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Home My WebLink About13-3382 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: ) Cumberland County 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 required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S Lead Plaintiff's Name: Deutsche Bank National Trust Lead Defendant's Name: Kali Delaney a/k/a Kali L. E Company, as Trustee of the Residential Asset Pinder; David M. Pinder C Securitization Trust 2006 -A7CB, Mortgage Pass - T Through Certificates, Series 2006 -G under the Pooling I and Servicing Agreement dated May 1, 2006 Dollar Amount Requested: within arbitration limits O Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits N 1 Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ 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 ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T ❑ Other: I ❑ Other: O MASS TORT N ❑ Asbestos ❑ 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 ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 12- 042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION C '�_2 Securitization Trust 2006 -A7CB, Mortgage CUMBERLAND COUNTY 5.i Pass - Through Certificates, Series 2006 -G :a under the Pooling and Servicing Agreement NO: dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder 118 Pearl Drive Carlisle, PA 17013 David M. Pinder 118 Pearl Drive Carlisle, PA 17013 DEFENDANTS COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. a� �' Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 12- 042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006 -A7CB, Mortgage CUMBERLAND COUNTY Pass - Through Certificates, Series 2006 -G under the Pooling and Servicing Agreement NO: dated May 1, 2006 PLAINTIFF t VS. ' Kali Delaney a/k/a Kali L. Pinder 118 Pearl Drive Carlisle, PA 17013 David M. Pinder 118 Pearl Drive Carlisle, PA 17013 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Deutsche Bank National Trust Company, as Trustee of the Residential Asset Securitization Trust 2006 -A7CB, Mortgage Pass - Through Certificates, Series 2006 -G under the Pooling and Servicing Agreement dated May 1, 2006, the address of which is, c/o OneWest Bank, FSB, 888 E. Walnut Street, Pasadena, California 91101, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee Mortgage Electronic Registration Systems, Inc., as nominee for IndyMac Bank, F.S.B., a federally chartered savings bank, its successors and assigns Mortgagor(s) Kali L. Pinder and David M. Pinder (b) Date of Mortgage March 23, 2006 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Mortgage Book 1945, Page 369 Date: March 30, 2006 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for IndyMac Bank, F.S.B., a federally chartered savings bank, its successors and assigns Assignee: Deutsche Bank National Trust Company, as Trustee of the Residential Asset Securitization Trust 2006 -A7CB, Mortgage Pass - Through Certificates, Series 2006 -G under the Pooling and Servicing Agreement dated May 1, 2006 Date of Assignment: November 28, 2012 Recording Date: December 3, 2012 Instrument No.: 201237388 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property which is subject to the Mortgage is generally known as 118 Pearl Drive, Carlisle, PA 17013 and is more specifically described as attached as part of Exhibit "A ". 4. Kali Delaney a/k/a Kali L. Pinder executed a note as evidence of the debt secured by the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as Exhibit "B ". 5. The names and mailing addresses of the Defendants are: Kali Delaney a/k/a Kali L. Pinder, 118 Pearl Drive, Carlisle, PA 17013 and David M. Pinder, 118 Pearl Drive, Carlisle, PA 17013. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2012 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The total amount due the Plaintiff on said Note to May 6, 2013 is $120,465.40, which breaks down as follows: Principal Balance Due $113,828.14 Interest @ 6.25% $6,025.96 Pre - Acceleration Late Charges $351.04 BPO /Appraisal Fees $145.00 T TAL $120,350.14 9. Per Diem interest in the amount of $19.49 will accrue on the Principal from May 6, 2013 in accordance with the terms of the note. 10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and /or the mortgaged property address by first -class mail and certified mail. Copies of the material part of the Notice are attached hereto as Exhibit "C" in accordance with Pa.R.C.P. 1019(i). 12. Pursuant Pa.R.C.P. 1019(d), the Notice sent to the Defendant(s) contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. § 403 et seq., and separate Notice of Intention to Foreclose is not required. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: BY: At eys for la tiff S & D File No. 12- 042661 i.ER Pmpsred Dr.. = ..FC3RiEi'. CF JF.cDS 30 Pit 12 1mmw Of me" ft-M l �..taam.a�r ICU Sho zo C0*1 R� Aiterrecording plau:+etall to:: Bank, F. S.18. c% DOMMMt f0xWWW 4 5 11UM QrNdWd �900�1Epp104th Street ng B Suite lsbser / Jidd�rl �� KWHM City, NO 64131 (cx�, sibls Zp Aooel , frame 1 . UPUI'Wrax M 1 [J3oWAlan rau LAW For ROOF&W Dale MORTGAGE N - pg,Ir1FPI'IONS Words need in n mWe sections of this document am defined below and other words we defined is Sections 3, 11, 13, 18, 20 and 2l. Cartsin riles g the u&W of wards seed in this docomept ae also provided in Section 16. (A) "Seewlty Instr=vW memo thisdocumcA which is dated lMaxich 23, 2006 , tosedw with ali Riders to this docalue t UMM No: pbm)tweie bkr% e.Sifl* PWIl -Mok MadRieda Mee UNWOatM 1NMUMFMr MGRS M9ditA IMs 310! t•1/W —TIM C UMLIAMM 800a[s, MG— 94MIA ua era ua .�e�0ioswo�Qas =05.nWC v#WM"Uwe% - BX l 945PGO369 r g .e:;_ � t (B) "Borrower" is FA i L`:Pindet and David H P3nder Borrow is die mortgagor under this Sammy Instam>eM (C) 41 14ZRr is Mortgage Electronic Registation System Inc. MF.&S is a saperme corporation diet is aping sokly as a naminoe for Lander and Lender's successes and aaiim. MW is tbi Offs ee cadet lids Sentrlty lad"==& hf n is organized and a under drt lam of Delawam rood has as address and slepharye number of P.O. Box 2026, FHK MI 49501 -2026, tel. (999) 6794PR& (D) "Leader" is DX 4%W Bank, F. S. B. a federal chattered savings bank Lender is a p1edual Savings Bank organized and aidstmg under the laws of United States of Awariaa . Leader's address is 155 W th Woe Atreaue, Pasadetsa, Ck 91101 (E) "Noter means the psomispcsy mate algued by Bartower and dated 1" 23, 2006 .. The Nate lilatlt r owes Lender °any hundred bweany lour thousas d eight hand n d and Doom (Os. S 124, 800.00 ) plus iDLer m Borrower has promised to pay this debt to regular Periodic Paymeots and to pay the debt in fall not later dram April 1, 2036 (F) "Praperiy" means the property that is described below under the heading ` transfer of Rigby in the Property." (G) °Loan" means the debt evidenced by the Note, phts I any prcpaygmerR charges and lift charges due under the Note, and all sums doe mtder ids Security rnstrumaot, plus interest. (n) 9Udew mesas all Riches to thls Security Inou meat that are executed by Borrower. 