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Supreme Cou' Pennsylvania Cou t of *Col<T mo nTleas For Prothonotary Use Only: Cl<i1Cove Sheet Docket No: � M12 CumB R N� " ` �. Count i p �� 0 The information collected on this form is used solely court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ix Complaint Cl Writ of Summons -` Petition El Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Household Finance Consumer Discount Company Tomas A. Quintero and Dawn M. Alexander - Quintero Dollar Amount Requested: =i within arbitration limits I Are money damages requested? El Yes 0 No (check one) outside arbitration limits O N Is this a Class Action Suit? El Yes El No Is this an MDJAppeal? Yes 0 No A. Name of Plaintiff/Appellant's Attorney: Andrew J. Marley 0 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 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 C? Intentional Q Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution El Debt Collection: Credit Card El Board of Assessment E] Motor Vehicle El Debt Collection: Other E] Board of Elections n Nuisance 0 Dept. of Transportation E] Premises Liability El Statutory Appeal: Other S Product Liability (does not include E Employment Dispute: mass tort) Q Slander/Libel/ Defamation Discrimination C =s Other: Employment Dispute: Other Zoning Board T Other: I Other: O MASS TORT El Asbestos N E] Tobacco Toxic Tort - DES Q Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Q Toxic Waste - Other: � Ejectment � Common Law /Statutory Arbitration B [2 Eminent Domain /Condemnation Declaratory Judgment 0 Ground Rent Mandamus 0 Landlord/Tenant Dispute =1 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Quo Warranto � Mortgage Foreclosure: Commercial Dental Partition 0 Replevin 0 Legal E] Quiet Title 0 Other: Medical 0 Other: 0 Other Professional: i Updated 1/1/2011 STEVEN K. EISENBERG ESQUIRE (75736) ( KEvIN P. DISKIN, ESQUIRE (86727) _- � ��� f �: ();~� N O �7fl�p�� TljF' i Stern & Eisenberg, PC { ,rfB 1581 Main Street, Suite 200 ~3 Ao f ,. The Shops at Valley Square f�! ; AN D C )Uki Warrington, PA 18976 CIS V � ,t NIA TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company 2929 Walden Avenue Depew, NY 14043 Civil Action Number: v. Tomas A. Quintero and Dawn M. Alexander - Quintero 1558 Boiling Springs Road COMPLAINT IN Carlisle, PA 17007 -9690 MORTGAGE FORECLOSURE Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PA Complaint I -A(CML Owner) I1DecI2Ver3.0 ,I n1 4 -a 1 o3.7t pp a, Co 5a-mo8 f 0ga&'?4- IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800 - 990 -9108 717 -249 -3166 PA Complaint 1 -A(CML Owner) 11Dec12Ver3.0 NOTICE PURSUANT TO FAIR DEBTOR COLLECTION PRACTICE ACT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE /LIEN AGAINST REAL PROPERTY. PA Complaint 1 -A(CML Owner) 11 Dec 12Ver3.0 4' STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) LESLIE J. RASE, ESQUIRE (58365) Stern & Eisenberg, PC 1581 Main Street, Suite 200 The Shops at Valley Square Warrington, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY CIVIL ACTION NUMBER: 2929 WALDEN AVENUE DEPEW, NY 14043, COMPLAINT IN Plaintiff, MORTGAGE FORECLOSURE V. TOMAS A. QUINTERO AND DAWN M. ALEXANDER - QUINTERO 1558 BOILING SPRINGS ROAD CARLISLE, PA 17007 -9690 Defendant(s). CIVIL ACTION/MORTGAGE FORECLOSURE 1. This is an action to foreclose a mortgage brought on behalf of Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY. 2. The Defendant(s), TOMAS A. QUINTERO AND DAWN M. ALEXANDER - QUINTERO ( "Mortgagor(s) ") are the real owner(s) of the mortgaged property hereinafter described. The last known address of Mortgagor(s) is 1558 BOILING SPRINGS ROAD, CARLISLE, PENNSYLVANIA 17007 -9690. PA Complaint 1 -A (CML Owner) 11 DEC 12ver3.0 1 3. Attached hereto as Exhibit A is a true and accurate copy of the promissory note and/or loan agreement ( "Note ") bearing the date of DECEMBER 26, 2006, in which TOMAS A. QUINTERO AND DAWN M. ALEXANDER - QUINTERO promised to pay the sum of $218,555.15 ( "Loan"). 4. Attached hereto as Exhibit B is a copy of the mortgage ( "Mortgage "), dated DECEMBER 26, 2006 and bearing the names of Mortgagors, as the mortgagors, on real estate together with all improvements thereon, located at 1558 BOILING SPRINGS ROAD, CARLISLE, PENNSYLVANIA 17007 ( "Real Estate "). A true and accurate copy of said Mortgage is attached as Exhibit B. The Mortgage was duly recorded on DECEMBER 29, 2006, at Book 1977 and Page 3816, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania. 5. The Real Estate subject to the Mortgage is described in the legal description attached hereto as Exhibit C. 6.. The Mortgage is in default because the payments due and secured by the Mortgage have not been made. The Loan is currently due for the JANUARY 2012 payment and all payments thereafter. 