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Home My WebLink About13-3065 Supreme Cour-t.of Pennsylvania Cou''ef Co rton Pleas For Prothonot Use On avilyCo�e�, eet �' y� 31 UMBERLAND County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Wells Fargo Bank, N.A. Lead Defendant's Name: Eileen J. Mangan C T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) x outside arbitration limits O N Is this a Class Action Suit? El Yes ® No Is this an MDJ Appeal? E] Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self Represented [Pro Se) Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ 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 j ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include mass tort) El Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: El Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus B ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition E] Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: i Updated 1/1//2011 Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, NO.: l3, 3��5 a�l vs. TYPE OF PLEADING Eileen J. Mangan; CIVIL ACTION - COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Far Bank, N.A. FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. " COUNSEL OF RECORD FOR THIS I HEREBY CERTIFY THAT THE ADDRESS j OF THE PLAINTIFF IS: ZUCKER GOLDBERG & ACKE -XV, L 3476 Stateview Blvd. �*— Ft. Mill, SC 29715 > C Scott A. Dietterick, Esquire IF AND THE DEFENDANT: Pa. I.D. #55650 <Q � 16 Sinclair Road Kimberly A. Bonner, Esquire . Mechanicsburg, PA 17055 -4050 Pa. I.D. #89705 Joel A. Ackerman, Esquire =- �� t Pa I.D. #202729 CERTIFICATE OF LOCATION Ashleigh Levy Marin, Esquire I HEREBY CERTIFY THATTHE LOCATION OF THE REAL ESTATE AFFECTED B HIS LIEN IS Pa I.D. #306799 16 Sinclair Road Mechaniw6um PA 17055-4050 Ralph M. Salvia, Esquire Munici alit : Monro Pa I.D. #202946 Jaime R. Ackerman, Esquirer� Pa I.D. #311032 ATTORNEY F R PLAINTIFF ATTY FILE NO.: XFP 177222 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office @zuckergoldberg.com File No.: XFP- 177222/rbo �= - «y.tJ 77 rr, S CJ u ��s3 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Eileen J. Mangan; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: Eileen J. Mangan; Defendant. AVISO USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demands 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Eileen J. Mangan; Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff ") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Eileen J. Mangan, is an individual whose last known address is 16 Sinclair Road, Mechanicsburg, PA 17055 -4050. 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 December 10, 2009, Eileen J. Mangan, a single person made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $118,030.00 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 Deeds of Cumberland County on December 17, 2009, Instrument #200941817. 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. 6. Eileen J. Mangan, adult individual, as sole owner is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due November 1, 2012. Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 8. As of 05/14/2013 the amount due and owing Plaintiff by Defendants) is as follows: Principal $112,525.46 Interest through 05/14/2013 $3,482.41 Escrow Advance $3,024.18 Suspense Balance ($1,121.91) Late Charges $174.83 Inspection Fees $117.66 Total $118,202.63 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 action does not come under Act 91 of 1983 because the mortgage is FHA insured. 11. 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 Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $118,202.63 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG ERMA , L BY: Dated: ) Scott A. Dietteric , quip/e; PA I.D. #55650 l Kimberly A. Bopher, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP- 177222/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 NOTE FHA Cllsc No. Multistate DECEMBER 10, 2009 lthtel 16 SINCLAIR ROAD, MECHANICSBURG, PA 17055 IPreperly Add—sl 1. PARTIES "Borrower" means each person signing at the end of Ibis Note, and the person's successors and assigns. "Lender" means WELLS FARGO BANK, N.A. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum ofONE HUNDRED EIGHTEEN THOUSAND THIRTY AND 00 /100 Dollars (U.S. S ""'"118,030,00 ),plus interest, to the order of Lender. Interest will he charged on unpaid principal, front the dale ot'disburscincio of the loan proceeds by Lender, at the rue ofFIVE percent ( 5.000 %) per year until the full amount of principal has been paid. 3. PROM ISF TO PAY SECURED Borrower's promise to pay is secured by a mortgage, decd of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Leader Gout losses which might result if Borrower del'uulls under this Note. 4. MANNER OF PAY'NIE.mr (A) Time Borrower shall Make a payment of principal and interest to Lender on the first Clay of each month beginning on FEBRUARY 01 , 2010 . Any principal and interest remaining on the first day o1' JANUARY 2040 , will he duc oo that Jule, which is called the " Maturity Dale." (B) Place payment shall be nadeal WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amotnl or U.S. S * * * * * ** 633.61 This ainoum will be pan of a larger monthly payment required by the Security Instrnnent, that shall be applied III principal, interest and other items in the order described in the Security Instrument. (0) Allonge to this Note for payment adjustments [[ allonge providing for payment adjuslntcntti it execuled by 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 pan of this Note. [Check applicable box] ❑Grtahnatcd payment Allonge OGrowing Equity Allonge 00ibcr [spccilyj 5. BORROWER'S RIGHT 1'O PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in purl, without charge or penally, on the first clay of any month. Lender shall accept prepayment on other clays provided that borrower pays interest on the amount prepaid for the remainder of the month m the extent required by Lcnder and penniued by regulations of the Secretary. If Borrower stakes a partial prep ayment, there will he no changes in the dne date or in the amount of the monthly payment unless Lender agrees in writing to Ihusc changes. ®��R I11.PIMORTGAGE IOrORMS- (600MI- 729ls :Rll' • tlye I F N I 6. BORROWER'S FAILURE •1'O PAY (A) Late Charge for Overdue Payments If Lender hus not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calcndardays after the payment is clue, Lender may collect a late charge in the amount of FOUR percent ( 4.000 %) of the overdue urnounl of each payment. (B) Dcfault If Borrower defaults by toiling to pay in frill any monthly payment. then Lender mry, except as limited by regulations of the Secretary in the case c4 payment defaults, require immediale payment in till of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent delaull. In many circmnslances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when nut permitted by HUD regulations. As used in this Nate. "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above. Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such tees and costs shall bear interest from the elate of disbursement at the same rate us the principal of this Note. 7. WAIVERS Borrower 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 Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts clue have not been paid. It. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must he given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address it' Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will he given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address, 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more 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, surely 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. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) (Seal) - Borrower EILEEN J MAN -B--r (Seal) (Seal) •noaower - Borrower (Seal) (Soul) -Boar. ver - norrowcr (Seal) (Seal) - Borroa'cr - Borrower ® (seam) v.e.2 &2 WITHOUT RECOURSE PAY TO THE ORDER OF WELLS FARGO BANK, N.A. BY A dn In in /lIi•- oan M. Mills, Vice President EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP- 177222 062 -PA -V3 LEGAL DESCRIPTION: LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT CERTAIN PROPERTY SITUATED IN CITY OF MECHANCSBURO IN THE COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA AND BEING DESCRIBED IN A DEED DATED 11122/2006 AND RECORDED 11/3612006 IN BOOK 272 PAGE 676 AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, AND REFERENCED AS FOLLOWS: 16 SINCLAIR ROAD, MECHANICSBURG, PA 17066 PARCEL NO. 22-24-0783-118 ...,_.,...,,.., .�...�.....,. VERIFICATION Steve DeFurio, hereby states tha he/ e is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, tha he he 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 o his er 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. P Name: Steve DeFurio Title: Vice President Loan Documentation Company: Wells Fargo Bank N.A. Date: 05/16/2013 086 -PA -V2 File # 177222 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, /* VS. M'r r" Eileen J. Mangan; Defendant. '� ' 4 r . 5 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 MiclPenn 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. Zucker, Goldberg & Ackerman, LLC XFP- 177222 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & AC N, LLC By: Dated: May 28, 2013 Scott A. Dietterir�I., Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 t� Attorneys for Plaintiff XFP- 177222/cper 200 Sheffield Street, Suite 101 Mountainside, N1 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP- 177222 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 Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY , 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: Zucker, Goldberg & Ackerman, LLC XFP- 177222 Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. 