71c following Riders are to be wasouted by Borrower fdaec* bar as gVfi aNeP- ❑ Adjustable Rate Ridei Condominium Rider ❑ Second Home Rider ❑ Balloon Rider Pianaed Unit Dndopmend Rider :, ❑ Bi%=W Payment Rider ❑ 1.4 Family Rider. ❑ Revocable Trost Rider ❑ Offim( fSpeco1 (1) "Applimble Law '° menq all controlling applicable federal, state and Id cal statafea, regulations, ordinances and rdmidsusti a mks and arias (that have the effect of lac) as well n OW applicable final, non- appealable judicial opmtons. (J) "Communtty Assoeiatloi Does. Fen, and Asaasaaeata" mesas all dws, foes, assessments and other charges that are imposed an Borrower or the Property by a condominium association, homeowners anwis iou or simr7r a uhation. (K) "Eketrunk Famds TransW means aW transfer of faads, other tim a transaction arigimfed by check, dra% or similar paper Instrument. which is initiated through m clectrank telephonic h! ftwnent, camputei. Cr magnetic tape so as to ordm instruct, or authorize a financial imtlbmtiam to or credit an a000aat. Such tam indudcs, but is not limifod to. point- of-sak ttansfors, automated teller mecidne transactions; transfen initialed by telephone, wire irandhm and autammated clearinghouse tnmfas. : ra.r�t..af. hwr wrasivgh a may -caste ssw7adde Met orrQOaear avarKtUAZ rr its Woamod Ram acs 41M — MCaPnuusCM8OVX t,D lap2�u rar�►�wa..wr xww �� 00m3.740��fawa.Yc BK ! 945 PGO370 ° r� • s (L) "Eaeraw Items" means those Imes that at described in Sectloa 3. (14) *Nbed aamous Proosew meets arty ca upamsdoa, aettlament, awm of dama m or proceeds Paid by any tbird icy (odw time iasm mm proceeds paid under the cove sus described is Section 3) fa: (i) damage to, or destruction oC the Propartl, f i) caodemeadoo ar adw hkin g of all or day parrs. e f the Prapar(y; In Heu of caod�on; or (iv) mid 4 or omissiom as to, the vdui`= /or condition of fo P�ropert�y.!. "Moalgage Isumaaoe" aoeans hwstoe pnooedireg Lander sgaimt tbe�t oC or defauh an, the Lo m. (0) 4 Wladie Paymmtw meets the regnialy schodalod anoaatt dad for C,prj cqW mad irtaaa tinder flue-- Nom, Ptm Cn) my amaamts under Section 3 of dds Security baranrent 7 a. (P) 4 RSSPA" mesas the Raul Estaoe Soldemeal Prooedam Act (12. US.C. §Wl et seq.) and its t*kma wmg ragwation, Reguhtloa X (24 C.F.R. Part 3300), as thy might be a m ded from time to am. or ate! additional or succowar leodadowar regaletion that gave= the same subject ma#eer As deed In this Security. Instrument, "RESPA" refers to ell .tequirmunu amd restrictions that are Imposed in regard to a "federdly related matgage load" evar if the Loan door not gnalify as i "fedwaiiy related moriage loan^ under RESPA. (Q) 4 8erceomw to Interest ot;Borrowa" maws day party dud has taken We to the Property, wheew or no tbad party bas asset ad Borry vw's pbHgation under the Nate and/or din SwvAW Ina mm t. TRANSFMOFRIGHTS IN THR PROPERTY '1 k Security bstrammt secmos to Leader: (i) the mp row of the Loan, and dl renewals, e*mstoms and modifications of tie Note; and (ii) the padbromince of Bmaneer's cwmaats said opmocam under this Security ln*umeat and she Note. For this purpose, Barvwer does hweW mortgage. $tart and oaa oy MERE (solely as nomiooe for Lender and Leader's sucees. scan and assign) and to the successors idd oadpa of MM the foDo * described property locsmed it the Qot�ty of dcadw ].a d MT pt of RewrAtg Jinf dkdoy (!Vases cp'Rta rd W mq Tar Parod lD No: 1 ?. See Ea ibit "A" attacbEft hereto and ioecia a part teergof:: F which cwcatly has the address of 118 PERM MUM Carlisle r Penmsylvado 17013 ("PropertyAddress"k TOGETHER WITH aD d1raD the impaoveromb now a haaalier adored oa the popm% and all cmeowms„ appartmm z� trier a , . and 6es tiered - lo r a pert of the psvpatry. All nphoemmb and addition also be covered by tbls Seca ft lit AD of the Somg*g is referred to in this Sec fnW Iaaerurnent as the `Trop".p Borrower and agrees MERE bolds only raga! No to the inteafeats graaeed by Sarawer in this So=* lostrwnent, but, if mawm � ar y to cmapiy with lew or tutor►, be= ( for Lender and Lemderis su messes and assign) has the ftbt: to em oin any or sA of those hieerests, ln?bft& but not limited to, the right >�da Mee�aae -Sbya ramarFstsk t�herPea'de illae iA�l[ Hi87AUl1f�rt[ � b!>�3li.ieed l� �l0! alA[ 7>eat7oaesaeanaraoonca , ivc.— heeiart4 wwe►.r.ss.... i 94.5PG03 1 ,x i I 8 oi l lei 6 till g �.. x .�o . 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' . s 91 ion afta SOMadkft W-*MM Ica Ulm . it =P=wqvvA*%jo=wMw9W*jd*% tqwq op *IM - FIr N PTAW avuw 'x 11 MA PWJO*U PO AMMO PDX== AM AM M PM MMU41lq sm FM sMn *9 of =agk Pi AmmM*AkaMff OXIMMS AS p herd &Pwjcu UD cawpuw Hof on tom, tie �� MOJW ;O w appeared Kali L Pindea` etid David M Pinter _. Imawn to me (or wflsYctorUy proven) to be tho paacm(s) wbose nsme(s) igim submmftd to the within WsbuueA and aclmawledsed that heldm t q eawcnted the same fa the porposes theme cagab ed. In witness wben& I hereunto set my haad and offidd aed. N IRI (Seed) � C�rrY +�r�aooe tMm6e►. Peresyerw,ye �.eooii4,,, d Nonrbs rise sf S .. �F s ' : f III opt lme�lwrle Nw�ao-Si alo Poke lad "Oft UK IMD O� a MM aMod ted lbm 71Pl gw, 1�s e�a.etu�as SWA=.lrct Poke 14 of 14 l�N1i1�M wr bl�[ ..,...M cows �.t4i.w>•.g�,�< IXI945PGO382" ti' ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF NORTH MIDDLBTON IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING DESCRIBED AS FOLLOWS: LOT No. 20 ON PLAN NO. 6 OF NOLL MANOR, AS RECORDED IN PLAN BOOK VOLUME 22, PAGE 163. BEING MORE FULLY PESCR1BED IN A FEE SIMPLE DEED DATED 02107rAM AND RECORDED 0210912000; AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE IN VOLUME 215 PAGE 1146 BEING Pawl No. 29-16- 1096-012 t, c - t 1 j - l - c ertify In Cunib= .i.x. c c; i, ,:, . . ``- Recorder of Deeds r� A-1945PG0363 j NOTE ORI INA L . March 23, 2006 Aarrisburq Pennsylvania [Da!e] [City] [&ate] 118 PERM MIVE, Carlisle, PA 17013 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. S 124, 800.00 (this amount;is called "Principal'), plus interest, to the order of the Lender. The Lender is IItdyMac Bank, F. S. B. , a federally chartered savings bank 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 called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay irderest at a yearly rate of 6.250 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described 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 1st day of each month beginning on May, 2006, 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 April 1, 2036 , I 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 IndyMae Bank, F.S.B. , P.O. Boot 78826, Phoenix, AZ 85062 -8826 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount ofU.S. S 768.42 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. Loan No: MIN: MWttmte Flud Roa Note 5bWc F'mnHy- -Fyode MbdFreddk Mac UNIFORM INMUMENT Fom 3MB OM —Torre Coxrrs vt¢ South, hve— Page 100 tuatstu am .nv.eo�t:n�.e,cm oraoq rnoeoop:� some~ the I I. 1 1 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 i 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 1 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 5.000 % of my overdue payment of principal and interest. 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. j (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 I 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 to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. I 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. & 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, 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. 1 I 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 Dishonoi" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE I 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 Trlst, or Security Deed (the "Security Instrument"), dated the same Iran Nc MuttisMe Flied Rate Note— .Single Family- -Fsmde MadFreddte Mae 111411FORM INSM MENT Foam 3M 01M —IrM ONrUANrs Sooats, INC.— Page 2 of3 ruouno woo ..m° ortoo, re.cmq:,�e sarec em I I I .n j I I date as this Note, protects the Note Holder from possible losses which might result if I do not keep 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 are described as follows: i If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited' by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice I shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. I I i WITNESS THE HAND(S) AND SEALS) OF THE UNDERSIGNED. i (Seal) (Seal) L P ]I1dPS - Borrower - Boffower I ' i i (Seal) (Seal) -Banowa - Borrower I I . PAY TO THE ORDER OF /Sign Origf�a 0*1 WPITIOUT RECOURSE , INDYMAC BA F .S.B. VINCENT DOMBROWSla , VICE PRESIDENT LOan NO: j Mdtlshte Fixed Rah Nolr— Single Family —Faw k MaNF7eddit Mat UNIFORM INMUMENT Form 3200 OLaI —THM COPAPUANCE SOURCE, ntG— Page 3 of 3 tuorarU a" ��utmam�uAOe�o 02W3, Th. C-0.6s�» I I I ' , , i I Date: �5 3 Kali Delaney aka Kali L. Pinder 7 012 3460 0 0 01 6947 0 5 01 118 Pearl Drive Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 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 Ho u sing Finance Agency to!! free °+ 1 _QM_2d7_7'2Q7 ( norennS Wit jE2221rn hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES 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 DERECHO A REDIMIR SU HIPOTECA. 1 t � ' C HOMEOWNER'S NAME(S): Kali Delaney aka Kali L. Pinder and David M. Pinder PROPERTY ADDRESS: 11 Pea rl Drive, Carlisle, PA 17013 LOAN ACCT. NO.: ORIGINAL LENDER: Mortgage Electornic Registration Systems, Inc., as nominee for IndyMac Bank, F.S.B., a federally chartered savings bank, its successors and assigns CURRENT LENDER/SERVICER: OneWest Bank, FSB LAW FIRM FILE NO.: 12- 042661 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOU 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 THE NEXT THIRTY -THREE (33) DAYS 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. 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 have 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. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DA IS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED 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. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION -- PURPCYSES ONLY AND SHOULD NOI'BE CONSEDERED AS I - I LIVIYI 1 V CULLEI 1 - THE DEBT. (If you have filed bankru tc , you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date), NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 118 Pearl Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 2012 to February 1, 2013 @ $768.42 = $5,378.94 Other charges (explain/itemize): Pre - Default Late Charges: _ $351.04 Inspection Fees: _ $55.00. TOTAL AMOUNT PAST DUE: _ $5,784.98 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ( not use if not applicable HOW TO CURE THE DEFAULT - You- may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 5,784.98 , 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 OneWest Bank, FSB c/o Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 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 tio to foreclose upon yo mortgaged vroOero, IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 3 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CIO The Law Firm of Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610)278 -6800 Fax number: (610)278 -9980 Contact person: Christopher A. DeNardo, Esquire EFFECT OF SHERIFF'S SALE You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You X may or _ may not (CHECK ONE) sell or transfer yetff home to a buyer or transferee �41;_O__ vii ass the as debt provided -thatall the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 01/09/2013 10:27 AM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888-511-2227 717 - 232 -9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717- 855 -2752 717- 762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717- 234 -6616 717- 264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 -334 -1518 717 - 780 -3940 800 - 342 -2397 Date: David M. Pinder 118 Pearl Drive 7012 3460 0001 6947 0518 Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 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 listed at the end of this Notice if you h a n a r gu e s t ions, y ou .TM- w-ppa-1.1_ -h-P Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397. (persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES 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 DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Kali Delaney aka Kali L. Pinder and David M. Pinder PROPERTY ADDRESS: 118 Pearl Drive, Carlisle, PA 17013 LOAN ACCT. NO.: -- " ORIGINAL LENDER: Mortgage Electornic Registration Systems, Inc., as nominee for IndyMac Bank, F.S.B., a federally chartered savings bank, its successors and assigns CURRENT LENDER/SERVICER: OneWest Bank, FSB LAW FIRM FILE NO.: 12- 042661 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOU 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 THE NEXT THIRTY -THREE (33) DAPS 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. 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 have 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. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL Y 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. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION FU"USES ONLY AND SHOULD NOT 33E CONSIDER DASANATTEMTTTOCOLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergen Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 118 Pearl Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 2012 to February 1, 2013 @ $768.42 = $5,378.94 Other charges (explain/itemize): Pre - Default Late Charges: _ $351.04 Inspection Fees: _ $55.00 TOTAL AMOUNT PAST DUE: _ $5,784.98 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ( not use if not applicable HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 5,784.98 , 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 OneWest Bank, FSB c/o Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) 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 IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by� paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. y EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 3 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610)278 -6800 Fax number: (610)278 -9980 Contact person: Christopher A. DeNardo, Esquire EFFECT OF SHERIFF'S SALE You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You X may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee �_ will assume the mortgage debt, that al the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBTOR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 01/09/2013 10:27 AM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717- 232 -9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717- 855 -2752 717- 762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717- 234 -6616 717- 264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717- 334 -1518 717- 780 -3940 800 - 342 -2397 VERIFICA'T'ION The undersigned is Assistant Secretary of OneWest Bank, FSB on behalf of C \ --�, -. V� and as such is familiar with the business records maintained by OneWest Bank, FSB for the purpose of servicing mortgage loans. These records (which :include data compilations, electronically imaged documents, and others) are made at or near the time by, or from other information provided by, persons with .knowledge of the activity and transactions reflected in such records, and are kept in the course of business activity conducted regularly by OneWest Bank, FSB. I am authorized to make this verification on behalf of Plaintiff and hereby verify that the facts set forth in the foregoing Complaint in Mortgage .Foreclosure are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of Pa. C.S. §4904, relating to unsworn falsification to authorities. OneWest Bank, FSB on behalf of Date: ,�`� -2�1 �• _ �_. ..._- __..— ._....__..._......__. Name: Mable . pulaney Title: Assistant Secretary Company :�� e w�r4 - a`, �I/l S & D FILE NO: 12- 042661 Kali Delaney a /k/a. Kali L. Pinder and David M. Pinder � s FORM 1 IN THE COURT OF COMMON PLEAS OF Deutsche Bank National Trust Company, as Trustee CUMBERLAND COUNTY, of the Residential Asset Securitization Trust 2006- PENNSYLVANIA A7CB, Mortgage Pass - Through Certificates, Series r j 2006 -G under the Pooling and Servicing Agreement --a dated May 1, 2006 -- —' Plaintiffs):, r �� =- r - Kali Delaney a/k/a Kali L. Pinder 118 Pearl Drive F5 Carlisle, PA 17013:_ -' David M. Pinder 118 Pearl Drive Carlisle, PA 17013 DEFENDANTS Defendant(s) ' Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation -Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) t e 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 submitted: SHAPIRO & DeNARDO, LLC )q a, Date` Auorqpys for aintiff 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 Please provide the following information to the best of your knowledge: CUST 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- BOR R OWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FIN ANCIAL •' • 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 #2: 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): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Ex enses: Please only include ex enses you are currently a in EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2 Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other pro . Payment Install. Loan Payment Cable TV Child Su ort/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: 2 7 � ' 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 know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATIO I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating in 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 Past 2 bank statements 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 market) FORM 3 : IN THE COURT OF COMMON PLEAS OF Deutsche Bank National Trust Company, as Trustee CUMBERLAND COUNTY, PENNSYLVANIA of the Residential Asset Securitization Trust 2006 - A7CB, Mortgage Pass - Through Certificates, Series 2006 -G under the Pooling and Servicing Agreement dated May 1, 2006 Plaintiff(s) vs. Kali Delaney a/k/a Kali L. Pinder 118 Pearl Drive Carlisle, PA 17013 David M. Pinder 118 Pearl Drive Carlisle, PA 17013 DEFENDANTS Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 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; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. 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 unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Defendant(s) Civil 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. 2. At least twenty -one (2 1) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendantiborrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the 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 J. �C�rrf SChe �1r1,� /1/a Coo. a_i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) V S. 1 t `- kac.(,i OVM e &14 &U L. P«k Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURtr, - 3 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 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. THIS PROGRAM IS FREE. Respectfully submitted: xv Date [Signature of C nse for Plaintiff] 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: CUST 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? C O-BO R ROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FINANCIAL INF ORMATIO N 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 #2: 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): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthl�Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortage 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 Su port/Alim. I Spending Money Day /Child Care /Tuft. I 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: 2 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 know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTliORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating in 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 Past 2 bank statements 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 market) .. _. ...__._..._.. SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF,ESQUIRE, ATTORNEY I.D. NO. 310530 17,c-) * 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 fzi c..' ~ TELEPHONE: (610)278-6800 S &D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & DeNARDO, LLC Date: -1\.3 I7j BY: Attorneys for Plaintif, 0-) othA s 11 .-63A or igotoff-) g-4)- c)c) Ocia SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r L -0FR-"E Sheriff i; .. I'HE f ROTHONOTAR Jody S Smith r � 2S , Chief Deputy Richard W Stewart ' a :A: CUMBERLAND COUNTY Solicitor OFFICE OFTVE S�ER1FP PENNSYLVANIA Deutsche Bank National Trust Co. Case Number vs. 2013-3382 Kali Delaney (et al.) SHERIFF'S RETURN OF SERVICE 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has resided at this address for months. 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kali Delaney, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has resided at this address for months and the Carlisle Postmaster informed this office that they still deliver mail to this address for the defendant. 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David Pinder, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has lived at this address for months and the Carlisle Postmaster confirms that the defendant no longer resides at this address. SHERIFF COST: $75.78 SO ANSWERS, u June 19, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson (a� " t Or' j Sherifft'a'Cti 0118p111 of fi:iro�t� �r�xr ,- Jody S Smith ,, 2013 SF-P —6 f l Chief Deputy Richard W Stewart -° CUMBERLAND Ct}( NTy Solicitor OFFICE OF THE SPERIFF PENNSYLVANIA Deutsche Bank National Trust Co. Case Number vs. 2013-3382 Kali Delaney (et al.) SHERIFF'S RETURN OF SERVICE 07/16/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kali Delaney, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 105 E. Willow Street, Carlisle Borough, Carlisle, PA 17013. This office was advised by co-defendant David M. Finder that the defendant is now living somewhere in Maryland, but he did not provide a good address for her. 09/04/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David Pinder, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Served" at 105 E. Willow Street, Carlisle Borough, Carlisle, PA 17013. Deputies were told my neighbors that the defendant is only at the residence on weekends and then only for a short period of time a business card was left for the defendant who then called into office stating he moved out from Mortgaged address, but did not provide a forwarding address, instead made arrangements to come to office to pick up paperwork but never showed. Complaint has since expired. SHERIFF COST: $62.56 SO ANSWERS, September 04, 2013 RON + R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosott,Inc. y SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 3'11403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF'COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David _? r-- M. Pinder --' DEFENDANTS y PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & DeNARDO, LLC i Date: BY: Attorneys for Plaintiff � - 29 s3cx� QUIRE,ATTORNEY I.D.NO. 311403) LEONARD J.mucd JIL ESQUIRE,ATTO1ZNEYLD.NO. 921357 3600HORJZON'DRr\7E,'SU1TE 150 K]NG OFPRUSSIA, PA 19406 TELEPHONE: (6'10)278-6'800 Deutsche Bank National Trust Company,,as COURT 01, COW 40N PLEAS Trustee of the Residential Asset CRITL DWISION Pass-Througgli Certificates. Series 2006-G under iffie Pooflng and Servicing Agreement NO: dated May 1,2006 M Kali Delaney A/a Kali L. P i ader --4- n 8 Pearl Drive _4 Carlisle,PA 17013 David M. Pinder Carlisle, P.A 17013: MORTGAGE FORECLOSURE NOTTCE YOU HAVE BEEN SUED IN Comm IF You NvISII TO DEFEND AGAINSTI'lit'CLAIMS SET FORT11INTITE FOLLONN'TNG PAGES,You MUST TAKE ACTJO.N,WITTI-IN-I-NNT'_1NT1j_70)DAYS A M-ERTHISCO51PLAINT AND ENTERED AGAINST YOUIIYTDL-, COURT WITHOUT Fimmm GICE rORAWY MONEY CLA�IM'EIITN tur.- OP.PROPER-h'OR OTHER RIGHTS TMPORTANTT To)!0 U. YO'U SHOULD TAXt THIS PAPER*ro YOURLAVk1rLR AT ONCE. JJ,'YOUDONOT)1ANTt.ALANAqq' CANNOT AFFORD ONE,,GO TO ORTELEPHONL Tilt OFFICE SETj,"ORTfl IIE1,0NA1,110 FIND OUT WJJEREYO'U CAN PROVIDE YOU WYM WFORINIATION ABOUT AGENCTE S THAT jNlAy OFFEIR LEGAL SERN710ES TO ELIGIBLE PERSONS.A.T A RE DUCE D FEE OR NO FEE. _ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson A,yp,�. Sheriff i.,ik' TKF PRO O "y>,1ti ,Nop Jody S Smith Chief Deputy 13 SEA' 25 A 11,. ,��,;�. . Richard W Stewart �+! p (jib COUNTY Solicitor OFFIC�EQFTj<$KERIFv ks1JML��[\� At°� COUN Y pEHNS% LBIAHIA Deutsche Bank National Trust Co. Case Number vs. 2013-3382 Kali Delaney(et al.) SHERIFF'S RETURN OF SERVICE 09/14/2013 08:55 AM -Deputy Mark Conklin, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosur by "personally"handing a true copy to a person representing themselves to be the D fe ant o wit: David Pinder at 1417 Walnut Bottom Road, South Middleton, Carlisle, PA 17015,. MAR C KILN, D UTY 09/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kali Delaney, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1417 Walnut Bottom Road, South Middleton, Carlisle, PA 17015. Per co-defendant David Pinder, defendant moved somewhere to Maryland. Per USPS, defendant is not known at address given; no forwarding information is available. SHERIFF COST: $55.78 SO ANSWERS, 6�� September 24, 2013 -RONW R ANDERSON, SHERIFF (c)countysuite Sheriff,Teleosoft,!nc. C) 4'-' SHAPIRO & DeNARDO, LLC -0 ° ``' BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 `4, CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 > KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 3105300 . AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 ;> KING OF PRUSSIA, PA 19406 Lit • TELEPHONE: (610)278-6800 S & D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS MOTION FOR SERVICE PURSUANT TO COURT ORDER Plaintiff, by its counsel, Shapiro & DeNardo, LLC moves this Honorable Court for an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting alternative service of the Complaint and any other document or pleading requiring original process upon Defendant, Kali Delaney a/k/a Kali L. Pinder, by sending a true and correct copy by simultaneous certified and regular mail; and by posting a true and correct copy on the mortgaged property that is the subject of the above-captioned mortgage foreclosure action; and in support thereof avers the following: 1. On June 12, 2013, Plaintiff filed its complaint in mortgage foreclosure against the above-captioned Defendants for the property located at 118 Pearl Drive, Carlisle, PA 17013 (hereinafter "Property"). 2. Plaintiff forwarded the Complaint to the Cumberland County Sheriff in order to effectuate personal service upon Defendant, Kali Delaney a/k/a Kali L. Pinder. 3. The Cumberland County Sheriffs attempts to serve Defendant, Kali Delaney a/k/a Kali L. Pinder, with the Complaint have been unsuccessful, as reflected on the Sheriffs Return of Service, attached hereto as Exhibit"A," and made a part hereof. 1. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to locate Defendant, Kali Delaney a/k/a Kali L. Pinder. An Affidavit of Good Faith Investigation, which sets forth the specific inquiries made and the results thereof, is attached hereto as Exhibit"B" and made a part hereof. 5. The Affidavit of Good Faith Investigation reflects that 118 Pearl Drive, Carlisle, PA 17013, 105 E. Willow Street, Carlisle, PA 17013 and 1417 Walnut Bottom Road, Carlisle, PA 17015 are valid addresses for Defendant, Kali Delaney a/k/a Kali L. Pinder; See Ex. "B." 6. However, the Cumberland County Sheriffs Return of Service for such address states otherwise. See Ex. "A." 7. A Request for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(ii), completed and certified by the Carlisle Pennsylvania Postmaster reflects the following: "Good as address/No change of address order on file" for the Pearl Drive address, and "Not known at address given" for the E. Willow Street address. True and correct copies thereof are attached hereto as Exhibit "C" and made a part hereof • WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order allowing Plaintiff to serve the Complaint and any other document or pleading requiring original process on Defendant, Kali Delaney a/k/a Kali L. Pinder, by (1) sending a true and correct copy thereof by simultaneous certified and regular mail to the last known address located at 118 Pearl Drive, Carlisle, PA 17013, 105 E. Willow Street, Carlisle, PA 17013 and 1417 Walnut Bottom Road, Carlisle, PA 17015; and (2) posting a true and correct copy thereof on the mortgaged property located at 118 Pearl Drive, Carlisle, PA 17013 by the Sheriff or any competent adult. SHAPIRO & DeNARDO, LLC Date: 161-1\1 BY: ` I� Attor -ys for Plaintiff CAITLIN M.DONNELLY, : I U1RE S&D: 12-042661 7 12 -d-12-40(01 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff o»,t„of Cum,„,yy� Jody S Smith - a o Chief Deputy G.r--'•• ,:) Richard W Stewart Solicitor GF RLE�F 7fE eacpi ; Deutsche Bank National Trust Co. vs. Case Number Kali Delaney (et al.) 2013-3382 SHERIFF'S RETURN OF SERVICE 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has resided at this address for months. 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kali Delaney, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has resided at this address for months and the Carlisle Postmaster informed this office that they still deliver mail to this address for the defendant. 06/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David Pinder, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 118 Pearl Drive, North Middleton, Carlisle, PA 17013. Deputies were advised by a neighbor that no one has lived at this address for months and the Carlisle Postmaster confirms that the defendant no longer resides at this address. SHERIFF COST: $75.78 SO ANSWERS, June 19,2013 RONNY R ANDERSON, SHERIFF Evio\m,t\:),tsr tel CourtySuea Stxn f.rceosor, inc 1 - 10--(Zto(o■ SHERIFF'S OFFICE OF CUMBERLAND COUNTY A Ronny R Anderson Sheriff y0�,tt,of subtrf?,,o Jody S Smith Chief Deputy C' Richard W Stewart Solicitor O%F is GF T.