HomeMy WebLinkAbout13-3540 Supreme Court :a Pennsylvania
C OUr Co ;Pleas For Prothonotary Use Only:
et
C 4 County Docket No: 8s 4,4
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
F S 21 Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
F C Lead Plaintiff's Name: SUNTRUST MORTGAGE, INC. Lead Defendant's Name: JOHN K. COPELAND
�T
I Dollar Amount Requested: El within arbitration limits
O Are money damages requested. El Yes Z No
(Check one) N outside arbitration limits
E
N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes x❑ No
A Name of Plaintiff/Appellant's Attorney: Melissa J. Cantwell, Esq., Id. No.308912, Phelan Hallinan, LLP
❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant)
�^ Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
P"MARYCASE. 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) CP*IM 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
❑ Product Liability (does not
S include mass tort) ❑ Employment Dispute:
❑ Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
0 ❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
• Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
• Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
$ ❑ 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:
Pa.R. C A 205.5 Updated 01/01/2011
+ E f'fi0 T i10 4' 0 T A Wi
2013 MIN' 18 AM 10: 3O
'C'UMBERLAND COUNTY
PEN14SYLVANIA
PHELAN HALLINAN, LLP
Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
ATTORNEY FOR PLAINTIFF
One Penn Center Plaza
Philadelphia,. PA 19103
215 -563 -7000
SUNTRUST MORTGAGE, INC.
1001 SEMMES AVENUE COURT OF COMMON PLEAS
P.O. BOX 27767
RICHMOND, VA 23224 -7767 CIVIL DIVISION
Plaintiff TERM
NO.
JOHN K. COPELAND
17 LILAC DRIVE CUMBERLAND COUNTY
MECHANICSBURG, PA 17050 -3189
MARCY L. COPELAND
17 LILAC DRIVE
MECHANICSBURG, PA 17050 -3189
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
a
Ik
File #: 319754
1 2 , W - - o ? q Po/ c
1. Plaintiff is
SUNTRUST MORTGAGE, INC.
1001 SEMMES AVENUE
P.O. BOX 27767
RICHMOND, VA 23224 -7767
2. The name(s) and last known address(es) of the Defendant(s) are:
JOHN K. COPELAND
17 LILAC DRIVE
MECHANICSBURG, PA 17050 -3189
MARCY L. COPELAND
17 LILAC DRIVE
MECHANICSBURG, PA 17050 -3189
who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described.
3. On 07/30/2007 JOHN K. COPELAND and MARCY L. COPELAND made, executed
and delivered-a mortgage upon the premises hereinafter described to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR MEMBERS
1 ST FEDERAL CREDIT UNION, which mortgage is recorded in the Office of the
Recorder of Deeds of CUMBERLAND County, in Mortgage Book 2001, Page 2612. By
Assignment of Mortgage recorded 01/03/2013 the mortgage was assigned to PLAINTIFF,
which Assignment is recorded in Assignment of Mortgage Instrument No.
201300200.The mortgage and assignment(s), if any, are matters of public record and are
incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule
relieves the Plaintiff from its obligations to attach documents to pleadings if those
documents are of public record.
4. The premises subject to said mortgage is described as attached.
File #: 319754
5. The-mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/01%2012 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage as of 6/30/2013:
Principal Balance $153,007.61
Interest $7,848.66
10/01/2012 through 6/30/2013
Late Charges $128.73
Property Inspections $169.09
Property Preservations $0.00
Appraisal/BPO $0.00
Mortgage Insurance Premium/ $0.00
Private Mortgage Insurance $0.00
NSF Charges $0.00
Escrow Deficit $0.00
Escrow Credit ($200.92)
TOTAL $160,953.17
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage. Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in
File #: 319754
2008 and/or Notice of Default as- required by the mortgage document -as applicable, have
been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as
provided by said notice has terminated because Defendant(s) has/have failed to meet with
the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied
assistance by the Pennsylvania Housing Finance Agency.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$160,953.17, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN, LLP
By
Melissa J. Cantwell, s ., No.308912
Attorney for Plaintiff
File #: 319754
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or parcel of land situate in Silver Springs Township, Cumberland
County, Pennsylvania, bounded and described according to a plan of Section I, Mulberry
Crossing as recorded in Plan Book 40, Page 142B as follows, to wit:
BEGINNING at a point on the southerly side of Lilac Drive at the dividing line of this lot and the
northerly line of Lot #77; thence along said line South 59 degrees 12 minutes 11 seconds East, a
distance of 137.00 feet to a point on the westerly line of Lot No. 62; thence along said line North
30 degrees 47 minutes 49 seconds East a distance of 68.50 feet to a point on the southerly line of
Lot No. 75; thence along line North 59 degrees 12 minutes 11 seconds West, a distance of 137.00
feet to a point on the southerly side of Lilac Drive; thence along Lilac Drive South 30 degrees 47
minutes (erroneously referred to in a previous deed as 74 minutes) 49 seconds West a distance of
68.50 feet to a point, the place of BEGINNING'.