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 " 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 Support /Alim. Spending Money Day /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: Zucker, Goldberg & Ackerman, LLC XFP- 177222 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 or 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 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: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP- 177222 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Eileen J. Mangan; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court - supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties. of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XFP- 177222 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Eileen J. Mangan; Defendant. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 1. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XFP- 177222 resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP- 177222 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,- 'sOKTAt� Sheriff �2- �3 �tStit p 01 ► t 3+ 2 3 Jody S Smith ),*, «f l,4 Chief Deputy �`� �Q�fi�TY Richard W Stewart CUMIBF-4�N SYL yL�IARtA Solicitor 0MCE O� �` r�fjrt� �R'r` Wells Fargo Bank, N.A. Case Number vs. 2013-3065 Eileen J Mangan SHERIFF'S RETURN OF SERVICE 06/14/2013 04:52 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Eileen J Mangan at 16 Sinclair Road, Monroe Township, Mechanicsburg, PA 17055-4050. RYAN BURGETT, DEP SHERIFF COST: $39.30 SO ANSWERS, 6z, June 17, 2013 RON R ANDERSON, SHERIFF (c)CountySuife Sheriff,Toleosoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, fj'' vs. C= Eileen J.Mangan; rrTrCO Defendant. G-' CD ,+ REQUEST FOR CONCILIATION CONFERENCE { Pursuant to the Administrative Order dated February 28,2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property,which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program"and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties.of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Def dant's Counsel/Appointed Date al 'presentative __ L Signature of De ndant Date Signature of Defendant Date Zucker,Goldberg&Ackerman,LLC XFP-177222 Certificate of Service The undersigned certifies that a copy of the foregoing was served on the following by First Class Mail, postage prepaid on August 13, 2013 to: Scott A. Dietterick, Esq. Kimberly A. Bonner, Esq. Joel A. Ackerman, Esq. Ashleigh L. Marin, Esq. Ralph M. Salvia, Esq. Jaime R. Ackerman, Esq. ZUCKER, GOLDBERG&ACKERMAN, LLC XFP-177222/rbo 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 Counsel for Plaintiff Wells Fargo Bank, N.A. Melissa H. Calvanelli Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Melissa Furrer Miller WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : vs. CIVIL ACTION rnC7 `. NO. 13-3065 CIVIL EILEEN J. MANGAN, Defendant 5;c ; CASE MANAGEMENT ORDER N) Cn AND NOW,this day of August, 2013,the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on OA2WA12 X4/3 , at /0:36 c, m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. ti 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, Ke i Hess, P.J. , Jaime Ackerman, Esquire 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 For the Plaintiff ✓Melissa Furrer Miller, Esquire 950 Walnut Bottom Road, Suite 15-209 \� Carlisle, PA 17015 For the Defendant Am WELLS FARGO BANK,N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-3065 CIVIL EILEEN J. MANGAN, • Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW,this /0` day of October, 2013, at the request of counsel,the conciliation conference set for October 11,2013, is continued to Friday,November 22, 2013, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi . . Hess, P. J. /Jaime Ackerman,Esquire 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 For the Plaintiff Melissa Furrer Miller,Esquire 950 Walnut Bottom Road, Suite 15-209 Carlisle, PA 17015 For the Defendant :rlm m") cD Pi , )_ ice tc0.2 11) _ -F- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Eileen J. Mangan; Defendant. NO.: 13-3065 CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the case filed at the above -captioned term and number SETTLED, DISCONTINUED and ENDED, without prejudice. Respectfully Submitted: ZUCKER, GOLDBERG & ACKERMAN, LLC BY: Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032,__._ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-177222/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX