HomeMy WebLinkAbout13-3056 Supreme Court of Pennsylvania
' Court om'on Pleas
� N% r� . For Prothonotary Use Only:
Civill"Covef; Sheet
CUMBEREANDt County '
Docket No: � 1
%1L'*1"__*J9 _� �,
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as req uired by law or rules of court.
S Commencement of Action:
Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff s Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: KATHLEEN L. ZIMPLEMAN
T
I Are money damages requested? El Yes 9 No Dollar Amount Requested: 11 within arbitration limits
0 (Check one) Z outside arbitration limits
N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes ❑x No
A Name of Plaintiff /Appellant's Attorney: Meredith Wooters Esq. , Id. No.307207, Phelan Hallinan, LLP
❑ 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 includ7Judgments CIVIL APPEALS
El Intentional ❑ Buyer Plaintiff Administrative Agencies
• Malicious Prosecution ❑ Debt Collection: Credit ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
• Premises Liability ❑ Statutory Appeal: Other
• Product Liability (does not
S include mass tort) ❑ Employment Dispute:
• Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
0 ❑ Asbestos
N ❑ Tobacco
• Toxic Tort - DES
• Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
• Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
Z Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
• Dental ❑ Partition ❑ Replevin
• Legal ❑ Quiet Title ❑ Other:
❑ Other:
• Medical
• Other Professional:
Pa.R.C.P, 205.5 Updated 01 /01/2011
OF TF E FIL FL)
PRO N6,� �-
?013 , t oy 29 41'� 10: 49
CUtIBERt AND CCG'� !
P4 t *NSYLVAtjf
PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF
Meredith Wooters, Esq., Id. No.307207
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215 -563 -7000
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715 n '
Plaintiff, NO.: s a s V
vs.
KATHLEEN L. ZIMPLEMAN
DAVID W. ZIMPLEMAN
632 ALLEN STREET
NEW CUMBERLAND, PA 17070 -1826
Defendants.
CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE
And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan, LLP
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff').
04 /n � 4 / 7 Y
Cl� 1213
062 -PA -V3 CR 911 b I
2. The Defendants, KATHLEEN L. ZIMPLEMAN and DAVID W. ZIMPLEMAN,
are individuals whose last known address are 632 ALLEN STREET, NEW CUMBERLAND, PA
17070 -1826.
3. WELLS FARGO BANK, N.A., directly or through an agent, has possession of the
Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the Promissory
Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory
Note is marked Exhibit "A ", attached hereto and made a part hereof.
4. On or about July 31, 2009, KATHLEEN L. ZIMPLEMAN and DAVID W.
ZIMPLEMAN made, executed and delivered to INTEGRITY HOME FUNDING LLC a
Mortgage in the original principal amount of $178,650.00 on the premises described in the legal
description marked Exhibit "B ", attached hereto and made a part hereof. Said Mortgage being
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No.
200929212. The Mortgage is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded August
19, 2009, the mortgage was assigned to WELLS FARGO BANK, NA which Assignment is
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 200929213.
The Assignment is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
6. KATHLEEN L. ZIMPLEMAN and DAVID W. ZIMPLEMAN are record and real
owners of the aforesaid mortgaged premises.
7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due January 1, 2013.
062 -PA -V3
8. As of 05/08/2013, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $ 170,796.31
Interest $ 4,466.43
12/01/2012 THROUGH 05/08/2013
Late Charges $ 531.26
Property Inspections $ 45.00
Escrow Deficit $ 660.69
Suspense Balance $(1,144.54)
TOTAL $ 175,355.15
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania
Law, actually and reasonably incurred by Plaintiff including but not limited to, costs (including
escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file
a motion in the above - captioned action to add such additional sums authorized under the
Mortgage and Pennsylvania Law to the above amount due and owing when incurred
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended
in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s).
10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff
is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to
do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish
such liability.
062 -PA -V3
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $ 175,355.15, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
By: NuA
Date: f au I I Meredith Wooters, Esq., Id. No.307207
1
Attorney for Plaintiff
062 -PA -V3
Exhibit "A"
NOTE
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE
APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS
OR ITS AUTHORIZED AGENT.
JULY 31, 2009 DILLSBURG PENNSYLVANIA
[Daft] [City] [State]
632 ALLEN ST, NEW CUMBERLAND, PA 17070
lProperty Address]
1, BORROWER'S PROMISE TO PAY
in return for a loan that I have received, I promise to pay U.S. $ *****178,650. 00 (this amount is called "Principal'),
plus interest, to the order of the Lender. The Lender is INTEGRITY HOME FUNDING, LLC
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is tailed the "Note Holder."