BEING Lot No. 76 on Section I of Mulberry Crossing as recorded in the Recorder of Deeds
Office, for the county of Cumberland at Carlisle, PA, in Plan Book 40, Page 142B.
HAVING THEREON ERECTED a dwelling house being known and numbered as 17 Lilac
Drive.
PROPERTY ADDRESS: 17 LILAC DRIVE, MECHANICSBURG, PA 17050 -3189
PARCEL #38 -21- 0289 -104.
File #: 319754
m
' r VERIFICATION
hereby states that he /she is Officer of SUNTRUST
MORTGAGE, INC., Plaintiff in this matter, that he /she is authorized to make this Verification,
and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are
true and correct to the best of his/her information and belief. The undersigned understands that
this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
DATE: �PII 145 /
Name:—�� uil
Title: Officer
SUNTRUST MORTGAGE, INC.
File #: 319754
v
File #: 319754
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249 -3166
(800) 990 -9108
File #: 319754
FORM 1
IN THE COURT OF COMMON PLEAS
SUNTRUST MORTGAGE, INC. OF CUMBERLAND COUNTY, PENNSYLVANIA,.._,
Plaintiff(s)
JOHN K. COPELAND� -,z '
MARCY L. COPELAND C�/� - )
1�'/y ea
Defendants) Civil G
.. C rf"
NOTICE OF RESIDENTIAL MORTGAGE FORECLO
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 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 ' work -
orksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
JU�1 17 2013
Date
Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
t
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
CUSTOM ER/PRIMARV APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-RORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
INFORMATION FINANCIAL
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:
I • Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2nd Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency: Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I/We, , authorize the above named
to use /refer this information to my lender / servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to
use the counseling services provided by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
Sheriff OF THE PROTHONOTARY
Jody S Smith
Chief Deputy 2013 JUN 26 PM 2:, 1 '1
Richard W Stewart
Solicitor CUMBERLAND COUNTY
PENNSYLVANIA
Suntrust Mortgage Inc. Case Number
vs. 2013-3540
John Copeland (et a[.)
SHERIFF'S RETURN OF SERVICE
06/2012013 11:57 AM-Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: John
Copeland at 17 Lilac Drive, Silver Spring, Mechanicsburg, PA 17050.
V)
1WE"DIMART1.1, DEPUTY
06/2012013 11:57 AM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be John Copeland, Husband,who accepted as"Adult
Person in Charge"for Marcy L Copeland at 17 Lilac Drive, Silver Spring, Mechanicsburg, PA 17050.
IE DIMARTLE, DEPUTY
SHERIFF COST: $55.30 SO ANSWERS,
June 21,2013 RbNWY R ANDERSON, SHERIFF
(0 CountySufte Sheriff,Teleosoft,lnc.
