dense aka Ellen M. Deaso, at al., Defendant(s) UDREN LAW OFFICES Ms. Laura Dolly 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 State of: District of Columbia) ss. County of: Washington ) Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: Steve Reeder Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File I#: 123166-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: —Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso Court Case No. Cumberland Co 13-2290 Civil , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; that on the 9th day of May , 20 , at 6:57 o'clock __LM at 1509 Paul Spring Parkway the undersigned served the documents described as: Complaint in Mortgage Foreclosure , in Alexandria. VA 22308 A true and correct copy of the aforesaid document(s) was served on: Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso ® By personally delivering them into the hands of the person to be served. ❑ By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex F ; Skin Color White ; Hair Color Brown ; FacialHair Approx. Age 50 ; Approx. Height 5' 5" ; Approx. Weight 1 An ® To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersign 4 eclares under penalty of perjury that the f. 7.* ' g is true and correct. Lignature of Server APS International, Ltd. Subscribed and sworn to before me this 1 b day of a ,20 13 T 211 F -k G , 0.3 Notary Pu8ic (Commission Exp) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 TO: Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso 1509 Paul Spring Parkway Alexandria, VA 22308 Date of Notice: July 9; 2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST,YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TJENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY: UDREN LAW OFFICES, PC. A C o * y ' . , tiff HARRY B. RE E, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 13020679 CASE#: 13020679-1 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Mark). Udren, Esq. Licensed: PA, NJ, FL UDRENLA W OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill, NJ 08003 (PH)856-669-5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 Re: PNC Bank, National Association vs. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO, Cumberland County C.C.P. No. 13-2290 MJU#: 13020679 CASE#: 13020679-1 Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MN/ Enclosures MJU#: 13020679 CASE#: 13020679-1 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken PA. 19428 (PH)215-568-9500 Mark,/. Udren, E . Licensed: PA, NJ, IL UDREN LAW OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill NJ 08003 (PH)856-669-5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Re: PNC Bank, National Association vs. Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO, Cumberland County C.C.P. No. 13-2290 MJU#: 13020679 CASE#: 13020679-1 Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MJU/ Enclosures MJU#: 13020679 CASE#: 13020679-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s ' udren.com PNC Bank, National Association Plaintiff v. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A"'. The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for: said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §49 falsification to authoritiies. Dated: June 9, 2014 MJU#: 13020679 CASE#: 13020679-1 • 0'11"; a-intiff id Neeren, Esquire PA ID 204252 Ddpartment of Defense Manpower Data Center Results as of : Jun -09-2014 09:37:25 AM SCRA 3.0 Status Report Pursuant to Sere cemeffibers Civil Relief Act Last Name: DEASO First Name: ELLEN Middle Name: M. Active Duty Status As Of: Jun -09-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NAS . - .. -.. No ‘‘. NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA -. NA - -. •_. No - NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA 3. -` ,No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty i Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The'Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOM Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: DAG3K2F7106BV30 Department of Defense Manpower Data Center Results as of : Jun -09-2014 09:36:26 AM SCRA 3.0 Status Report Pursuant to Servicemegtbers Civil Relief Act Last Name: DEASO First Name: ELLEN Middle Name: MARIE Active Duty Status As Of: Jun -09-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .. • — , _ - No " NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End DateStatus Status Service Component NA i 4,1]] NA • � 1. . _ v No1 7 . NA This response reflects where the Individual left active dub) status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA _I ,No l NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The'Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually, reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: FA8CF2D7R06AB30 Ddpartment of Defense Manpower Data Center Results as of : Jun -09-2014 09:35:10 AM SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: DEASO First Name: ELLEN Middle Name: Active Duty Status As Of: Jun -09-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA + No `. NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ' 4 .No NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director , Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 • The'Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this' certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the�SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually;reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: JAL2J2D7306AS60 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO ESQUIRE - ID#311050; HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 .- o n_ JOHN ERIC KISHBAUGH ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 <C) :: - o DAVID NEEREN, ESQUIRE - ID#204252 :r,> ° JORDAN DAVID, ESQUIRE - ID#311968 '' WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 669 - 5400 pleadings @udren.com PNC Bank, National Association COURT OF COMMON PLEAS C/O PNC Bank, N.A. CIVIL DIVISION 3232 Newmark Drive CUMBERLAND County Miamisburg, OH 45342 Plaintiff NO. �a-a� U l V. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO 1509 PAUL SPRING PARKWAY ALEXANDRIA, VA 22308 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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 this 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 claimed in the Complaint or 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. e0 y C_)L44 JZ4� a8 9c9 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 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 dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir 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 SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is PNC Bank, National Association . Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff's favor: Assignor: N/A Assignee: N/A Date of Assignment: N/A Recorded Date: N/A Book/Instrument #: N/A Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso (hereinafter "Defendants "), are the owners of property located at 615 Bloserville Road, (Upper Frankford Township), Newville, PA 17241, by virtue of Deed dated 07/27/2004 and recorded 07/28/2004 in Official Records Book 264 at Page 1961 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 10/02/2006, Defendant(s) and/or their predecessor: ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO promised to pay to the order of National City Mortgage a Division of National City Bank, the principal sum of $107,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 10/0212006, Defendant(s) and/or their predecessor: ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO to secure the Note, mortgaged to National City Mortgage, a Division of National City Bank , the Property which is the subject of this action. The Mortgage was recorded on 10/09/2006 in Official Records Book 1968 at Page 4013. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 07/01/2012, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $99,555.25 Accumulated Interest $3,397.59 Accumulated Late Charges $229.68 Escrow Deficit /(Reserve) $834.36 Recoverable Balance $5,241.65 Grand Total $109,258.53 The above figures are calculated to 2/27/2013: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 4.62500 %. The per diem interest accruing on this debt is $12.6100 and that sum should be added to the above date and each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $28.71. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $109,258.53 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: � / �'/ �ARRY B. R E, ESQUIRE PA 310501 VERIFICATION I, Luann Jones , as an Authorized Signer of the Plaintiff, PNC Bank, National Association , do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and that 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. Section 4904 relating to unsworn falsification to authorities. Date I"� I (o Name: Luann Jones Title: Authorized Signer Company: PNC Bank, National Association MN #: 13020679 CASE #: 13020679 -1 02- 28 -'13 14;52 FROM -ABLE ABSTRACTS T -778 P0011/0011 F -474 Exhibit "A" Legal Descr on Ail that certain parcel of land situate in the Township of upper Frankford, County of Cumberland and State of Pennsylvania, being known and designated as follows: Beginning at a concrete block at the public road leading to Bloserville at lands now or formerly of Mervin H. Griffie, at ux; thence in an Easterly direction along the said land now or fom dy of Mervin H. Griffis, et ux, 152 feet to line of lends now or formerly of J.B. Hurley to a concrete