2. INTEREST
interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of * ** *6.000 %.
The interest rate required by this Section 2 is the rate 1 will pay both before and after any default describcd in Section 6(B)
of this Note.
3, PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the FIRST day of each month beginning onSEPTEMBER 01, 2009 I will
make these payments every month until I have paid all of the principal and interest and any other charges described below that I
may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest
before Principal. If, on AUGUST 01, 2039 ,1 still owe amounts under this Note, I will pay those amounts in full on
that date, which is called the "Maturity Date."
I will make my monthly payments at WELLS FARGO ROME MORTGAGE, P . O . BOX 11701, NEWARK, NJ
071014701 or at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $ * *1, 071.10
4, BORROWER'S RIGHT TO PREPAY
The Borrower shall have the right to prepay at any time, without premium or fee, the entire indebtedness or any part
thereof not less than the amount of one installment, or 5100.00, whichever is less. Any Prepayment in full of the indebtedness
shall be credited on the date received, and no interest may be charged thereafter. Any. partial Prepayment made on other than an
installment due date need not. be credited until the next following installment due date or 30 days aflor such Prepayment,
whichever is earlier.
MULTISTATE FIXED RATE NOTE - Single Family- Fannie MaelFreddle Mac UNIFORM INSTRUMENT
Amended for Veterans Affairs
Form 3200 1101
(00.'5' owl Amended 61% VMP MORTGAGE FORMS - (B(Q521- 7291
PaOe 103
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit and (b) any sums already collected from
me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days
after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 4.000 % of
my overdue payment. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default .
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of-Principal which has not been paid and all
the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described
above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to
be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail io me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first
class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that
different address.
S. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If mare than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Note against each person individually or against all of us together. This means that any one of us may be required to
pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights 'of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
Form 3200 .
Initial
irm ® - SG (0005)
Page 2 of 3 s:
10. ALLONGE TO THIS NOTE
If an allonge providing for payment adjustments or for any other supplemental information is executed by the Borrower
together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of
this Note as if the allonge were a part of-this Note. [Check applicable box]
Graduated Payment Allonge ❑ Other [Specify) ❑ Other (Specify]
11. UINIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the'same date as
this Note, protects the Note Holder from possible losses which might result .if I do not kccp the promises which I make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions arc described as follows_
Regulations (38 C.P.R. Part 36) issued under the Department of Veterans Affairs ( "VA ") Guaranteed Loan
Authority (38 U.S.C. Chapter 37) and in effect on the date of loon closing shall govern the rights, duties and
liabilities of the parties to this loan and any provisions of this Note which are inconsistent with such
regulations are hereby amended and supplemented to conform thereto.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED
(seai) • )
DAVID W ZI -,i'4. . , , ,, -Borrower KATHLEEN L ZIMPL Borrower
(Seal) (Seal)
'Borrower -Borrower
• (Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower -Borrower
[Sign Original Only]
AIRa® lsl �a� a d 3 Porm 3200 1101
PAY TO THE ORDER O N .A.
WILLS FARGO BAN
"GA 0 F
OY trR. VI ppIESIDFNt'
WITHOUT RECOURSE
PAY TO THE ORDER OF
WSLW FARGO BANK, N.A.
BY Am ;1^.
an M. Mills, Vice President
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground situate in New Cumberland Borough, County of
Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the South side of Allen Street (50 feet wide), said point being 1200
feet measured along the South side of Allen Street in an easterly direction from Park Avenue at
corner of land N/F of Curvin Ness, Jr.; thence along said Ness land South 06 degrees 17 minutes
West, a distance of 110 feet to a point; thence South 83 degrees 43 minutes East, a distance of
100 feet to land N/F of George W. Olewin; thence North 06 degrees 17 minutes East, along said
Olewine land a distance of 110 feet to the South side of Allen Street; thence along the South side
of Allen Street North 83 degrees 43 minutes West, a distance of 100 feet to land N/F of Curvin
Ness, Jr., the place of BEGINNING.
UNDER AND SUBJECT, nevertheless, to a five foot utility easement across the rear of the
above described lot.
UNDER AND SUBJECT to restrictions of record.