Suntrust Mortgage, Inc. : IN THE COURT OF COMMON PLEAS
1001 Semmes Avenue : CUMBERLAND COUNTY,
P.O. Box 27767 : PENNSYLVANIA
Richmond, VA 23224-7767
Plaintiff
—
0
V. : Docket No. 13-354 =
John K. Copeland
Marcy L. Copeland �' 'Y s
17 Lilac Drive : CIVIL ACTION-
Mechanicsburg, PA 17050-3189 : MORTGAGE FORECLOSURE
Defendants
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012, governing the
Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned
hereby certifies as follows:
1. Defendant is owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
off/GZ� zo
ignature of Defendant's Counsel/A inted Date
L a Re resent e
CQ 9-� C5 Z('ZG$ i
Signa ure of Def dant Date
Signat re Defend I_nt Date
Suntrust Mortgage, Inc. : IN THE COURT OF COMMON PLEAS
1001 Semmes Avenue : CUMBERLAND COUNTY,
P.O. Box 27767 : PENNSYLVANIA
Richmond, VA 23224-7767
Plaintiff
V. : Docket No. 13-3540
John K. Copeland
Marcy L. Copeland
17 Lilac Drive : CIVIL ACTION-
Mechanicsburg, PA 17050-3189 : MORTGAGE FORECLOSURE
Defendants
CERTIFICATE OF SERVICE
1, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendants,
John K. Copeland and Marcy L. Copeland,hereby certify that I am serving a copy of the
Praecipe for Entry of Appearance and Request for Conciliation Conference on the Plaintiff,
through their attorney, on the following date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Melissa J. Catwell, Esq.
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
MIDPENN LEGAL SERVICES
DATE:
t J ime M. Haley, Esquire 0
Attorney for Defendants
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
Suntrust Mortgage, Inc. : IN THE COURT OF COMMON PLEAS
1001 Semmes Avenue : CUMBERLAND COUNTY,
P.O. Box 27767 : PENNSYLVANIA
Richmond, VA 23224-7767
Plaintiff
V. : Docket No. 13-3540
John K. Copeland
Marcy L. Copeland n
17 Lilac Drive : CIVIL ACTION- ` zz
Mechanicsburg, PA 17050-3189 : MORTGAGE FORECLOSU
Defendants ,
r-- --
CD CD
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of MidPenn Legal Services on behalf of the Defendants, John
K. Copeland and Marcy L. Copeland, in the above matter, representing the Defendants in the
Cumberland County Residential Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE:
Jame M. Haley, Esquire '
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
Suntrust Mortgage, Inc. : IN THE COURT OF COMMON,-PLEAS
1001 Semmes Avenue : CUMBERLAND COUNTY, a
-rj P.O. Box 27767 : PENNSYLVANIA . : r
Richmond, VA 23224-7767
Plaintiff --
V. : Docket No. 13-3540 , N) '
-� cn
John K. Copeland
Marcy L. Copeland
17 Lilac Drive : CIVIL ACTION-
Mechanicsburg, PA 17050-3189 : MORTGAGE FORECLOSURE
Defendants
CASE MANAGEMENT ORDER
AND NOW, this 94day of , 2013, 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 o7(0 A013 ate 30 , in
at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one(21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with 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 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 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.
DISTRIBUTION:
Jaime M.Haley, Esquire
MidPenn Legal Services
401 E. Louther Street, Ste 103
Carlisle,PA 17013
For the Defendants
..XMelissa J. Catwell, Esq.
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
For the Plaintiff
a lea(
Q//3
SUNTRUST MORTGAGE, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION—LAW
NO. 13-3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND,
Defendants MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
In lieu of a conciliation conference this date, the Court was advised that a full packet has
been submitted for review by the plaintiff. A mistake was noted with regard to certain income
information. New documents in this regard will be submitted within fourteen(14) days.
Continued conciliation conference will be set by order of even date herewith.
ORDER
AND NOW,this Z(6 ' day of September, 2013, continued conciliation conference is
set for Thursday,November 14, 2013, at 11:00 a.m. in Chambers of the undersigned.
BY THE COURT,
�f
Kevin . Hess, P. J.
,XD. Troy Sellars, Esquire
For the Plaintiff -*y?.
Maj C/5
aime Haley, Esquire C
For the Defendant �— z.x
:rlm
A7
yy
SUNTRUST.MORTGAGE, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION—LAW
NO. 13-3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND,
Defendants MORTGAGE FORECLOSURE
,IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW,this day of November,2013, at the request of counsel for the
parties, the conciliation conference set for Thursday,November 14, 2013, is continued to Friday,
January 3, 2014, at 3:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin Hess, P. J.
oseph Schalk, Esquire
For the Plaintiff
'aime Haley,Esquire
For the Defendant
:rlm
cc� ce's /??Zt
ZZ:
2:
SUNTRUST MORTGAGE, INC., •
IN THE COURT OF COMMON PLEAS OF
Plaintiff •
CUMBERLAND COUNTY, PENNSYLVANIA
vs. •
CIVIL ACTION-LAW
•
NO. 13-3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND, •
Defendants •
MORTGAGE FORECLOSURE
ORDER
AND NOW, this 9' day of January, 2014, at the request of counsel for the parties,
the conciliation conference set for January 3, 2014, is continued to Friday, February 14, 2014, at
4:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevi A. Hess, P. J.