block; thence in a Southeasterly direction 90 feet to a concrete block; thence in a Westerly direction, 140 feet to a concrete block at the public road to Bloserville; thence in a Northerly direction 90 feet along said road to the place of beginning. Tax H?: 43- 122922 -OI OA I Certify this to be recorded in Cumlv�d County PA rage S of g 6 /l Recorder of Deeds PNC Attention: Collection Department MORTGAGE" tfis- t7tD7 -015) 3232 N—tk Drive Vi- isburg, OH 45342 ELLEN MARIE DEASO 9008 9111 � , � 8966 9653 7196 615 BLOSERVILLE RD 9 NUVILLE. PA 17241 Please f nd enclosed the ACT 91 NOTICE for Loan Number: 0004832333 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. Exhibit A DR672 A Dwision of PNC Bank, National Assoaabon T1 337 -910 -1200 72 BMS22 5626 3232 Newmark or Miam sburg OH 45342 P.O Box 1820 Dayton OH 45401.1820 Date: 122/2013 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 von must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800- 342 -2397. (Persons with impaired hearing can call (717) 780- 1869) This Notice contains important legal information. U 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 NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCCIGN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO 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): ELLEN MARIE DEASO PROPERTY ADDRESS: 615 BLOSERVILLE RD NEWVILLE,PA 17241 LOAN ACCT. NO.: 0004832333 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, • 1F 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 _NOTICJE. 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 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 tender 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 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 SHERIFFS SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION — Available fiords 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 baakruptcy you can still apply for Emergency Mortgage Assistance.) $OW 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: 615 BLOSERVILLE RD NEWVILLE, PA 17241 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 $756.12 per month, From 1/1/2013 through 1/1/2013 at $766.93 per month Monthly Payments Accrued: $5,303.65 Late Charges Accrued: $200.97 Non - Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $54.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $5,558.62 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 $5,558.62, 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, 0.1145342 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 riehts to accelerate the morteaee debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON —The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY 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 abd prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving 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 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 aAer the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE —You _ may or X may not (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 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 FOKM 1 n IN THE COURT OF COMMON PTUAS Ol✓c.-, a Q�± S bu 801, CUMBERLAND COUN:Y, PENiv'S`, LV) As E plaintiff(s) r n rn —0 . V N 70 (:J VS. —4 Defendant(s) f U`. I "� 1�'ll r �.3 NOTICE OF RESEDENTLALL MORTG FORECLOSURE =- DINTRSION PROGRAM M You have been. served with. a foreclosure complaint that could cause you to lase 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 coliciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the fallawiner steps to be eligible for a conciliation conference. First, within twenty- (20) days of your receipt of this notice, you must contact MidP 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.le�al 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 eorir 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 eov erence. It is not necessary for you to contact MidPenn Legal Ser •ice for the appointment of a i ®gd1 representative_ However, you must provide y our 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 RegUest 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 comp laint, i f you do so and a conciliation conference is scheduled., you will have an opportunity to mccl With a representative of your lender iri un artern}ft iv warlc Out easCiiabiC ar anae ^Cuts with your lender before the mortgage fore closure slut proceeds forwaid. IF YOU FISH TO SAVE YOtTR HO?47E, YOU MUST 4CT QL 4ND T AKE TIME STEPS REQUIRED BY TIIIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: r Daw [Si a u f r_�sei for aintiff) HA B. REESE, ESQUIRE PA ID 310501 900 /Z00d WdLL :DO EIOZ 9Z add :red FORM 2 Cumberland County Resideufial Mortgage Foreclosure Diversion Program Financial 