HomeMy WebLinkAbout13-2468 Supreme Cou of peauisylvaiiia
Coutt of Catnx on Pleas
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�C`f� C0V Sheet For Protlaonot ru 001
Cum_ Berland' ' County � °�� °� �°: I
The information collected on this form is used solely for court administration purposes. This form does not
Su lement or replace the alias and service o leadin s or other a ers as required b law or rules o court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin
E Lead Plaintiff Name: Lead Defendant's Name:
C GREEN TREE CONSUMER DISCOUNT COMPANY JACK V. COBLE JR
T
I
O Are money Damages requested ?: ❑ Yes ® No Dollar Amount Requested within arbitration limits
(Check one) X outside arbitration limits
A Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO
F_ Name of Plaintiff/appellant's Attorney: KML Law Group, P.C.
❑ Check here if you are a Self-Represented (Pro Se Litigant
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your.
PRIMARYCASE. If you are making more than one type of claim, check the one that
you consider most important:
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Zoning Board
❑ Product Liability (does not include ❑ Statutory Appeal: Other
❑ Employment dispute:
E mass tort)
- C ❑ Slander/Libel Defamation Discrimination
❑ Other ❑ Employment Dispute: Other
T ❑ Other:
I
d MASS TORT ❑ Other
N T ❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort -Implant
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory
❑ Eminent Domain/Condemnation Arbitration
$ ❑Other ❑ Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑Mandamus
® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order
❑ Dental ❑ Partition ❑ Quo Warranto
❑ Legal ❑ Quiet title ❑ Replevin
❑ Medical
❑ Other Professional: ❑ Other ❑ Other
Pa.R.C.P. 205.5 Updated 1/1/2011
KML LAW GROUP, P.C.
SUITE 5000 - BNY MELLON INDEPENDENCE CENTER
701 MARKET STREET J TA R PHILADELPHIA, PA 19106
(866)413 -2311
GREEN TREE CONSUMER DISCOUNT COMPANY lv S ERLA RU tJ6bNVyRT OF COMMON .PLEAS
7360 S. Kyrene Road R EN NSYLVANIA
Mail Stop: T -208 OF Cumberland COUNTY
Tempe, AZ 85283
Plaintiff CIVIL ACTION - LAW
vs.
JACK V. COBLE JR ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s) and Record Owner(s)
208 4th Street CIVIL ACTION: MORTGAGI
Summerdale, PA 17093 F I OSM
Defendant (s)
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 1.7013
717 - 243 -9400
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las 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 LLAM
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cx,�-� s / 03 S pnd a*-
Cic.# '7359 t(
'- 4--Pg0 1CO
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717- 243 -9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS TN 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.Dhfa.org/consumers/homeowners/real.aW,—X
Y .
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: hllp://www.philadelphiafed.ora/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- 866413 -2311 or via email
at homeretentiongkmllawgrou com Call Seth at 215 -825 -6329 or fax 215- 825 -6429. The figure and /or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 21.5- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 119950FC.
Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GREEN TREE CONSUMER DISCOUNT COMPANY, 7360 S. Kyrene Road, Mail Stop: T-
208 Tempe, AZ 85283.
2. The name(s) and address(es) of the Defendant(s) is /are JACK V. COBLE JR, 208 4th Street,
Summerdale, PA 17093, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises
hereinafter described.
3. On April 14, 2005 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONICS REGISTRATION SYSTEMS, SOLEY AS NOMINEE
FOR MEMBERS 1 ST FEDERAL CREDIT UNION, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County on April 18, 2005 as Book 1903 Page 4072. The mortgage
has been assigned to: GREEN TREE CONSUMER DISCOUNT COMPANY by assignment of
Mortgage recorded on June 20, 2006 as Instrument # Instrument #201117273. The Mortgage and
Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance
with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation
to attach documents to pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ( "Property ").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for November 01, 2012 and each month thereafter and by the terms of the Mortgage, upon default in
such payments for a period of one month or more, the entire principal balance and all interest due and
other charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
PrincipalBalance ............................... ............................... .....................$70,954.15
Interest from 10/01/2012 through 03/27/2012 at 6.5000 % . ......................$1,866.00
Per Diem interest rate at $12.64
LateCharges ............................................ ............................... ....................$101.12
Monthly Escrow amount $174.38
NSFFees ................................................ ............................... .........................$40.00
Escrow........................................... ............................... .......... $191.56
.....................
Reasonable Attorney's Fee .................. ............................... ............ ..........$1,650.00
$74,802.83
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.
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 $74,802.83,
together with interest at the rate of $1.2.64, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and
Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale
of the Property.