-.E jM�F,IF= Deutsche Bank National Trust Co. Case Number vs. Kali Delaney (et al.) 2013-3382 SHERIFF'S RETURN OF SERVICE 0711612013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kali Delaney,but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 105 E. Willow Street, Carlisle Borough, Carlisle, PA 17013.This office was advised by co-defendant David M. Pinder that the defendant is now living somewhere in Maryland,but he did not provide a good address for her. 0910412013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David Pinder, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Served"at 105 E. Willow Street, Carlisle Borough, Carlisle, PA 17013. Deputies were told my neighbors that the defendant is only at the residence on weekends and then only for a short period of time a business card was left for the defendant who then called into office stating he moved out from Mortgaged address, but did not provide a forwarding address, instead made arrangements to come to office to pick up paperwork but never showed. Complaint has since expired. SHERIFF COST: $62.56 SO ANSWERS, September 04, 2013 RONNY R ANDERSON, SHERIFF (C)Cou.-.!ySUilo Sttonr Teec oft I c ' ' - - - ) '/ ' - ° ` / `~ | - ` ~ | SHERIFF'S OFFICE OF CUMBERLAND COUNTY • Ronny RAnderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Suhc8o/ Deutsche Bank National To�Co - Case Number vs. 2013-3382 Kali Delaney (et ai) SHERIFF'S RETURN OF SERVICE 00/14/2013 08.55 AM Deputy Mark Conklin, being duly sworn according to law, se'ved the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage ForeclosurVby "personally" handing a rue copy to a person representing themselves to be the Defer) nt 'o cut: David Pindorut 1417 Walnut Bottom Road, South Middleton, Cadis|a, PA 17015. '/ MAR ^COlKL^ D rUTY 08/2412013 Penny R Anderson, Sheriff, being duty sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit' Kali De|aney, but was unable to locate the Defendant in his bailiwick The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure DiversionPmgramandComp|aintinMm1gageFnredosuveas~NotFound~sg1417VYa|nutBottomRoad. South Middleton, Carlisle, PA 17015 Per co-defendant David Pinder, defendant moved somewhere to Maryland. Per USPS, defendant is not known at address given; no forwarding inhormaUonisavai|ah|e SHERIFF COST: 85578 SO ANSWERS, September 24, 2013 RONNY R ANDERSON, SHERIFF r Confidential Plaintiff: Deutsche Bank National Trust Company Investigative County: Cumberland Services, Inc. vs. Term#: 13-3382 Civil Defendant: Kali Delaney a/Wa Kali L.Pinder and David M. Pinder Locate: Kali Delaney a/k/a Kali L. Pinder Address Given: 118 Pearl Drive,Carlisle,PA 17013 ATTENTION: Tiffany Donnell Shapiro& DeNardo,LLC 3600 Horizon Drive,Suite 150 King of Prussia,PA 19406 File#: 12-042661 AFFIDAVIT OF GOOD FAITH INVESTIGATION LAST KNOWN ADDRESS 118 Pearl Drive, Carlisle, PA 17013 INQUIRY OF THE CREDIT BUREAU The credit bureau reports that the most recent address of the subject is 118 Pearl Drive, Carlisle, PA 17013. INQUIRY OF THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION The Pennsylvania Department of Transportation—Division of Motor Vehicles reports driver's license number111111111111is issued to Kali Delaney of 118 Pearl Drive, Carlisle, PA 17013. The license is current and not due to expire until March 3, 2015. INQUIRY OF U.S. POST OFFICE (FOIA) Requests have been forwarded to the United States Post Offices. SEARCH OF LOCAL TELEPHONE DIRECTORIES & PHONE COMPANY OPERATOR CONTACT The telephone company operator reports no listing issued in the subject's name at 118 Pearl Drive in Carlisle, PA or the surrounding area. CONTACTS No neighbors could be reached to confirm the subject's residency at 118 Pearl Drive in Carlisle, PA. I CERTIFY UNDER PENALTY OF PERJURY,THAT THE FOREGOING IS TRUE AND CORRECT,TO THE BEST OF MY KNOWLEDGE. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE UBJE O THE PENALTIES RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. AFFIANT: IA E WAN, CLI 235 South 13th Street SW• ' & UL:CRIBED BEFORE ME TH1S3 Philadelphia,PA 19107 0 - . o: :I. 2013 igr tjiCIM N I COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL ERICA ROBERTSON,Notary Public City o1 Ptl1lo, olAhte Putts. urn, ii1�13tfIff111I:gn r ao� +emu+: 10 2014 csigit)ri:pr arf6 8!19/13 Report Results-This Form Produced by Equifax( User Reference:DIANE Inquiry Information: Date of Inquiry: 08/19/2013 UserID: DIANE Subject Information: Name: delane , kali SSN: Current Address: 118 pearl DR Carlisle, PA 17013 Report Results SSN AFFIRM - INQUIRY SSN ASSOCIATED WITH CONSUMER ************************************************************************•**** * ADDRESS DISCREPANCY - NO SUBSTANTIAL DIFFERENCE OCCURRED * 199 EQUIFAX INFORMATION SERVICES LLC, P 0 BOX 740241, ,ATLANTA,GA,30374-0241,800/685-1111,WWW.EQUIFAX.COM/FCRA *PINDER,KALI SINCE 01/26/91 FAD 12/14/12 FN-901 118,PEARL,DR,CARLISLE,PA,17013,TAPE RPTD 07/00,TAPE DLR 08/06/2013 270,W RIDGE,ST,CARLISLE,PA, 17013,TAPE RPTD 03/00,TAPE DLR 03/09/2011 1104,REGENT,CT,CARLISLE,PA,17013,TAPE RPTD 10/98,TAPE DLR 03/09/2011 FN-DELANEY,KALI FN-DELANEY,KRISTEN FN-GREENHALGH,KRISTEN,L FN-PINDER,KRISTEN,L BDSAIIIMIRD,SSS 01 ES-,CAPE CRAFTSMAN 02 EF-,FARMERS TRUST& END OF REPORT EQUIFAX AND AFFILIATES - 08/19/13 Nips Jt eport.equifaxconYedaVgetResponse.htm 111 PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING BASIC DRIVER INFORMATION } AUG 28 2013 DRIVER: KALI DELANEY DRIVER LICENSE NO : 1E6 118 PEARL DRIVE DATE OF BIRTH CARLISLE, PA 17013 SEX : FEMALE RECORD TYPE : REG LICENSE DRIVER LICENSE (DL) COMMERCIAL DRIVER LICENSE (CDL) LICENSE CLASS : C CDL LICENSE CLASS . LICENSE ISSUE DATE: MAR 01 2011 CDL LICENSE ISSUED : LICENSE EXPIRES : MAR 03 2015 CDL LICENSE EXPIRES: ORIG ISSUE DATE : AUG 06 1987 CDL ENDORSEMENTS : NONE MED RESTRICTIONS : NONE CDL RESTRICTIONS : NONE LEARNER PERMITS COL LEARNER PERMITS: LICENSE STATUS : CDL LICENSE STATUS : SE ENDORSEMENT PROBATIONARY LICENSE (PL) PL LICENSE CLASS : PL LICENSE ORIG ISS PL LICENSE ISSUED PL LICENSE EXPIRES : PL LICENSE STATUS OCCUPATIONAL LIMITED LICENSE (OLL) OLL LICENSE CLASS OLL LICENSE ISSUED OLL LICENSE EXPIRES : OLL LICENSE STATUS . *** END OF RECORD *** 4 Brenda Scholly 113 Pearl Dr Carlisle,PA 17013-1045 Home_EM Answering machine Sandra R Wyckof 114 Pearl Dr Carlisle,PA 17013-1044 Home�� Number not in service Michael Murray 116 Pearl Dr Carlisle, PA 17013-1044 Homea111111111 A facsimile machine answers Judith S Phillips 120 Pearl Dr Carlisle, PA 17013-1044 Home 1.1111.1110 Answering machine Robert D Ford 115 Pearl Dr Carlisle, PA 17013-1045 Home'Home 1111111111111 Answering machine • The telephone company operator reports no listings issued the subject at 118 Pearl Drive or in Carlisle, PA. 3600 Horizon Drive,Suite 150 King of Prussia, PA I9406 4 January 9, 2013 Postmaster CARLISLE. PA 17013 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or name and street address(ila boxholder) for the %dlowiorr: N: ltirE & nt)nttrss: Kali Delaney ADDRESS: ► 18 Pearl Drive Carlisle. PA 17013 '' Oil.: l'he name and last known address are required for change of address inl >rnration. The name. if known,and post office box address are required for hoxholder information. I he following information is provided in accordance with 39('FR 265.6(d)(6)(ii). t here is no fee for providing boxholder information. I he lie or providing change of address infornaatiorl is w 3O('I R 265.6(d I(I)and(2)and corresponding Adnrinistratire Support Manual 352.44a and E. Capacity of Requester(e.