'Worksheet Date Cumberland. County Court of Common Pleas Docket BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: State: Zip: City: is the property for sale? Yi.s ❑ No ❑ Listlri° date: Pric:: Realtor Name: Realtor Phone: Borrower Occupied,? Yes ❑ No ❑ Mailing Address (if different); State _Zip: City: Phone Numbers: Home. Office: Cell: Other: Email: of people in household: How long? Mailing Address: State: Zip: City: phone Numbers- Home: Office: Cell: Other: Email: TF of people in household: How long? First Mortgage Lender: Type of Loan: Lcan Number: Dale You Closed Yom Loan: Second Mortgage Lender: Type of Loan: Loan Numbs:: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy-? Yes ❑ No 900 /600d Wdll:Do eloz 9Z add :xed If yes, provide names, location of court, case number & attorney: Assets Amount Owed, Value: Home: $ $ Other Real Estate: S $ Retirement Rands: $ IncTestments: $ $ Checking: $— $ Savings: $ Automobile #1: Model: Year: Amount owcd: Value: Automobile #2 : Model: Year: Amount awed' Value: Oth °r_transvortation (autozrtabil °s oaa7s. in tore.clesl' Model: 'Year: , Amoun! owed: V alue I M.Outhly Xncame ! Name of Employers: 3. 1. Additional income Description (not Wama:es): 1 monthly amount: monthly amotmt: Borrower Pay Days: Co- Borrower Pay Days: Monthly Exoe»ses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE ;AMOUNT lvlortQaae Food I 12 Mort¢age Utilities Car Pa ent(s) Cnndo/Nei.ah. Fees ?auto lnsurwca Med. (not covered) ! Other ro a ent ' Auto fuel/repairs 1 Install, Loan Pa. mcrit i Cable 7V Child SSu ort/Alim, I Spending Mon Da /Child Care,/Tuit. Other E eases Amount Available for Monthly Mortgage Fayrnsnts Based on Lncome &)= tipenses: I Have you been working with a Housing Counseling Agency? Yes ❑ No if yes, please provide the ol.lma'ing information: Counseling Agency: Counselor: Phone (Office): Fes`= 2 900/V00d Wdll:VO ELOZ 9Z add :xed Email: Have you made application. for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ N.o ❑ If yes, please indicate the status of the application_: Have you had any prior negotiations with your ]ender or lender's loan servicing company to resolve your delinquency? Y'es ❑ No t] if yes, please indicate the status of those negotiations: Please provide the following information, it know, regarding your lender or Lender's loan servicing company; Lender's Contact (Namt): Phone: Servicing Company (Name): Contact: Phone: I/ e , authorize the above named to use /refer this information to Iny lender /servicer for the sole purpose of evaluating my financial situation_ for possible mortgage options. 1 WC understand that atn /are under no obligation to use the services provided by the above named Borrower Signature Date C — orr • r S Pate B.._..o �, e. S:�ature Please forward this document along with the following information to lender and lender's counsel: \ Proof of income �1 past 2 bank statements Proof of any expected jocome for the last 45 days 1� Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) --- - 900/500d mall -VO EIOZ 9Z add :XBA FORM. 3 IN TSB COURT OF COMMON PLEAS OF WWMOA �5JodO : CUMBERLAND COUNTY, PENNSYLVANIA Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Admimstrative Order dated 2012 governing the Cumberland Count' Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: Defendant is the owner of the real property , %'hich is the subject of this mortgage foreclosure ac'd.on, 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Tviortgage Foreclosure Diversion Program" and has taken all of the steps -required in That Notice to be eli to participate in a court - supervised conciliation conference. The undersigned verities that the statements made herein are true and oorrect. I understand that false statements are made subject to the penalties of 13 Pa, C.S. 9`4904 relating to unsworn falsification to authorities. Signature of Defendant's counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date :xe 900/900d Wdll:g0 ELOZ 9Z Jdy j UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE. ID#90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 KATHERINE E. KNOWLTON, ESQUIRE - ID #311713 C= ° _n JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID #204252 ON JORDAN DAVID, ESQUIRE - ID #311968 �- q WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 - 3620.E 856- 669 -5400 Pleadings@udren.com PNC Bank, National Association COURT OF COMMON PLEAS 3232 Newmark Drive, Miamisburg, 01145342 CIVIL DIVISION Plaintiff CUMBERLAND County . V. NO. Ellen Deaso aWa Ellen Marie Deaso aWa Ellen M. Deaso 1509 Paul Spring Parkway Alexandria, VA 22308 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; Katherine E Knowlton, Esquire, and John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire; Jordan David, Esquire on behalf of the Plaintiff, in the above - captioned matter. UD DRY LAW OFFI S, P.C. BY B. SE, ESQUIRE P D 310501 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson � -� #C Sheriff OF THE PROTHONOWY Jody S Smith ��;�+.1i�r �mtpraFi�.