By:
KML LAW GROUP
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. Gornall Pa. ID 92382
Alyk L. Oflazian Pa. ID 312912
/ S c Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
VERIFICATION
e 1 _ , as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date:]
#119950FC - JACK V. COBLE JR
208 4th Street Summerdale, PA 17093
E.X,,hibitA
ALL THOSE CERTAIN three tracts, pieces or parcels of land situate in East Pennsboro
Township, Cumberland County, Pennsylvania, bounded and described as follows:
TRACT l:
BEGINNING at the southeast corner of Fourth and Wayne Streets, on the hereinafter mentioned
Plan; thence eastwardly along the southern line of Wayne Street, 160 feet to a 16 foot wide alley;
thence southwardly along the western line of said alley 41 feet, more or less, to the northeast
comer of Lot No. 101; thence westwardly along the northern line of Lot No. 101, a distance of
160 feet to Fourth Street; thence northwardly along the eastern line of Fourth Street, a distance of
41 feet, more or less, to a point, the place of BEGINNING.
BEING Lot No. 102, Section 'A', in the Plan of Summerdale, as recorded in the Office of the
Recorder of Deeds in and for said County of Cumberland in Plan Book 1, Page 44, and being
improved with a two -story frame dwelling, formerly known as 119 Fourth Street, now known as
208 Fourth Street, Summerdale, Pennsylvania.
TRACT 2:
BOUNDED on the west by Fourth Street; on the North by Lot No. 102, on the East by an alley
and on the South by Lot No. 100, having a frontage of 30 feet on Fourth Street and a depth of
160 feet.
i
BEING Lot No. 101, Block 'A' in the Plan of Summerdale, as recorded in the Office of the i
Recorder of Deeds aforesaid in Plan Book 1, Page 44. I
i
TRACT 3:
BOUNDED on the West by Fourth Street, on the North by Lot No. 101, on the East by an alley
and on the South by Lot No. 99, having a frontage of 30 feet on Fourth Street and a depth of 160
feet.
BEING Lot No. 100, Block 'A' in the Plan of Summerdale as recorded in the Office of the
Recorder of Deeds aforesaid in Plan Book 1, Page 44.
j"
BEING the same premises which Clarence G. Blaine and Louree B. Blaine, his wife, Thomas G.
Blaine, individually nd as
y guardian for his minor children, and Sean Blaine, his wife, and Nancy
K. Otstot, individually and as guardian for her minor children, and Ivan Otstot, her husband, by
Deed dated February 27, 1968 and recorded in Cumberland County Deed Book'B', Volume 30, ['
Page 566, and re- recorded in Cumberland County Deed Book R', Volume 22, Page 562, granted
and conveyed unto Clarence G. Blaine and Louree B. Blaine, his wife. Clarence G. Blaine died
March 12, I982, whereupon sole title to said premises became vested in Louree B. Blaine by
virtue of the doctrine of survivorship incident to tenancies by the entireties, Grantor herein.
Exhibit
*Exhibit has been redacted to remove all personally identifiable information or non public information
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
F
F
Date: 3/29/2013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortp_aec 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 MORTGAGE ASSISTANCE PROGRAM (HEMAP) may -_
be able to help to save your home. This Notice explains how the prolzram works. To see
if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with
you when you meet with the Counseling Agency. -
The name, address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions you may call the >:
Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397. (Persons with impaired
hearing can call (717) 780-18691.
This Notice contains important legal information. If you have any questions, e
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact any attorney in your area. The local bar association
may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PIJES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTFNTDO DE ESTA NOTIFICATION OBTENGA UNA
TRADUCCION 1MMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUIVIERO MENCIONADO ARRIBA.
PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM' EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERF,CHO A REDIMIR SU
HIPOTECA.
i
Date: 3/29/2013
HOMEOWNER'S NAME(S): JACK V. COBLE JR
PROPERTY ADDRESS: 208 4th Street, Summerdale, PA 17093
LOAN ACCT. NO.: M115
ORIGINAL LENDER: MORTGAGE ELECTRONICS REGISTRATION SYSTEMS, SOLEY
AS NOMINEE FOR MEMBERS 1ST FEDERAL CREDIT UNION
CURRENT LENDER/SERVICER: GREEN TREE CONSUMER DISCOUNT COMPANY /
GREEN TREE SERVICING
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN (331 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. 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.
2
- - - -- - -- -- ......... ......... - - - -- ......... .
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) You have the right to apply for financial assistance from the Homeowner's Emergency
Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your
application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face
meeting with the counseling agency.
YOUSHOULD FILEA HEMAPAPPLICATION SOONAS POSSIBLE IF YOU
HA VE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK
DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF
THAT MEETING, THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROM
STAR TING A FORECLOSURE A GAINST YO 11k PROPERTY, AS EXPLAINED ABOVE, IN
THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE."
YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE
T I M E P E R I O D S . A L A TE APPLICATION WILL NOT PREVENT THE LENDER FROM
STARTING A FORECLOSUREACTION, BUT IF YOUR APPLICATIONIS EVENTUALLY
APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
1�� YOU ARE CTRREI�IT`LYPROT�ECTED BY ,THE FT�FVG�(lF �i F�TTiI.ON k
-
B�RUPTG PART C)F!TI3J1S l�fi(]1'ICE IS EOY2 fk �r'
O TIOI UIiP(3 ES (3�NLY. ND 81EI0 IIIrD - NOT BE ONSIDI�R)N,D AS 1
A"�`I`EMP� TO �O LZ��T�',HE - DES"T (IfyouTrave filell �a�kruptcy you can stilt�Pply
lFb meX "1R9y, 71 - e ss�stante J,g; . , .. •_:?.. _._; i `# '
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: 208 4th Street, Summerdale, PA 1709315 SERIOUSLY IN DEFAULT because:
3
't'
A- YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 12/01/2012 thru 3/29/2013
(2 mos. at $680.08 /month) $1,360.16
(1 mos. at $671.13/hnonth) $671.13
(1 mos. at $720.04 /month) $720.04
(b) Late charges $101.12
(c) Other charges; Escrow, Inspec., NSF Checks:
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $2,852.45
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $2,852.45 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:
GREEN TREE LLC
PO Box 94710
Palatine, IL 60094 -4710
i
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 brings 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. f
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
4
i ... .:... .... .. _ _.._..- .._..-
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.
You may do so by paying the total amount then past due, plus any late or other charges then due.
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected I:
with the Sheriff s Sale as specified in writing by the tender 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
Sheriff's Sale of the mortgaged property could be held would be approximately four (4) to six (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. F
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: GREEN TREE LLC
Address: PO Box 94710
Palatine, IL 600944710
Pbone Number: 800 - 643 -0202
G
Fax Number: 866 -210 -6192
Contact Person: Collection Department
EFFECT OF SHERIF'F'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may 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.
s
{ ... .. .......... ______. .. ...... .......... ........ .. .. ..... ....... ._____.. .__.. _...
I
I
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.)
x 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.
i
i
i
6
- -- - - - -- ........
90 .
Comprehensive Housing
s -_ Counseling Agencies
Agencias de Consejo al Cliente para Vivienda
Cumberland County
*CCCS of Western PA - York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227 / 888.511.2227
www.cccspa.ora
Community Action Commission - Capital Region F
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactricoungl.ora
I
Harrisburg Fair Housing Council j
2100 N 6th St
Harrisburg PA 17110
717.238.9540 t
Housing & Redevelopment Authority - Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907 / 717.249.0789
www.cchra.com
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102 s
717.234.6616
www.ruralisc.org /oathslone oa.htm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www adamscha_oro
I I I
f I
1
11
NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you.
Report last updated: 4/30/2012 9:03:04 AM Page 1 of 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
r �
C
GREEN TREE CONSUMER DISCOUNT COMPANY
Plaintiff _ n't w'".
p(`T (p cr, r c2w
VS. Case No. � �. �.�.,
JACK V. COBLE JR VI `cam°
Defendant(s) c ���
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSUff
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able
to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services
at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal
representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet
with that legal representative within twenty (20) days of the appointment date. During that meeting, you must
provide the legal representative with all requested financial information so that a loan resolution proposal can be
prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached
hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which
must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so
and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender
in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for
a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a
legal representative. However, you must provide your lawyer with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the
format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court,
which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully ubmitted.
(Signature of Counse Plaintiff)
Date
t
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete-your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working vAth your
Please provide the .following information to the best of your knowledge:
(:t_J.ST0Mtl1/PIZl1N1Al?Y APPLICANT
Borrower name(s):
Property Address:
City: _ -- State: Zip:
Is the property for sale? Yes E_J No ❑ Listing date Price: S
Realtor Name: Realtor Phone-
Borrower Occupied? Yes No
Mailing Address (if different):
City: Mate: Zip:
Phone Numbers: Rome: 0ffi ft:
Cell: Other:
Email:
# of people in household.: How long?
Mailing Address;
City: - State: Zip:
Phone Numbers: Home: Office:
Cell: Other: T
E-mail; T T
# ofpeople in household:. How long?
1A 0
7 0 T1
First Mortgage Lender;
Type of Loan:
Loan Number: -- Bate You Closed Your Loan:
Second Mortgage Lender: -
Type of Loan:
Loan Number:
Total Mortgage: Payments Amount: $ 'Included 'Faxes & Insurance:
Date of bast Payment:
Primary Reason for Default:
is the loan in Bankruptcy? Yes E] No [3 -
S
If yes, provide names, location of court, case number Vic. attorney:
Assets Antognt Owed: Va.kL
Rome: $ ---- - - ---- $
Other Real l -state: $
Retirement Funds; $ $ --
Investments: $ —
Checking: $ $
Savings: $ $
Other: $ $
Automobileril Model: Year:
Am ount owed: Value:
Automobile #F2 Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats motorcycles) Model-
Year Amount owed: Value -
Monthly Income
Name of Employers;
1.