‘2,. process server.attorneA, party representing himself: ATTORNEY. 2. Statute or regulation that empowers me to serve process(nut required when requester is an attorney or a party. acting pro se- except a corporation acting pro se 'mist cite statutels) NtA I he names of all known parties to this litigation: Deutsche Bank National Trust Company, as"Trustee of the Residential Asset Securitization Trust 2006-A7C'13, Mortgage Pass- Through Certificates,Series 2006-G tinder the Pooling and Servicing Agreement dated May 1,2006 vs. Kali Delaney and David M. finder The court in which the case has been or will he heard:'The Court of Common Pleas of CGIMBERLAND Counts 5. lie docket or other identity Mg number if one hers been issued: fending the capacity in which this individual is to be served(e.g. defendant or witness): Df:FFNI)ANl \VARN!NC i t II:SttltMISSION 01-i'At SIT(NI"OIZNHA"i it)N FO OUFAIN AND l`SI t,I I A."^ct 01',AD1)Ht s5 1'.i I)F',1,A I ll iN OR 13ONi l))! 1 li R INI OR.AI:AI RON FOR ANY t'iTr( _SF OHIIEI WAN 1 1 1 1,S l I\IC1 111 1 t.(.i'1 Oli)('1 Y,l v(()NNW Ill) \VII I:A("I!':Al.r)R I'ROSiTCIIV'I 1111D;A III r`J NII;I D 01-51=1.1 tN('RtAltNrAI I't NAI:ftr'S t N( t.1.11A M.;A h'1.`J f't)1'alt''rO S 1 0),0 00i i t I\t t'I i l S l",Arl h:I a l i t(I 1 IO A VUID I':A1''vIl:".''I Of l Oil Ili FO1 tIA"GLOP ADDIttSSINH)R\1ATIONOt Nof%IORl "IlIAN5YI:ARS.ORrtUlii(1nll 1x1+SC '511u01) information t'rule and tlr,rt the I Jres>iaum:rri a u uccrlr'd and kraal In conrre■rir,n ssitrr 1)00)1 0) rr,,1% ‘• ;r:atjsdtr 1,1)1101,!,S Shdpu„,"; I>,':.a I 1 H' �r�:Htac N nn'r I)mt_Saiy 1:n Sterile I'tu.);r. t coal Numl cr I_'-rrr'nni FOR POST OFFICE USE ONLY Good As Addresscd'No change of address order'on file. NEW :ADDRESS or ROXl-lOL_Dl R'S POSTMARK Not known at t ddress 'pis°cn N.AME SI RI I I ADDRESS ytoned. left no forwarding address No such address Ek 1 64, cm,. 3(100 JTorizon Drive,Suite i50 King of Prussia, t'2 19-106 July 2. 2013 I10strnaster CARLISLE . PA 17013 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or name and street address(if a boxholder) for the following: NAME & ADI)RI:SS: Kali Delaney ADDRESS: 105 i: \Vtllo\\v street Carlisle. PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known. and post office hoy address are required for boxholder information. I he following information is provided in accordance with 39 CFR 265.6(d)(61( I here is no iee for providing boxhoider information. Ctr tee 01'}+s).iS1oe of inti nn uion is vtamed in accordance o ith 3to C'FR 265.6(dk!?and(2)and correspondinw ,-ldministrative•Support Manual 372.-1dda and b. Capacits of Requester(e.g. process server. attorney,party representing himself): ATTORNEY. Statute or regulation that empowers me to serve process(not required a hen requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute)s): N A The names of all known parties to this litigation: Deutsche Bank National Trust Company, as Trustee of the Residential Asset Securitization Trust 2(106-A7CI3, Mortgage Pass- 'T'hrough Certificates, Series 2006-C under the Pooling and Servicing Agreement dated May I, 200(i v.s. Kali Delaney a/ti/:► KaIi L. Pinder and David M. Pinder 4. I he court in which the case has been or mm ill he heard: The Court of Common Pleas of Ct''Ni DERE.A,Ni) Cotmt■ 5, The docket or other identifying number if one has been issued: I3-3382 Civil (i. The capacity in which this individual k to be served(e.g.defendant or witness): DEFENDANT WARNING 'i}9[S l'B'�i 1 5 5 1 1 i`:{t i 1 \t 5 1 1 I"I:UR`I.V 1?(e': 1 I O i tit I,A I' V 'f)'. 5} CI \`a(O 4 OF \t)I)t t i 55 INN R9.1 y I It r`,;i H !3a),1 1(U Ot ft !NH")R\1-A i RH,I t,l< i't.'i+P(rSf R filmS. 1!t} tit_RV,( I ∎: Irr:A i'S S I V,11 V I``=. Al ?RPP+ Otii'I ("II\l If [I( .o) II)PItil l i 4'1.%Al i l} IN(I t I)i?..i \. 4'.} ,:i til' r rit, t;'RIs r. .lt a ■l{ - i+ '`t)11) n.. 11 :S l E .tOt. ) f.A' . �I`-� t'ii fit).} j;1„ t P 'I i cern P., bran th also Inhumation is tru:and that rnlnnnauert is n,:adrd;nit Well be u,arl sal(),, star icc lenat t,r,,ceo In connection mti}ttt actual r,r ntirspte lire hn . iurr 11)lltt1`55 tiharnn ti I)cNiirmt>. 1_LC St;tsra riire ;t,(u,t!onion I)1 Oar Sutre 150 1 m(Iam Donnell kin::ui I'rsr,Oa 1'-A I'+IOrI rtn p rt:rrt S A I)I tl•"=wn'cr 12-0 FOR POSTOFFfCF 1'Sl' ONLY Good As Addressed No change ofaddres' order on file. NEW ADDRESS or BOX f IOI.I)E:R'S POSTMARK Not knossn at address given ti,AAil:and STREE_C ADl)RE.SS Moved.left no fonssardim7 address No such address Deutsche Bank National Trust Company, as Trustee of the Residential Asset Securitization Trust 2006-A7CB, Mortgage Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement dated May 1, 2006 vs. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder VERIFICATION Caitlin Donnelly, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO COURT ORDER are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & DeNARDO, LLC \ jam, Date: ( D'-1VID BY: Attrreys for 'lainti CAITLIN M.DONNELLY, :.QUIRE S&D: 12-042661 } SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the Plaintiff may move the Court for a special Order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note A Sheriffs Return of Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of a good faith effort to locate the Defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As reflected on the attached Sheriff's Return of Service, the Cumberland County Sheriff's attempts to serve Defendant, Kali Delaney a/k/a Kali L. Pinder, with the Complaint have been unsuccessful. See Ex. "A." Good faith efforts to discover the whereabouts of Defendant, Kali Delaney a/k/a Kali L. Pinder, have been made, as evidenced by the numerous inquiries set forth in the attached Affidavit of Good Faith Investigation. See Ex. "B." The Affidavit of Good Faith Investigation reflects that 118 Pearl Drive, Carlisle, PA 17013, 105 E. Willow Street, Carlisle, PA 17013 and 1417 Walnut Bottom Road, Carlisle, PA 17015 are valid addresses. See Ex. "B." However, the Sheriff's Return of Service for that address states otherwise. As reflected in the Affidavit of Good Faith Investigation, inquiries have been made to the following persons and entities: 1. Defendant's creditors; 2. Directory Assistance; 3. Defendant's neighbors; 4. United States Postal Service; 5. Pennsylvania Department of Transportation, Driver and Vehicle Services; and 6. Pennsylvania State Vital Records Office. See Ex. "B." Inquiries have also been made to public record databases on the Internet, the County voter registration records, and the County tax assessment records. See Id. Despite all of the foregoing inquiries, Plaintiff has not been able to determine Defendant, Kali Delaney a/k/a Kali L. Pinder's present location. Based on the foregoing, it is more likely than not that Defendant, Kali Delaney a/k/a Kali L. Pinder is avoiding and/or evading personal service of the Complaint. Plaintiff respectfully requests this Honorable Court enter an Order allowing Plaintiff to serve the Complaint and any other document or pleading requiring original process on Defendant, Kali Delaney a/k/a Kali L. Pinder, by (1) sending true and correct copies thereof by simultaneous certified and regular mail to the last known address located at 118 Pearl Drive, Carlisle, PA 17013, 105 E. Willow