�aw�,.r�,� 2013 HA Y �-3 PM 2 0 7 Chief Deputy Richard W Stewart Solicitor OF C;CG OFF CUMBERLAND COUNTY PENNSYLVANIA PNC Bank, National Association vs. Case Number Ellen Deaso 2013-2290 SHERIFF'S RETURN OF SERVICE 04/30/2013 04:55 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Ellen Deaso, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found"at 615 Bloserville Road, Upper Frankford, Newville, PA 17241. Residence is vacant. SHERIFF COST: $47.02 SO ANSWERS, May 02, 2013 RON R ANDERSON, SHERIFF (C)CountySuito ShoriN,Toleosoit,Inc. ELLEN DEASO DEFENDANT 1509 PAUL SPRING PARKWAY ALEXANDRIA, VA. 22308 PNC Bank,National Association, COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, Cumberland County V. MORTGAGE FORECLOSURE C-1-W. Ellen Deaso, NO. 13-2290 Defendant. DEFENDANT'S RESPONSE TO COMPLAINT AND DEFAULT NOTICE I am the defendant in this case. I have been trying-and am continuing to try-to work through PNC Bank's processes for achieving a"deed in lieu of foreclosure" in order to resolve the economic hardships created by my recent and permanent physical disability which makes me unable to make the payments on my mortgage to PNC. The bank's processes for doing so are complicated. VA file I have submitted many pages of financial information as required by the PNC"Home Affordable Alternative to Foreclosure"process, I was advised yesterday by telephone that PNC has sent me a letter dated July 12,2013 informing me of additional steps and information needed to complete this process. I have not yet received that letter,but when I do I will endeavor to comply with it as promptly as I can. I would respectfully ask the Court to please allow me a reasonable amount of time to complete this procc&% Th ELLE As S u or Vau pring NParkway cc:Urden Law Offices Alexandria,VA. 22308 crn e PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) Please list for December 20, 2013. CAPTION OF CASE (entire caption must be stated in full) PNC Bank, National Association o r=, _ vs. c ry --0 -<> N c, , Ellen Deaso v No. 13-2290 Civil arm _„_ 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to ,w complaint, etc.): Plaintiff's Motion for Summary Judgment 2. Identify all counsel who will argue cases: (a) for plaintiffs: Harry B. Reese, Esquire, Udren Law Offices, P.C. (Name and Address) 111 Woodcrest Road, Cherry Hill, NJ 08003 (b) for defendants: Ellen Deaso, Defendant Pro Se (Name and Address) 1509 Paul Spring Parkway, Alexandria, VA 22308 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argu Court Date: December 20,2013 'T n ru re V/" `■-r pA:Zp 310501 ,y Print your name Plaintiff/Movant Date: October 21 , 2013 Attorney for INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR(not the Prothonotary) before argument. 2.The moving party shall file and serve their brief 14 days prior to argument. 3.The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR(not the Prothonotary)after the case is relisted. a � gik9ell i S ~ r 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings(a udren.com PNC Bank,National Association COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso NO. 13-2290-Civil Defendants PRAECIPE FOR ARGUMENT LIST TO THE PROTHONOTARY: Please place Plaintiff's Motion for Summary Judgment in the above-captioned case on the Argument List. This matter does not require the taking of testimony. UDREN LAW OFFICES, P.C. B ' Y _ Att• er for Plaintiff/ ovant HARRY B. REESE,.ESQUIRE PA ID 310501 Notice has been provided to the following by the moving party: Ellen Deaso Ellen Deaso 1509 Paul Spring Parkway 615 Bloserville Road Alexandria, VA 22308 (Upper Frankford Township) Newville, PA 17241 a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003 856-669-5400 pleadings @udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND COUNTY v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso NO. 13-2290-Civil Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that he has served pursuant to Pa.R.C.P. 440 true and correct copies of Plaintiffs Praecipe for Listing Case for Argument, Plaintiff's Brief in Support of its Motion for Summary Judgment, and proposed form of Order upon the following person(s) named herein at their las known address or their attorney of record via USPS First Class Mail. Date Served: October 2013 TO: Ellen Deaso Ellen Deaso 615 Bloserville Road 1509 Paul Spring Parkway (Upper Frankford Township) Alexandria, VA 22308 Newville, PA 17241 Defendant Defendant UDREN LAW OFFICES, P.C. By: Al A tow e',for Plaint' "f/Movant HARRY S. REE , ESQUIRE