7. The business records maintained by Plaintiff demonstrate that the Notice of Intention to Foreclose was mailed, by registered or certified mail, to Mortgagor(s) at Mortgagor(s)' last known address and, if different, to the address of the Real Estate ( "Notice ") on the date set forth in the Notice. A true and accurate copy of the Notice is attached as Exhibit D. A Notice of the Homeowner's Emergency Assistance Program was not mailed to the Mortgagor(s) because Act 91 was suspended during this period in time. PA Complaint 1 -A (CML Owner) I IDEC12ver3.0 2 C 8. As of JUNE 10, 2013, there is due and owing amounts secured by the Mortgage in the sum of $203,665.65, which amount due includes the following: Principal Balance: $177,686.93 Interest through 06/10/2013 at the Current Rate of 7.50000 %: $20,318.32 Advances for Taxes: $4,265.49 Advances for Hazard Insurance: $2,444.78 Advances for Private Mortgage Insurance: $0.00 Total: $204,715.52 Less Suspense Balance or Escrow surplus, if any: $1,049.87 Less Restricted Escrow Balance, if any: $0.00 Total Amount Due or Owed: $203,665.65 The per diem interest due from JUNE 11, 2013 is $36.5110. These itemized amounts may not include all fees currently due and owing under the Note and secured by the Mortgage, including certain late fees, inspection charges, property preservation expenses, and attorney's fees, since Plaintiff has decided to forgo collecting those fees, but that decision does not indicate that such fees were not properly due and owing at the time of any prior communications to the borrower(s) on the Note. PA Complaint 1 -A (CML Owner) 11 DEC 12ver3.0 3 WHEREFORE, Plaintiff demands in rem judgment against the Defendant in the sum of $203,665.65, together with the current interest at the rate of 7.50000% and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. By: ST & EISENBERG, PC Attorneys For Plaintiff VERIFICATION I am a VP and Asst Sec of the Administrative Services Division of the Plaintiff and do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and the facts set forth in paragraphs 1 through 8 of the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties relating to unsworn falsification to au rities. By: Si atur / V0 4-ley Printed Name of Signatory On behalf of HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY VP and Asst. Sec, Its: Admin serv. Div Signatory's Title PA Complaint 1 -A (CML Owner) 11 DEC] 2ver3.0 4 i I LOAN AGREEMENT Including Truth -in- Lending Disclosure Lender: (Called "We ", "Us ", "Our") HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SQUARE/SUITE 107 MECHANICSBURG, PA 17055 Borrowers: (Called "You ", "Your") TOMAS A. QUINTERO DAWN M. ALEXANDER- QUINTERO 1558 BOILING SPRINGS CARLISLE, PA 17007 Date of Loan: 12/26/2006 Loan Number: In this agreement, "you ", "your" mean the Borrowers) who signs this agreement. "We ", "us" and "our" refer to the Lender. This agreement covers the terms and conditions of your ban. It is important to us that you clearly understand the features of your loan. Please read this agreement carefully, and ask us any questions you may have. Truth -in- Lending Disclosure ANNUAL FINANCE CHARGE Amount Financed Total of Payments PERCENTAGE RATE The dollar amount The amount of The amount you wi11 The cost of your credit the credit will cost credit provided to have paid after you have as a yearly rate. you. you or on your made all payments as behalf. scheduled. 7.665% $187,002.79 ( "e ") $213,999.05 $401,001.84 Your payment schedule will be: Number of Payments Amount of When Payments are Due ( "e ") Payments 1 $1,908.01 Day 26 of each month thereafter. 11 $1,908.01 Day 26 of each month thereafter. 12 $1,881.99 Day 26 of each month thereafter. 12 $1,857.19 Day 26 of each month thereafter. 12 $1,833.63 Day 26 of each month thereafter. 12 $1,811.35 Day 26 of each month thereafter. 12 $1,790.38 Day 26 of each month thereafter. 12/26/2006 17:49 Page 1 of 7 EX BIT 0315LE08 Q588773F00 - 976ICET.r 0- 000 - 0315LE - Z- 1 12 $1,770.75 Day 26 of each month thereafter. 12 $1,752.49 Day 26 of each month thereafter. 12 $1,735.61 Day 26 of each month thereafter. 12 $1,720.16 Day 26 of each month thereafter. 