HAVING THEREON ERECTED a dwelling house known as 632 Allen Street, New
Cumberland, Pennsylvania.
TAX PARCEL NO.: 25 -24 -0811 -452
Filek 321165
PROPERTY ADDRESS: 632 ALLEN STREET, NEW CUMBERLAND, PA 17070 -1826
PARCEL # 25 -24- 0811 -452
File #: 321165
P
VERIFICATION
Linwood Williams , hereby states that hb /she is Vice President Loan
Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that hg /she is
authorized to make this Verification, and verify that the statements made in the foregoing
Civil Action in Mortgage Foreclosure are true and correct to the best oggher
information and belief. The undersigned understands that this statement is made subject
to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Name: Linwood Williams
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 05/15/2013
086 -PA -V2 File #321165
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 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.
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 ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249 -3166
(800) 990 -9108
File #: 321165
FORM 1
r�
IN THE COURT OF COMMON PL�AS� . 1
WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENIA�i V.4NIA F : -
Plaintiff(s) `� v
t.? C
VS. ` n
-r�
; n R
KATHLEEN L. ZIMPLEMAN ; / �� C r". c�
DAVID W. ZIMPLEMAN
Defendants) ivil j
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 2439400
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 pnvide 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 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 wil 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 sothat 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
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date Meredith Wooters, Esq., Id.
No.307207
Attorney for Plaintiff
FORM 2
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 with your counseling agency. Please provide the following information to
the best of your knowledge:
CUSTOM ER/PRI MARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile 42 : Model: Year:
Amount owed: Value:
Other transportation (automobiles boats motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 Id Mortgage Utilities
Car Payment(s) ) Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency: Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above named
to use /refer this information to my lender /servicer 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 counseling 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:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson �' r) Url i '_
Sheriff . ..i -NE Pt20Tt' flG11--
Jody S Smith °d
Chief Deputy - 2013 JUN 14 AM 8: 59
Richard w Stewart CUMBERLAND 000-1 f
Solicitor PENNSYLVANIA
Wells Fargo Bank, N.A. Case Number
vs. 2013-3056
Kathleen L Zimpleman (et al.)
SHERIFF'S RETURN OF SERVICE
05/3112013 03.23 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
'personally'handing a true copy to a person representing themselves to be the Defendant, to wit:
Kathleen L Zimpleman at 632 Allen Street, New Cumberland Borough�New
)Cumberland,,PA 117070.
RONALD HOOVER, DEPUTY
05/31/2013 03:23 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Kathleen L. Zimpleman, wife of defendant, who
accepted as"Adult Person in Charge'for David Zimpleman at 632 Allen Street, New Cumberland
Borough, New Cumberland, PA 17070. �7
RONALD HOOVER, DEP
SHERIFF COST'. $63.21 SO ANSWERS,�/)�/J�
June 04, 2013 RONNY R ANDERSON, SHERIFF
-1- PROTHONOTARY
2013 JUL 16 AM 10: 12
Phelan Hallinan,LLP U M B t R L A N d C O U N TXttorney For Plaintiff
1617 JFK Boulevard,Suite 1400 PENNSYLVANIA
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
WELLS FARGO BANK,N.A. Court of Common Pleas
Plaintiff
Civil Division
vs
CUMBERLAND County
KATHLEEN L.ZIMPLEMAN
DAVID W.ZIMPLEMAN No. 13-3056-CIVIL
Defendant
PRAECIPE
TO THE PROTHONOTARY:
® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑Please mark the above referenced case Settled,Discontinued and Ended.
❑Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
❑Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
❑ Please Vacate the Judgment entered.
Date: PHELAN HALLINAN,LLP
BY=
Meredith Woofers,Esq.,Id.No.307207
Attorney for Plaintiff
PHS#321165
Phelan Hallinan,LLP Attorney for Plaintiff
1.617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
WELLS FARGO BANK,N.A. Court of Common Pleas,
Plaintiff Civil Division
V. CUMBERLAND County
KATHLEEN L.ZIMPLEMAN No. 13-3056-CIVIL
DAVID W.ZIMPLEMAN
Defendant PHS#321165
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s)on the date listed below:
KATHLEEN L. ZIMPLEMAN
DAVID W.ZIMPLEMAN
632 ALLEN STREET
NEW CUMBERLAND,PA 17070-1826
Date: PHELAN HALLINAN,LLP
By:
Meredi Wooters,Esq.,Id.No;307207
Attorney for Plaintiff