PA ID 310501 #2. PNC BANK, NATIONAL ASSOCIATION, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA rnno � ' ` ---``' V. � CI)r- .1 co c� r—~c ELLEN DEASO a/k/a/ELLEN MARIE : NO. 2013-2290 CIVIL TERM _ � DEASOa/h/� ELLENK4. QEA��, a/k/a Defendant IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT BEFORE GUIDO, MASLAND, PECK,JJ. ORDER OF COURT AND NOW,this 6I day of JANUARY, 2014,at the request of the Defendant,argument on Plaintiff's Motion for Summary Judgment is continued to FRIDAY,FEBRUARY 14,2014. The Court Administrator is directed to place this matter on the Argument Court List for that date. The parties are directed to file (or re-file)their briefs with the Court Administrator in accordance with the Local Rules of Court. By the Court, Edward E. Guido,J. ^~~� Harry B. Reese, Esquire 111 Woodcrest Road Cherry Hill, N]. 08003 ueaso 1509 Paul Spring Parkway Alexandria,Virginia 22308 .�~NathanC.VVo|t Esquire �, Wolf, � ^ \� LC.CourtAdmministratmr ~. �� *~� -� t 0 's|d " ~&� ' ".�� , 0 � �� - - 0-op t MA,./ ~~ « . , PNC BANK, NATIONAL ASSOC. IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA Plaintiff V. CASE NO. 2013-2290 ELLEN DEASO, IN MORTGAGE FORECLOSURE Defendant PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of Robert L.O'Brien,Esquire as counsel for PNC Bank in the above matter, limited to appearance at the Argument Court scheduled for February 14, 2014. Robert L. O'Brien I. D. 28351 19 West South Street Carlisle, PA 17013 Dated: February 12, 2014 rn ;r- r;s r- s CD .Z N .aC.3 PNC BANK, NATIONAL ASSOCIATION : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ELLEN DEASO, A/K/A ELLEN MARIE DEASO, =m rrI A/K/A ELLEN M. DEASO Defendant No. 13-2290 Civil C IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMEN - D-t». BEFORE GUIDO, J., EBERT, J., AND PECK, J. ORDER OF COURT AND NOW, this 26" day of February, 2014, upon consideration of the Plaintiff's Motion for Summary Judgment, the Defendant's Response thereto, the brief filed by the Plaintiff, and the Court noting that the Defendant did not file a brief or appear for oral argument in the matter; IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion for Summary Judgment is GRANTED, and that Judgment, in rem, shall be entered in favor of the Plaintiff and against Defendant, Ellen Deaso, a/k/a Ellen Marie Deaso, a/k/a Ellen M. Deaso in the amount of$109,862.05, together with ongoing per diem interest, escrow advances, and any additional recoverable costs to date of Sheriff's Sale; and for foreclosure and sale of the mortgaged property. By the Court, `Y`�, U, V M. L. Ebert, Jr., /Harry B. Reese, Esquire Attorney for Plaintiff 111 Woodcrest Road Cherry Hill, NJ 08003 Ilen Deaso, Pro Se Defendant 615 Bloserville Road Newville, PA 17241 OR 1509 Paul Spring Parkway Alexandria, VA 22308 bas ;7a (0/11 UDREN LAW OFFICES, P.C. ' i"'`�� XrTTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER:Of' .,.�, 0 Ail , !1 rz 111 WOODCREST ROAD SUITE 200 r1 �_"' CHERRY HILL, NJ 08003-3620 LtaRI), 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 109,258.53 Interest From 10/05/2013 to Date of Sale 12/03/2014 Ongoing Per Diem of $12.61 to actual date of sale including if sale is held ata later date (Costs to be added) Dt/I dg So/ a �-r00- lo aJo 3. 7S " MJU#: 13020679 CASE#: 13020679-1 l9.75fft/ /4'•S()"if $ 5359.25 David Neeren, Esquire PAID 204252 a VO . as eo. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleading®udren.com PNC Bank, National Association Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE c- Defendant(s) NO. 13-2290 CERTIFICATE OF ACT 91 r= (17) I hereby state that as the attorney for the Plaintiff in the above -captioned matter: 37 -; El Act 91 procedures have been fulfilled El Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN B : Attorney f ntiff OFFICE David Neeren, Esquire PAID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO 1509 PAUL SPRING PARKWAY ALEXANDRIA, VA 22308 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relatin to unsworn falsification to authorities. REN LAW !N'' , P.C. or Plaintiff D. itl Neeren, Esquire PAID 204252 C.) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(n udren.com PNC Bank, National Association Plaintiff v. Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 1°4-P?4 4 /1/skiiip PNC Bank, National Association , Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 615 Bloserville Road, (Upper Frankford Township), Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s): Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso 1509 Paul Spring Parkway Alexandria, VA 22308 2. Name and address of Defendant(s) in the judgment: Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso 1509 Paul. Spring Parkway Alexandria, VA 22308 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 615 Bloserville Road Newville, PA 17241 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. • DATED: MJU#: 13020679 CASE#: 13020679-1 SL/' PAID 204252 s UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @udren. corn PNC Bank, National Association Plaintiff V. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Cl [� MORTGAGE FORECLOSURE rn �r GG NO. 13-2290 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso 1509 Paul Spring Parkway Alexandria, VA 22308 C? CS` Your house (real estate) at 615 Bloserville Road, (Upper Frankford Township), Newville, PA 17241 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $109,258.53, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net PNC BANK, NATIONAL ASSOCIATION Vs. NO 13-2290 Civil Term CIVIL ACTION — LAW ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $109,258.53 L.L.: $.50 Interest FROM 10/5/2013 TO DATE OF SALE 12/3/2014 - ONGOING PER DIEM OF $12.61 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $5,359.25 Atty's Comm: Due Prothy: $2.25 Atty Paid: $215.52 Other Costs: Plaintiff Paid: Date: 6/10/14 (Seal) David D. Buell, Prothonotary REQUESTING PARTY: Name: DAVID NEEREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: -37 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Dated: "y UDREN LAW ! FFICES, P.C. MJU#: 13020679 CASE#: 13020679-1 BY: Attorneys for Plaintiff ELIZABETH L WASSALL, ESQ. PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2290 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO; PROPERTY: 615 Bloserville Road, (Upper Frankford Township), Newville, PA 17241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/03/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 13020679 CASE#: 13020679-1 Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered ❑ Insured COD Certified El Return Receipt for Merchandise ❑ Intl Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: With Postal Insurance LJ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 4 13-2290 Tenants/Occupants 615 Bloserville Road PA 17241 ICNewville, 5 Uel,/,� -_ 6 12/03/2014 •U 7 3003 V 18.70E 8 jJ 9 10 11 12 13 14 15 Total number of Pieces Listed by Sender 4 Total Number of ieces Receiv at Pos Officereconstruction / /l/ Pos • aster, Pe ► (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and 5921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. / PS Fonn 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Ellen Deaso a/k/a Ellen Marie Deaso a/k/a Ellen M. Deaso - MJU# 13020679-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. ELLEN DEASO A/K/A ELLEN MARIE DEASO A/K/A ELLEN M. DEASO; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13-2290 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: t ,1 UDREN LAW OFFICES, P.C. BY. Attorney for Plaintiff ELIZABETH L WASSALL, ESE PA ID 77788 EIN PNC Bank, National Association. et. al. Plaintiff(s) vs. Ellen Deaso aka Ellen Marie Deaso, et. al., Defendant(s) r UDREN LAV OFFICES Ms. Henni Crommarty I 1 I Woodcrest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 State of: District of Columbi) ss. County of: Washington APS INTF.RNATIONA Service of Process by APS International, Ltd. 1-800-328-7171 ! APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 129990-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso Court Case No. Cumberland Co 13-2290 Name of Server: Dylan Stephenson , undersigned, being duly sworn. deposes and says that at the time of service. s/he was of legal age and was not a party to this action; Date/Time of Service: that on the 8th day of July , 20 14 at 9:40 o'clock P Place of Service: Documents Served: at 1509 Paul Spring Parkway the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property • to Alexandria, VA 22308 Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso Person Served, and Method of Service: Description of Person Receiving Documents: By personally delivering them into the hands of the person to be served. By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated. that he/she resides with Ellen Deaso, aka Ellen Marie Deaso aka Ellen M. Deaso at the place of service. and whose relationship to the person is: The person receiving documents is described as follows: Sex F • Skin Color white ; Hair Color brown Approx. Age 65 • Approx. Height 5 3" : Facial Hair Approx. Weight 175 To the hest of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury th f• eg. n . 's true and correct.,c,,,f., 'gnature of Server APS International, Ltd. Subscribed and sworn to before me this Li 6 Lith day of ,W! , 20 Notary Pu c k,H1/11ft 1, q 4 5 �'V ��'•., NOTARY ANGELA H. CROSON v , • I • ~'�.�il � My LIC DISTRICT OF COLUMBIA �J� C Commission Expires March 31, 2019 • py M 4 •........ '�.,. O I S T R (Commission Expires)