108 $1,706.14 Day 26 of each month thereafter. "e" means an estimate Assumption: Someone buying your home cannot assume the remainder of the mortgage on the original terms. YOU ARE GIVING US A SECURITY INTEREST IN THE REAL PROPERTY AS DESCRIBED IN THE MORTGAGE AND LOCATED AT: 1556 BOILING SPRINGS CARLISLE, PA 17007 Late Charge If your monthly installment is not paid in full within 10 day(s) after it is due, you will be charged a late charge equal to 5% of the full amount of the monthly installment. Prepayment You may prepay your loan in full or in part at any time. If you pay off your loan early, you may have to pay a penalty and you will not be entitled to a refund of that part of the Finance Charge consisting of any prepaid finance charges. See your contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date, and prepayment refunds and penalties. The Settlement Statement provides your disbursements and the itemization of the Amount Financed. The figure disclosed in the Annual Percentage Rate box on page one is a composite Annual Percentage Rate which reflects the effect of the various interest rate reductions over the term of your loan. Your payment schedule assumes that all payments are received on the due date. See the "Adjustment to Contract Rate (Pay Right Rewards Program)" section of this agreement. ABOUT THE SECURITY: Your Obligation to Insure You 0all'keep the structures located on the real property securing your loan insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss payable endorsement. If insurance covering the real property is canceled or expires while your loan is outstanding and you do not reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in the real property as outlined below. 12/26/2006 17:49 Page 2 of 7 0315LEOS II���I�I�����E�IWq��III�IIII��IIm�����I�II�I���II��IIIIDII� ' Q888773F00 - 97- CET- 9 - 000 - 0315LE - Z- 2- 0 ° QUINTERO ^ ORIGINAL i Real Property Taxes and Homeowners Insurance covering fire and other hazards on the real Homeowners Insurance property security is required, naming us as a loss payee for the term of your loan. You shall pay us on the day that monthly installments are due under this agreement, an additional sum (the "Funds ") to be used to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over the Mortgage as a lien or encumbrance on the real property; (b) leasehold payments or ground rents on the real property, if any; (c) premiums for any and all insurance required by us under this agreement and the Mortgage ( "Escrow Items "). You will pay us the Funds for Escrow Items unless we waive your obligation to pay the Funds for any or all Escrow Items. We may waive your obligation to pay us Funds for any or all Escrow Items at any time. Any such waiver must be in writing. In the event of such waiver, you will be solely responsible for paying the amounts due for any Escrow Items directly and, if we require, you shall furnish us with receipts evidencing such payment within such time period as we may reasonably require. Title Insurance Title insurance on the real property security is required, naming us as a loss payee. You must purchase title insurance or its local equivalent protecting our lien on the real property as a condition to obtaining your ban. You may purchase title insurance from any title insurance provider you choose that we reasonably believe provides sufficient financial protection to us. You request such title insurance and authorize us to deduct the costs of the title insurance from your loan proceeds in order to pay the title insurance provider. Lender's Right to Place You authorize us, at our option, to obtain hazard insurance coverage Hazard Insurance on the real property in an amount not greater than the outstanding balance of principal and interest on your loan or, if known to be less, the replacement value of the real property, in the event that you fail )?:maintain the required hazard insurance outlined above or fail to provide adequate .proof of its existence. You authorize us to charge you for the costs of this insurance. We may choose to add the insurance charges to the unpaid balance of your loan, which will accrue interest at the Contract Rate, or bill you for the annual premium on a periodic basis. The addition of the insurance charges due might increase the amount of your final monthly installment. The cost of lender- placed hazard insurance might be higher than the cost of standard insurance protecting the real property. The lender - placed insurance will not insure the contents of the real property or provide liability coverage. The insurance might not be the lowest cost coverage of its type available and you agree that we have no obligation to obtain the lowest cost coverage. We or an affiliated company might receive some benefit from the placement of this insurance and you will be charged for the full cost of the premium without reduction for any such benefit. If at any time after we have obtained this insurance, you provide adequate proof that you have subsequently purchased