2.
3.
Additional Income Description (not wages):
I. -- - monthly amount:
2a monthly amount:
Borrower Pay Days: - - -- -_ -- - _ _ _ Co- Borrower Pay Trays:
Monthly ExgLr ses: (Please only include expenses you are currently paying)
EXFEIiISId AMOUNT - EXPENSE AMOUNT Mo a e Food
2' Mortgage Utilities
Car P8 -ens - Condo/Nei . Fees
Auto Insurance
Med. not covered
Auto fuel /re irs Other pro payment
Install. Loan Payment Cable TV
Child Su rt/Alim, _ -_ SELnding Mone
Da /Child Care/Tuit, -
(lther Ex eases
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
yes 0 No [� J
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Ofllce): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(14EMAP) assistance?
Yes F� No
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loam servicing company
to resolve your delinquency?
Yes El No ❑
If yes please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lend'er's loan
servicing company:
Lender's Contact (Larne): Phone:
Servicing Company (Name):
Contact: Phone:
- - e W , authorize th ab
named to usetrefer this information to my lender /serkicer for the sole-
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
1� Past 2 bank statements
�f Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the m ar
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny,R Anderson HLEO—U 't'lUL-
A
Sheriffafurattrrr1b ! §
pY0% C�§ QThOiCl 'i "'�
Jody S Smith
Chief Deputy �44
Richard W Stewart �' r
Solicitor OFF;C OFT E SWE frr CU MS HNS LVA�A�'�
Green Tree Consumer Discount Co Case Number
vs.
2013-2468
Jack V. Coble, Jr.
SHERIFF'S RETURN OF SERVICE
05/20/2013 07:44 PM- Deputy Ryan Burgett, 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: Jack
V. Coble, Jr. at 208 4th Street, East Pennsboro Township, Summerdale, PA 17093.
RYAN BURGETT, D
SHERIFF COST: $46.08 SO ANSWERS,
May 24, 2013 RbNW R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoff,Inc.
In the Court of Common Pleas of Cumberland County
GREEN TREE CONSUMER DISCOUNT COMPANY
7360 S.Kyrene Road
Mail Stop: T-208
Tempe,AZ 85283 No. 13-2468
Plaintiff
VS.
JACK V.COBLE JR
(Mortgagor(s)and Record Owner(s) -"
208 4th Street
Summerdale,PA 17093
Defendant(s)
PRAECIPE FOR JUDGMENT ' "
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT)4EIW
OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TH"U&-OSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against JACK V. COBLE JR by default for want of an Answer.
Assess damages as follows:
$85,811.23
Debt
Interest from 11/13/2013 to
Date of Sale per diem at$12.64
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the
filing of this praecipe.A copy of the notice is attached.R.C.P.2 7.
By:
KML LAW GROUP,40eelli'e9
_Michael McKeever Pa 56129
_Jay E.Kivitz Pa.ID 26769
_Lisa Lee Pa.ID 78020
_Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puled Pa.ID 27615 Q 01
_Joshua I.Goldman Pa.205047
_Jill P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plaintiff
AND NOW �V S .x Sct,1�a.�-art'F'G'W�L0 313TTI
�t9 t3 ,Judgment is entered in favor of
GREEN TREE CONSUMER DISCOUNT COMPANY and against JACK V. COBL'1,JR byfault fop w nt of an Answe r
and damages assessed in the sum of$85,811.23 as per the above certification. =
Proth tary
Rule of Civil Procedure No.236—Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY,PENNSYLVANIA
CIVIL ACTION-LAW
GREEN TREE CONSUMER DISCOUNT COMPANY
7360 S.Kyrene Road
Mail Stop: T-208
Tempe,AZ 85283
Plaintiff
No. 13-2468
vs.
JACK V. COBLE JR
(Mortgagors and Record Owner(s)
208 4th Street
Summerdale,PA 17093
Defendant(s)
THIS LAW 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.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
David D.Buell
Prothonotary of Cumberland County
1 Courthouse S
Carlisle,PA 1
Prothonotary
By:
Ik P13
If you have any questions concerning the above,please contact:
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
119950FC
THIS LAW 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.
DATE OF THIS NOTICE: October 22,2013
TO:
JACK V.COBLE JR
COBLE JR,JACK
208 4th Street
Summerdale,PA 17093
In the Court of
GREEN TREE CONSUMER DISCOUNT COMPANY Common Pleas
7360 S.Kyrene Road of Cumberland County
Mail Stop:T-208
Tempe,AZ 85283 Plaintiff CIVIL ACTION-LAW
vs.