Troy Sellars, Esquire
For the Plaintiff
Jaime Haley, Esquire
For the Defendant
:rim
C-CY-3 I.C.S PtLg t1544,..
//49/pi
. 1171
..t--
rril■ t-
r?
r--
SUNTRUST MORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION—LAW
• NO. 13-3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND,
Defendants : MORTGAGE FORECLOSURE
ORDER
AND NOW,this Z d` day of February, 2014, at the request of counsel for the parties,
the conciliation conference set for February 14, 2014, is continued to Friday, April 4, 2014, at
3:30 p.m. in Chambers of the undersigned.
BY THE COURT,
r
A/Z.
Kevin Hess,P. J.
Troy Sellars, Esquire
For the Plaintiff
Jaime Haley, Esquire
For the Defendant
:rr1m
COF g.ES 1/2.t.t Lecl_
a/zo/'y
co . - ri°:
car- 1\3
c)
r-
1
_( cn
SUNTRUST MORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION — LAW
: NO. 13 -3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND,
Defendants : MORTGAGE FORECLOSURE
ORDER
AND NOW, this Z 'If day of March, 2014, at the request of counsel for the parties,
the conciliation conference set for April 4, 2014, is continued to Friday, April 25, 2014, at 3:30
p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin A. ess, P. J.
Troy Sellars, Esquire
For the Plaintiff
Jaime Haley, Esquire
For the Defendant
Copi^es ()%cti.ca
w
cW01/1
•••■77,ey)
.
SUNTRUST MORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION — LAW
: NO. 13-3540 CIVIL
JOHN K. COPELAND and
MARCY L. COPELAND,
Defendants : MORTGAGE FORECLOSURE
ORDER
AND NOW, this Z q day of April, 2014, at the request of counsel for the parties, the
conciliation conference set for April 25, 2014, is continued to Friday, June 27, 2014, at 3:00
p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin Hess, P. J.
--K). Troy Sellars, Esquire
For the Plaintiff
Haley, Esquire
For the Defendant
:rim
SUNTRUST MORTGAGE, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION-LAW
: NO. 13-3540 CIVIL
JOHN K.COPELAND and
MARCY L. COPELAND, •
Defendants . MORTGAGE FORECLOSURE
ORDER
AND NOW,this z s' day of June, 2014, on agreement of the parties, the conciliation
conference set for June 27, 2014, is continued generally.
BY THE COURT,
ft hi-
Kevin . Hess, P. J.
‘-'7Jaseph Schalk, Esquire
For he Plaintiff
Jaime Haley, Esquire
For the Defendant
:rim
C
t ES a2 EcL
to
S;fir
- t N
Cr- '
C c:.
fi r
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
F;LEO-OF FICE
OF THE PROTHONOTARY
i.:
2OI4 JUL 30 AM 11: _
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney For Plaintiff
SUNTRUST MORTGAGE, INC.
Plaintiff
v.
JOHN K. COPELAND
MARCY L. COPELAND
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13 -3540 -CIVIL
PRAECIPE
TO THE PROTHONOTARY:
® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
n Please mark the above referenced case Settled, Discontinued and Ended.
n Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
n Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
n Please Vacate the Judgment entered.
Date: -.461 (PHE • ' AN
PH # 813512
By:
Courtenay R. Dunn, Esq., Id. No.206779
Attorney for Plaintiff
S K 7
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
SUNTRUST MORTGAGE, INC.
Plaintiff
v.
JOHN K. COPELAND
MARCY L. COPELAND
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13 -3540 -CIVIL
I hereby certify true and
regular mail to the person(s) on
JAMIE M. HALEY, ESQUIRE
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
SUITE 103
CARLISLE, PA 17013
Date:
CERTIFICATION OF SERVICE
correct copies of the foregoing Plaintiffs Praecipe was served by
the date listed below:
PHELAN HAWN
By:
Courtenay R. Dunn, Esq., Id. No.206779
Attorney for Plaintiff