the required coverage, we will cancel the coverage we obtained and credit any unearned premiums to your loan. 12/26/2006 17:49 Page 3 of 7 O315LE08 Q088773176O - 97 - CET - 9 - 000 - 031 5LE - Z - 3 - 0 ° QUINTERO 11 ORIGINAL l ABOUT YOUR LOAN REPAYMENT: SCHEDULED MATURITY DATE 12126/2025 .PREPAID FINANCE CHARGES $4,556.10 MONTHS OF CONTRACT 228 PRINCIPAL $218,555.15 CONTRACT RATE (per year) 8.300% AMOUNT FINANCED $213.999.05 Promise to Pay You agree to the terms of this agreement and promise to pay us the principal (Amount Financed plus prepaid finance charges consisting of Origination Fee /Points, Closing Fee and Tax Service Fee) plus interest'which is computed at a rate of 8.300 9 /6 (the "Contract Rate "). You agree to pay us in monthly Installments as stated in the Payments provision of this agreement. You also agree to pay us: (a) other charges as provided in this agreement; (b) credit insurance charges, if any; (c) collection costs permitted by applicable law, including reasonable attomeys' fees otherwise due under your Mortgage and (d) any other charges reflected in your settlement statement. Interest Interest will be charged on the unpaid principal until the full amount of principal has been paid. You will pay us interest at a yearly Contract Rate of 8.300 %. The interest rate you will pay will change in accordance with the "Adjustment to Contract Rate (Pay Right Rewards Program)" section of this agreement. . 4 The interest rate required by this provision (and the Adjustment to Contract Rate [Pay Right Rewards Program] provision of this agreement) is the rate you will pay both before and after any default as described in this agreement. Payments Time and Place of Payments You 'will pay us principal and interest by paying your monthly installments. You will make your monthly installments to us on the same day of each month beginning on or about 01/26/2007. You will make these monthly installments every month until you have paid all of the principal an&interest and any other charges described herein that you may owe under this agreement. Your monthly installments will be applied to interest before principal. If, on the Scheduled Maturity Date, 12/26/2025, you still owe amounts under this agreement, you will pay those amounts in full on that date, which amount will include interest at ' the then current Contract Rate or any such other rate as required by law. 12/26/200617:49 Page 4 of 7 0315LE08 ( IU I�IININ1 111111®®®MMMMIR ' OSM773FDO - 97 - CET - 9 - 000 - 0315LE - Z - 4 - 0 " QUINTERO A ORIGINAL You will make your monthly installments at the address shown on page one or at the address shown on your monthly billing statement or at a different place that we may give you. Amount of Monthly Installments Your initial monthly installment will be in the amount of $1,908.01, plus the amount of any optional insurance or funds for escrow you elected. Your monthly installment amount will change if the interest rate that you must pay changes. We will determine your new interest rate and the changed amount of your monthly installment in accordance with the Adjustment to Contract Rate (Pay Right Rewards Program) provision of this agreement. Adjustment to Contract Rate The Contract Rate of 8.300% will decrease by 0.20% beginning with (Pay Right Rewards the thirteenth (13th) month after every twelve (12) consecutive monthly Program) periods where all monthly installments were made in full within 30 days of their due date. Up to a maximum of 10 Contract Rate reductions are available during the term of your loan. For each Contract Rate reduction; the monthly installment will be reduced accordingly. Notwithstanding anything to the contrary in this paragraph, you will not receive any Contract Rate reductions or the reduced monthly Installment after 24 periods of delinquency. A "period of delinquency" is defined as any monthly installment that is received more than 30 days past its due date. Consecutive monthly installments received more than 30 days past their respective due dates each count as separate periods of delinquency. Prepayment Subject to the prepayment penalty described below, you may prepay your loan in full or in' part at any time. If you pay off your loan early, you may have to pay a penalty and you will not be entitled to a refund of that part of the f=inance Charge consisting of any prepaid finance charges. Prepayment Penalty Your loan contains a prepayment penalty. If you prepay the entire outstanding balance of your loan at any time within 24 months of the Date of Loan, 12/26/2006, you agree to pay a prepayment penalty equal to 6 months interest calculated at the Contract Rate in effect at the time of prepayment on the unpaid principal balance. No prepayment penalty will be imposed: (a) if your loan is refinanced by another loan with us; (b) after 24 months; (c) if your loan is prepaid from the proceeds of any insurance; or (d) if we sue you. Late Charge If your monthly installment is not paid in full within 10 day(s) after it is due, you will be charged a late charge equal to 5% of the full amount of the monthly installment. Bad Check Charge You agree to pay $20.00 each time any check or payment is made on your loan by any means, including but not limited to, a check or ACH (our Authorization to Debit Account), which is returned unpaid by your bank or other financial institution for any reason. Additional Charges You agree to pay any amounts actually incurred by us for services rb&ered'in connection with the opening and servicing of your loan, as allowed by law. These amounts may include fees for appraisals, title 12/26/2006 17:49 Page 5 of 7 0315LE08 ' Q088773F0O - 97 - CET - 9 - OW - 0315LE - 2 - 5 - 0 " QUINTERO ^ ORIGINAL examination, title insurance or its local equivalent, fees and taxes paid to public officials in connection with recording, releasing or satisfying the Mortgage,and other taxes as shown in the Settlement Statement incorporated herein by this reference. You also agree to pay any other amounts incurred by us in connection with the servicing of your loan including any amounts that we may (but need not) pay or that are otherwise due under the Mortgage, incorporated herein by this reference. Default If you fail to make any monthly installment after it becomes due or fail to comply with the terms of the Mortgage, we may require that you pay us, at once and without prior notice or demand, the unpaid balance of your loan plus accrued interest and any applicable charges in this agreement as authorized. Security Interest You agree to give us a security interest in the real property as described in the Mortgage. 1 ABOUT OUR RELATIONSHIP: Exchange of Information You understand and agree that we will call you from time to time to discuss your financial needs and any ban products that may be of interest to you as may be permitted by applicable law. For more information regarding our privacy practices, please refer to our Privacy Statement, which is included with your ban documents. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. Credit Bureau Reporting If you fail to fulfill the terms of your loan, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. Telephone Monitoring You agree that we may listen to and/or record telephone calls between you and our representatives for quality assurance purposes. Insurance Credit insurance is optional. Any applicable insurance disclosures are included with this agreement and are incorporated herein by this reference. Alternative Dispute The terms of the Arbitration Rider signed by you as part of your loan Resolution transaction are incorporated herein by this reference. Applicable Law If you do not pay the full amount of an installment when it is due, and i we intend to foreclose on the Mortgage, we must comply with the provisions of Section 403 and 404 of the Act of January 30, 1974, which is known as Act No. 6, and the provisions of the Homeowner's Emergency Mortgage Assistance Act (Act No. 91 of 1983). If this loan is a first mortgage, it is a federally related loan made at an agreed4ate•authorized by Section 501(a), Part A, Title V, Public Law I 96- 221; ;Wso known as Section 173511-7(a), Title 12, United States Code. 12126/2006 17:49 Page 6 of 7 0315LE08 0088773FOO - 07 - CET - 0 - 000 - 0315LE - Z - 0 - 0 — QUINTERO ^ ORIGINAL If any provision of this agreement is finally determined to be void or unenforceable under any law, rule, or regulation, all other provisions of fhis'agreement will remain valid and enforceable. Our failure to enforce any provision(s) to this agreement shall not be deemed to constitute a waiver of such term(s). In order for any amendment to this agreement to be valid, it must be agreed to by you and us. You acknowledge that before signing this agreement, you have read and received this agreement which includes the Federal Truth -in- Lending disclosure and, as applicable, any other riders and /or disclosures incorporated herein by reference. By signing below, you agree to observe the terms and conditions of this agreement. ANY ADVANCE OF FUNDS PURSUANT TO LOAN AGREEMENT AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY DEFAULT, RESULT IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS SECURITY FOR YOUR LOAN. Borrower: Date: �o S A. QUINTERO Borrowe Date: /C2 DA N M. ALEXANDER -QUIN TE i Witness: 12/26/2006 17:48 Page 7 of 7 0315LE08 CM8773FOO - 97 - CET 9 - 000 - 0315LE - Z - 7 - 0 " QUINTERO "ORIGINAL (Page 1 of 10) • _ LiE LEE �3 0 2at OWAy Drive 1 :f t�l�urg, Pa„(N v 5 07 JAPE -9 05 � cg � 29 fin 10 10 cGGu Address Return To: Records Processing Services 577 Lamont Road j ...