JACK V.COBLE JR Action of
(Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure
208 4th Street
Summerdale_PA 17093 No,--13-2468
Defendant(s)
TO: JACK V.COBLE JR
208 4th Street
Summerdale,PA 17093
IMPORTANT NOTICE
YOU ARE J.N 1)I-FAUJ.T BECAUSE.YOU HAVE FAILED TO ENTER A WRIT ER 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 W1111IN TEN(10)DAYS FROM THE DATE OF THIS
NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU W1111OUT A 11FARING AND YOU MAY LOSE YOUR PROPERTY OR OTHFR IMPORTANT RIGlrIS. YOU
SHOULD TAKE.11IIS PAPF.R TO YOUR JAWYER 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)TIRE A LAWYER,1'111S OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY 0I11R U.-GAL SERVICES TO R IGIBLE PFRSONS AT A REDUCED FEE OR NO FEE..
CUMBERLAND COUNTY BAR ASSOCIATION
2labe ty Avenue
Carlisle,PA 17013
LEGAL SERVICES 1NC
8 Lvine Row
Carlisle,PA 17013
717-243-9400
By:. _
KML LAW GR P,P.C.
Michad McKeever Pa.ID 56129
Lisa I.ee Ia.ID 78020
_Kristian Martha Pa.ID 61850
_David Fein Pa.ID 82628
_Thomas Puleo Pa.ID 27615
(�All P.Jcaldns Pa.ID 306588
Alyk L O}laaiaa Pa.In 312912
_Salvatore Filippella Pa_ID 313897
_Michael J.Coskey Pa W 311835
2t5d27-1322
Allmneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
GREEN TREE CONSUMER DISCOUNT COMPANY
Plaintiff
vs.
JACK V.COBLE JR NO. 13-2468
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter,does hereby state to the best of his/her information and belief,as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmde.osd.mil/appj/scra/scraHome.do)
for the following individual(s): JACK V. COBLE JR, has a last known residence of 208 4th Street,
Summerdale, PA 17093. The following information was used to search the DMDC (check all that
apply):
X_Last Name
• First Name
• Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A.4904 relating to unsworn falsification to authorities.
Date /13/t3 By:
�(
Y
KML LAW GROUP,P.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
Jill P.Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Attorneys for Plaintiff
Results as of:Nov-12-2013 12:28:23
Department of Defense Manpower Data Center
SCRA 3.0
Staff Repot`C
Pursuant to Servicemembers Civil Relief Act
Last Name: COBLE
First Name: JACK
Middle Name: V.
Active Duty Status As Of: Nov-12-2013
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 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 Data Order Notification End Date status Service Component
NA -NA No NA
This response reflects whether the individual or hislher 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.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
010, 1 '
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:hftp://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(9 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 Nary 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: 05AE15297007YAO
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106
215-627-1322
Attorney for Plaintiff
GREEN TREE CONSUMER DISCOUNT COMPANY
7360 S.Kyrene Road IN THE COURT OF COMMON PLEAS
Mail Stop: T-208
Tempe,AZ 85283 of Cumberland County
Plaintiff
VS.
CIVIL ACTION LAW
JACK V. COBLE JR
(Mortgagor(s)and Record owner(s)
208 4th Street ACTION OF MORTGAGE FORECLOSURE
Summerdale,PA 17093
Defendant(s)
No. 13-2468
ORDER FOR JUDGMENT
Please enter Judgment in favor of GREEN TREE CONSUMER DISCOUNT COMPANY,and against JACK V.
COBLE JR for failure to file an Answer in the above action within(20)days(or sixty(60)days if defendant is the United
States of America)from the date of service of the Complaint, in the sum of$85,811.23.
By:
KML LAW GRO P.C.
Michael McKeever P .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.205047
Jill P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plainiff g p
2 SD�w'jorf— F—ceece �� -
I hereby certify that the above names are correct and that the precise resid ddr ess of the jud ment creditor is
GREEN TREE CONSUMER DISCOUNT COMPANY 7360 S.Kyrene Road Mail Stop: T-208 Tempe,AZ 85283 and that
the name(s)and last known address(es)of the Defendant(s)is/are JACK V.COBLE JR,208 4th Street Summerdale,PA
17093; ,
By: 5f
KML LAW GROUP,
Michael McKeever Pa.V6129
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.205047
Jill P.Jenkins Pa.ID 306588
Andrew F. Gornall Pa.ID 92382
Attorneys for Plaintiff
X 5al� a� �� owN
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $70,954.15
Interest from 10/01/2012 through $9,386.80
11/12/2013
Reasonable Attorney's Fee $1,650.00
Late Charges $101.12
Escrow Payments Due 20 X$174.38 $3,487.60
NSF Fees $40.00
Escrow $191.56
$85,811.23
2 Koc'
By.