Street, Carlisle, PA 17013 and 1417 Walnut Bottom Road, Carlisle, PA 17015; and (2) posting a true and correct copy thereof on the mortgaged property located at 118 Pearl Drive, Carlisle, PA 17013 by the Sheriff or any competent adult. SHAPIRO & DeNARDO, LLC Date: (e \ BY: At O,,;e :,4oPNW LY, :. QUJRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Motion for Service Pursuant to Court Order, Verification, Memorandum of Law, and proposed Order on (b °j\13 to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Kali Delaney a/k/a Kali L. Pinder, 118 Pearl Drive, Carlisle, PA 17013 Kali Delaney, 105 E. Willow Street, Carlisle, PA 17013 David M. Pinder, 1417 Walnut Bottom Road, Carlisle, PA 17015 Kali Delaney, 1417 Walnut Bottom Road, Carlisle, PA 17015 SHAPIRO & DeNARDO, LLC Date: !6NO BY: Attorneys for nlainf CAITLIN M.DO i Y ESQUIRE k SHAPIRO & DeNARDO, LLC `� ' BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 744c t 1 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 C`JMSERi AN1 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 PEE SYLvi lA 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 12-042661 Deutsche Bank National Trust Company, et al COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 13-3382 Civil Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS ORDER AND NOW, this /0 4 day of OC/o k u , 20®3 , upon consideration of Plaintiffs Motion for Service Pursuant to Court Order, Affidavit of Good Faith Investigation and Memorandum of Law is support thereof, and any response thereto, it is hereby ORDERED AND DECREED that Plaintiff may serve the Complaint and any other document or pleading requiring original process on Defendant, Kali Delaney a/k/a Kali L. Pinder, by (1) sending true and correct copies thereof by simultaneous certified and regular mail to the last known address located at 118 Pearl Drive, Carlisle, PA 17013, 105 E. Willow Street, Carlisle, PA 17013 and 1417 Walnut Bottom Road, Carlisle, PA 17015; and (2) posting a true and correct copy thereof on the mortgaged property located at 118 Pearl Drive, Carlisle, PA 17013 by the Sheriff or any competent adult. Service of the aforementioned mailings is effective upon the date of mailing and is to be effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a Certificate of Service as to such mailings BY THE COURT: J. e .-- ), ),(-)Ec1 y to I I A3 J- l SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 22!3 OCT 21 VI 10: 47 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 t^.jiiE€�L �4D COUNTY KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 PENNSYLVANIA AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & DeNARDO, LLC Date: , i(6)t3 BY: r - CAITLIN M.DONNEL ,ESQUIRE Attorneys for Plaintif S a ad). t- 1t/v,3) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith !. f..,_.p ? rxf r , , , Chief Deputy C.., Richard W Stewart �` f��,�� ; , , a Solicitor ,. �. �� , - J� 5 . ,-. '/'-1 }H Deutsche Bank National Trust Co. Case Number vs. Kali Delaney(et al.) 2013-3382 SHERIFF'S RETURN OF SERVICE 10/24/2013 03:36 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 upon the within named Defendant,to wit: Kali Delaney, pursuant to Order of Court by"Posting"the premises located at 118 Pearl Drive, North Middleton, Carlisle, PA 17013 with a true and correct copy according to law. RONALD HOOVER, EPUTY SHERIFF COST: $40.78 SO ANSWERS, October 25, 2013 RONNY R ANDERSON, SHERIFF ,,, ,,-;,3i, Too 0 a- ;..,,_ • SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 .w r'<'t CS,F C� �-q-' -r- TELEPHONE: (610)278-6800 r i l;r S & D FILE NO. 12-042661 ' Deutsche Bank National Trust Company, et al COURT OF COMMON PLEA " `^ C-7 " C' 41 PLAINTIFF CIVIL DIVISION ,r) ^ VS. CUMBERLAND COUNTY :rc: r Kali Delaney a/k/a Kali L. Pinder and David 1 M. Pinder NO: 13-3382 Civil f DEFENDANTS AFFIDAVIT OF SERVICE I,Tiffany Donnell, the undersigned, being duly sworn according to law, hereby depose and say that on the J- day of C)C41. e.f , 2013, pursuant to the attached Order of Court, attached as Exhibit "A", I served a true and correct copy of the Complaint in Mortgage Foreclosure in the above captioned matter to the Defendants by certified and regular mail, to their last known address of: Kali Delaney a/k/a Kali L. Pinder, 118 Pearl Drive, Carlisle, PA 17013 Kali Delaney, 105 E. Willow Street, Carlisle, PA 17013 Kali Delaney, 1417 Walnut Bottom Road, Carlisle, PA 17015 SHAPIRO & DeNARDO, LLC BY: Tiffany Donnell Legal Assistant to Attorney for Plaintiff SWORN AND SUIVCRIBE^,D!!\\ Before me this 28 da of <3.-M 20_ • Notary P r blic S & D FILE NO. 12-042661 COMMONWEALTH OF PENNSYLVANIA " Notarial Seal Denise L.Semetti,Notary Public Upper Merlon Twp.,Montgomery County My Commission Expires July 22,2014 Member.Pennsylvania Association of Notaries LL Idt3J011 uxt'aaI Qw ° LL 1iiDAIIaU pa1ai.tsa)J MN o 0� M . 2u!Tpu1u moods 1J p 16 )LL UOTTEL U JuoD amIeu2Ts L1 ER N a) > �, uot��mJ uoD �anilOU `1 0 t v w rn�M p CL >o fri ` 4'NOO )U NOO •= ) O r r �+• �r� C o d r1 j @ N • la' !Y�Yr > V aa ) > a)0 a m a) = m � g =t mU a'0E2ti m E m o°£ Nam Ro asp c`3) ° <CB I y� °m o m LL o�ao PA N a 0 R\ o E L n (yak C a) 0 2•_' • it i-•i •y Q m Y -2 Ili ea a> a> m o, c� cd cd p DODO . cd cd CCS o M M O kr)_ C.) �, N O �C/1 O ›, 0 0 a cn € a) V 7 N 3 O s a> U ,LD CO thfl!21 ,� ,a ,..a ❑❑❑❑D a oo U ° U Z U a U w a) U O« O O O na as Z > a N @a o N cc a N cn y 7 cci ti 6 a)a) -D N'O,> a) v q o N 4 ri a ❑ y o a Q $ 2 o. 0 M c �0,n N E > mox o € a) aovon Zo 0 N CL Zfn MV)� r N co W J d 1 U.S. Postal Service.r. 1 U.S. Postal Service Pi 7.------.1".................u............1"1"11.11.111.11111111111.11111111111111111111111111.11"11111"11111111111"" CERTIFIED MAILTM RECEIPT CERTIFIED MAIL,,, RECEIPT Ili 1 (Domestic Mail Only;No Insurance Coverage Provided) er (Domestic Mail Only;No Insurance Coverage Provided) For delivery information visit our website at www.usps.coms P- C:3 CI For delivery information visit our website at www.usps.coms .... 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DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS 2 T Trustee of the Residential Asset CIVIL DIVISION -. Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY ' - Pass-Through Certificates, Series 2006-G cro— ;R : • under the Pooling and Servicing Agreement NO: 13-3382 Civil . ca c,) dated May 1, 2006 _;_'` ' PLAINTIFF CA) '. VS. Kali L. Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. SHAPIRO &DeNARDO, LLC Date: BY: \7it4 Attorneys for Plaintiff SHAPIRO &DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D.NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 12-042661 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee of the Residential Asset CIVIL DIVISION Securitization Trust 2006-A7CB, Mortgage CUMBERLAND COUNTY Pass-Through Certificates, Series 2006-G under the Pooling and Servicing Agreement NO: 13-3382 Civil dated May 1, 2006 PLAINTIFF VS. Kali L. Delaney a/k/a Kali L. Pinder and David M. Pinder DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on \ \?7 \\L-1 to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Kali L.Delaney a/k/a Kali L. Pinder 118 Pearl Drive Carlisle,PA 17013 David M.Pinder 1417 Walnut Bottom Road Carlisle,PA 17015 Kali L.Delaney a/k/a Kali L.Pinder 105 E.Willow Street Carlisle,PA 17013 Kali L. Delaney a/k/a Kali L.Pinder 1417 Walnut Bottom Road Carlisle,PA 17015 SHAPIRO &DeNARDO,LLC Date: \ CI ULI BY: Attorneys for Plaintiff