KML LAW GROUP,P.
Michael McKeever Pa.ID 6 29
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.205047
Jill P.Jenkins Pa.ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
n x S�1 v zFDIV- � eabove.
AND NOW,this day of !V 2013 damages are assessed
Pro y
13-2468/119950FC
Willi 11010M 11
PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street l b
Philadelphia,PA 19106 I J f4i 3't tai LA N D COUNTY
215-627-1322 PENNSYL VA.NIA
Attorney for Plaintiff
GREEN TREE CONSUMER DISCOUNT COMPANY
7360 S.Kyrene Road
Mail Stop: T-208 IN THE COURT OF COMMON PLEAS
Tempe,AZ 85283
Plaintiff of Cumberland County
vs.
CIVIL ACTION—LAW
JACK V.COBLE JR
Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE
208 4th Street
Summerdale,PA 17093
Defendant(s) No. 13-2468
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$85,811.23
Interest from
11/13/2013 to Date of
Sale per diem at
$12.64
S� a (Costs to be added)
L or
(? , S t) it By:
^' KML LAW GROUP
Michael McKeever P . 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.205047
Jill P.Jenkins Pa. ID 306588
S Andrew F.Gornall Pa.ID 92382
S� Attorneys for Plaintiff
Ito
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ALL THOSE CERTAIN three tracts, pieces or parcels of land situate in East Pennsboro
Township, Cumberland County, Pennsylvania, bounded and described as follows:
TRACT 1:
BEGINNING at the southeast corner of Fourth and Wayne Streets, on the hereinafter
mentioned Plan; thence eastwardly along the southern line of Wayne Street, 160 feet to a
16 foot wide alley; thence southwardly along the western line of said alley 41 feet, more
or less, to the northeast corner of Lot No. 101; thence westwardly along the northern line
of Lot No. 101, a distance of 160 feet to Fourth Street; thence northwardly along the
eastern line of Fourth Street, a distance of 41 feet, more or less,to a point, the place of
BEGINNING.
BEING Lot No. 102, Section `A', in the Plan of Summerdale, as recorded in the Office of
the Recorder of Deeds in and for said County of Cumberland in Plan Book 1, Page 44,
and being improved with a two-story frame dwelling, formerly known as 119 Fourth
Street,now known as 208 Fourth Street, Summerdale, Pennsylvania.
TRACT 2:
BOUNDED on the west by Fourth Street; on the North by Lot No. 102, on the East by an
alley and on the South by Lot No. 100, having a frontage of 30 feet on Fourth Street and
a depth of 160 feet.
BEING Lot No. 101, Block `A' in the Plan of Summerdale, as recorded in the Office of
the Recorder of Deeds aforesaid in Plan Book 1, Page 44.
TRACT 3:
BOUNDED on the West by Fourth Street, on the North by Lot No. 101, on the East by an
alley and on the South by Lot No. 99, having a frontage of 30 feet on Fourth Street and a
depth of 160 feet.
BEING Lot No. 100, Block `A' in the Plan of Summerdale as recorded in the Office of
the Recorder of Deeds aforesaid in Plan Book 1, Page 44.
IMPROVEMENTS consist of a residential dwelling.
MUNICIPALITY East Pennsboro Township
BEING PREMISES: 208 4th Street Summerdale PA 17093
SOLD as the property of Jack V. Coble,Jr.
TAX PARCEL#09-12-2994-049
BEING the same premises which Louree B. Blaine, widow, by deed dated 4/14/2005 and
recorded 4/18/2005 in Cumberland County in Deed Book Volume 268 at Page 2170
granted and conveyed unto Jack V. Coble,Jr.,single man.
4i
KML Law Group,P.C.
Suite 5000—BNY Independence Center )- -
701 Market Street � r (j) `tea„ ,
Philadelphia,PA 19106
215-627-1322 l } r"- � ° '°
Attorney for Plaintiff „
GREEN TREE CONSUMER DISCOUNT L-I'Vi6YLVANIA
COMPANY IN THE COURT OF COMMON PLEAS
7360 S.Kyrene Road
Mail Stop: T-208 of Cumberland County
Tempe,AZ 85283
Plaintiff
vs. CIVIL ACTION-LAW
JACK V. COBLE JR
(Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE
208 4th Street
Summerdale, PA 17093
Defendant(s)
No. 13-2468
AFFIDAVIT PURSUANT TO RULE 3129
GREEN TREE CONSUMER DISCOUNT COMPANY,Plaintiff in the above action,by counsel,KML Law Group,
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:
208 4th Street
Summerdale,PA 17093
1.Name and address of Owner(s)or Reputed Owner(s):
JACK V. COBLE JR
208 4th Street
Summerdale,PA 17093
2.Name and address of Defendant(s)in the judgment:
JACK V.COBLE JR
208 4th Street
Summerdale,PA 17093
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg.-Room 432
P.O.Box 2675
Harrisburg,PA 17105-2675
{
4.Name and address of the last recorded holder of every mortgage of record:
MEMBERS 1 ST CREDIT UNION
5000 Louise Drive
Mechanicsburg,PA 17055
5.Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
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.
TENANTS/OCCUPANTS
208 4TH Street
Summerdale,PA 17093
1 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. Section 4904 relating to unsworn
falsification to authorities.
DATED:
By:
KML LAW GROUP,
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.205047
Jill P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plaintiff
X Sri VA-f f
13-2468
r
KML Law Group,P.C. L
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106 ,
(215)627-1322
Attorney for Plaintiff �" E ti LAND C Q W j`1'
F of
GREEN TREE CONSUMER DISCOUNT
COMPANY IN THE COURT OF COMMON PLEAS
7360 S.Kyrene Road
Mail Stop: T-208 of Cumberland County
Tempe,AZ 85283
Plaintiff CIVIL ACTION-LAW
vs.
ACTION OF MORTGAGE
JACK V. COBLE JR FORECLOSURE
Mortgagor(s)and Record Owner(s)
208 4th Street
Summerdale,PA 17093
Docket No. 13-2468
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: COBLE JR,JACK
JACK V. COBLE JR
208 4th Street
Summerdale,PA 17093
Your house at 208 4th Street,Summerdale,PA 17093 is scheduled to be sold at Sheriffs Sale on
Wednesday,March 12,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$85,811.23 obtained by GREEN TREE CONSUMER DISCOUNT COMPANY
against you.
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 GREEN TREE CONSUMER DISCOUNT COMPANY,
the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must
pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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.
13-2468
4. 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 below 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 NOT TAKE PLACE.
1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a 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 thirty(30)days from the
date of the Sheriffs 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 the schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orp-/foreclosure/
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
13-2468
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client)has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention gkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
119950FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
KML Law Group,P.C.
:r E
Suite 5000—BNY Independence Center l: ;
701 Market Street 2 [3 N1 0',
Philadelphia,PA 19106 "1 lu' 16
215-627-1322 ""'12-ER,LA D co ``pl
Attorney for Plaintiff PE104S Y
GREEN TREE CONSUMER DISCOUNT COMPANY
7360 S.Kyrene Road
Mail Stop: T-208 IN THE COURT OF
Tempe,AZ 85283 COMMON PLEAS
Plaintiff
vs. of Cumberland County
JACK V. COBLE JR CIVIL ACTION-LAW
Mortgagor(s)and Record Owner(s)
208 4th Street ACTION OF
Summerdale, PA 17093 MORTGAGE FORECLOSURE
Defendant(s)
NO. 13-2468
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By. .
KML LAW GROUP,
Michael McKeever Pa. 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.205047
Jill P.Jenkins Pa.ID 306588
Andrew F. Gornall Pa.ID 92382
Attorneys for Plaintiff
7�"'["U�(o 3 3"It
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 13-2468 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GREEN TREE CONSUMER DISCOUNT COMPANY
Plaintiff(s)
From JACK V.COBLE JR
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $85,811.23 L.L.: $.50
Interest FROM 11/13/2013 TO DATE OF SALE PER DIEM AT$12.64
Atty's Comm: Due Prothy: $2.25
Atty Paid: $194.83 Other Costs:
Plaintiff Paid:
Date: 11/15/13
David D. Buell, Prothonota
(Seal)
Deputy
REQUESTING PARTY:
Name: SALVATORE FILIPPELLO,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 313897
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _ _,,_ .
Sheriff `' L-
� rtt psi (m G,r oho
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor o F E. CUMBERLAND COUNTY
PENNSYLVANIA
Green Tree Consumer Discount Co
Case Number
vs.
Jack V. Coble, Jr. 2013-2468
SHERIFF'S RETURN OF SERVICE
01/09/2014 10:20 AM -Deputy Jamie DiMartle, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 208 4th Street, East Pennsboro-Township,
Summerdale, PA 17093, Cumberland County.
03/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1,017.44 SO ANSWERS,
March 05, 2014 RONR ANDERSON, SHERIFF
as-- P" . eo .
. sue 12- POI
43+ a,a
3.0.174(2
On November 19, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA,
Known and numbered as, 208 4th Street,
Summerdale, as Exhibit "A" filed with this writ and by
this Reference incorporated herein.
Date: November 19, 2013
By:
;\
Real Estate Coordinator
SO :OIty 8IAQNEI01
LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14
Writ No. 2013-2468 Civil Term
Green Tree Consumer Discount Co.
vs.
Jack V. Coble,Jr.
Atty.: Michael McKeever
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 208 4th
Street, Summerdale,PA 17093.
SOLD as the property of JACK V.
COBLE JR.
TAX PARCEL#09-12-2994-049.
24
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 24, January 31, and February 7, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
r
tr...---- C'I7-
Lisa Marie Coyne, Editor
SWO TO AND SUBSCRIBED before me this
7 day ay of February, 2014
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public.
CARLISLE BOROUGH,CUMBERLAND COUNTY,
My Commission Expires Apr 20,2014
The Patriot-News Co. r
' 2020 Technology Pkwy he atriotews
Suite 300
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
•
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
01/19/14
2013-2468 Civil Term 01/26/14
Green'free Consumer
Discount Co 02/02/14
Vs
__deck V.Coble,Jr.
Atty: Michael McKeever • •
IMPROVEMENTS consist of a
residential dwelling. Sworn to an a subscribed before me th. 18 day of February, 2014 A.D.
BEING PREMISES:208 4th Street
Summerdale,PA 17093
SOLD as the property'COBLEJR of TACK V. _1` I �'_�•
TAX PARCEL#09-12-2994049 '• ary 'ublic
CL?lIrCwwEALTH OF PENNSYt VANIA
1'-t.P[im Cc,,:ty
gtyt urr,vSQrs fq...c.V.._21016
MEME.ER,PENNSYLVANIA ASSC CIAT` NOTARIES
KML LAW GROUP, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
'JR
rlfrr fl....
ti 0 T f i C1,a ]�w
!'(�f ER X113:
PEN'S Y(� CQUfY', �r
GREEN TREE CONSUMER DISCOUNT
COMPANY
7360 S. Kyrene Road
Mail Stop: T-208
Tempe, AZ 85283
Plaintiff
vs.
JACK V. COBLE JR
(Mortgagor(s) and Record owner(s))
208 4th Street
Summerdale, PA 17093
TO THE PROTHONOTARY:
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
PRAECIPE TO VACATE JUDGMENT
Kindly vacate the judgment upon payment of your costs only.
By:
KML LAW GRO ' , P.C.
Michael Mc 4eeve Pa. ID 56129
Jay E. Kivitz ; . D 26769
Lisa Lee Pa. ID 78020
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello, Attorney ID 313897
Attorneys for Plaintiff
J1ei" P7C& e 31 buo
No. 13-2468
11'
�7(sG
?q613 J
CKdk 3oS96a
KML LAW GROUP, P.C.
SUITE 5000 — BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GREEN TREE CONSUMER DISCOUNT
COMPANY
Plaintiff
vs.
JACK V. COBLE JR
(Mortgagor(s) and Record Owner(s))
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 13-2468
CERTIFICATE OF SERVICE
Angela M. Smith , hereby certifies that he/she did serve true and correct copies of
Praecipe to Vacate Judgment and all supporting
/papers attached hereto upon Defendant, by first
class mail, postage pre -paid, on 1 / ! .
JACK V. COBLE JR
208 4th Street
Summerdale, PA 17093
By:
KML LAWROUP, P.C.
Angela M. Smith , Legal Assistant
asmith@kmllawgroup.com
215-825-6325 (Direct Phone)
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
204
COI
HE
6 pA,
GREEN TREE CONSUMER DISCOUNT
COMPANY
7360 S. Kyrene Road
Mail Stop: T-208
Tempe, AZ85283
Plaintiff
vs.
JACK V. COBLE JR
(Mortgagor(s) and Record owner(s))
208 4th Street
Summerdale, PA 17093
Defendant(s)
" O7
NA'S
)'i NT ,,,
A'
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 13-2468
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
KML LAW GROUP, P.C.
F/K/A GOLDBECK McCAFFERTY & McKEEVER
By:
ichael ver £a. ID 56129
Jay E. Kivi ID .769
Lisa Lee Pa. • 78020
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
jSalvatore Filippello, Pa. ID 313897
Jennifer Lynn Frechie, Pa. ID 316160
Attorneys for Plaintiff
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
GREEN TREE CONSUMER DISCOUNT
COMPANY
Plaintiff
vs.
JACK V. COBLE JR
(Mortgagor(s) and Record Owner(s))
Defendant(s)
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
No. 13-2468
CERTIFICATE OF SERVICE
Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe
to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class
mail, postage pre -paid, on
JACK V. COBLE JR
208 4th Street
Summerdale, PA 17093
KML LAW GROUP, P.C.
F/K/A GOLIIBECK McCAFFE :Y Y &
By:
An
ela M. Smith , Legal Assistant
asmith@knillawgroup.com
215-825-6325 (Direct Phone)
KEEVER