�,. Elmhurst,IL 60126 ( 800) 547 -8776 / (� UPI # Zzi�•'6Z�' 713303 M IF BOX IS CHECKED, THIS MORTGAGE IS AN OPEN -END MORTGAGE AND SECURES FUTURE ADVANCES. THIS MORTGAGE is made this day 26TH of DECEMBER 2006 , between the Mortgagor, A. QUINTERO AND DAWN M. ALEXANDER -Q I TERO, HMM AND WIFE herein rrower and Mortgagee HOUSEHOLD F I NANCE CONSUMER D I SCOUNT C OMPANY a corporation organized and existing under the laws of - PENNSYLVA I A , whose address Is 25 GATEWAY DRIVE, GATEWAY SQUARE /SUITE 107, MECHANICSBURG, PA 17055 herein "Lender"). X a The following paragraph preceded by a checked box is applicable. WHEREAS, Borrower is indebted to Lender in the principal sum of $ evidenced by Borrower's Loan Repayment and Security Agreement or Secondary Mortgage Loan Agreement dated and any extensions or renewals thereof (herein "Note "), providing for monthly Installments of principal and interest, including any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid, due and payable on nFrF:MBFR 26. 2025 WHEREAS, Borrower is indebted to Lender in the principal sum of $ or so much thereof as may be advanced pursuant to Borrower's Revolving Loan Agreement ated and extensions and renewals thereof (herein "Note "), providing For monthly installments, and interest at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of $ ; TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained. Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CUMBERLAND Commonwealth of Pennsylvania: SEE EXHIBIT A —LEGAL DESCRIPTION 1mil(IIIV�IIllli milIII1 111181111I�1111011110181IN11IIIIIlls1911mnm oil 11111IIm1 % 0680773FG097MTG900 .PA00i30ZONKDUIMERD �' ORIGINAL 11 -11 -05 MT6 PA001301 EXHIBIT BKI977PG3816 (Page 2 of 10) a J - TOGETHER with all the improvements now or hereafter erected on the property, and all easements, rights, appurtenances and rents, all of which shall be deemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on a leasehold) are hereinafter referred to as the "Property." • Borrower covenants that Borrower is lawfully selsed of 'the estate hereby conveyed and has the right to mortgage, grant and convey the'*Property, and that 'th"6 property is unencumbered, except for encumbrances of record. Borrower covenants that Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to encumbrances of record. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow.Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest (including any variations in interest resulting from changes in the Contract Rate that may be specified in the Note) on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S, currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money - order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 12. Lender may return any payment or partial payment if 'the payment or partial payments are insufficient to bring the Loan current, Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment -is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may'hold such unapplied funds until Borrower makes payment to bring the Loan current. if Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2 or as may be required by the Note and/or applicable law, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment 11 -11 -05 MTG PA001302 i�llll�l��l�l��Q�IIfII�Ul�illl�ll��lill��i�ll�Ial�ll�l��l�n�ll�lllll�ll��ll�lilli ■ 0699773FG097MTG9000PAOOi3020N "OUINTERO • ORIGINAL 8K 1977PG38 17 (Page 3 of 10) V a.,. -3- and the late charge. If more than one Pdriodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full, To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Volunatary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. t 3. Funds for Escrow Items. Bortower shall pay to Lender on the day Peridic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds ") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any;'(c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, These items are called "Escrow Items," At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items, Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 7. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 7 and pay such amount and Borrower shall then be obligated under Section 7 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section, 12 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are thep required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et.seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 35000, as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this security instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the loan does not qualify as a "federally related mortgage loan" under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) PA001303 11 -11 -05 MTG I INN 111111IIIIIIIIICU1111I Nil 1111I me011111A1IMHH11IIIIIIU1INIII I11111 9 0688773F6097MT09000PA0013030 9 "OUINTERO x ORIGINAL B� 1977PG3818 "I. ' (Page 4 of 10) • f - -4- or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required.by ! 2ESPA. If there is a surplus of Funds held in escrow, as defined under RESPA. Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Prior Mortgages and Deed of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenatA'ib make payments when due. Borrower shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions attributable to the Property which may attain a priority over this Mortgage, and leasehold payments or ground rents, if any. 5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender. Lender shall have the `right to hold the policies and renewals thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and shall comply with the provisions of any lease if this Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or PA001304 11 -11 -05 MTG Ii111lm111IIII1111111111111111111111 pill ROOM Nil UIIIII IBM 01101 NMI M Nil 11 9 0606773F6097MTG9000PA0013040N "OUINTERO " ORIGINAL OKI977PG3819 (Page 5 of 10) -5- governing the condominium or planned unit development, the by and regulations of the condominium or planned unit development, and constituent documents. 7. Protection of Lender's Security. If Borrower fails to perform the covenants and agreements contained in this Mortgage, or if any action or proceeding is commenced which materially affects Lender's interest in the Property, then Gender, at Lender's option, upon notice to Borrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and takesuch action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 8. Inspection. Lender may take or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance i n lieu of condemnation, are hereby assigned and shall be paid to Lender, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in interest. Lender shall not be required to commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's j successors in interest. Any forbearance by Lender in exercising any right or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any such right or remedy. 11. Successors and Assigns Bound; Joint and Several Liability; Co- signers. The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co this Mortgage, but does not execute the Note, (a) is co signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accom modations with regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to Borrower provided forin this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at Property Addressor at such other address as Borrower may designate by notice to Lender as provided herein, and. (b) any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender when given in the manner designated herein. 13. Governing Law; Severability. The applicable law contained in the Note shall control. Where no applicable law is contained therein, the state and local laws applicable to this Mortgage shall be the laws of the 1 isdictio i �n i � i �c ii � the aiiQiii r 1 n�n�IggO������ °i� a�iioocioii iiliiii�a�ami �ina�PtA001305 11 -11 - MTG 0 0688773F6097MTG9000PA001305Ox "GUIMERO " ORIGINAL i 8 1977PG3820 , , (Page 6 of 10) -6- of Federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting ptovision, and to this end the provisions of this Mortgage and the Note are declared to be severable. �► used herein, "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 15. Rehabilitation Loan Agreement. Borrowershall fulfill all of Borrower's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection : with improvements made to the Property. 16. Transfer of the Property. If" Borrower sells or 'tiaii`sfi:rslall or any part of the Property or an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this .Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or less not containing an option to purchase, (d) the creation of a purchase money security: interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f)' a transfe'rAvhere the spouse or children of the Borrower become an owner of the property, `(g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreement, by which the spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by the Federal Home Loan Bank Board, Borrower shall cause to be submitted information required by Lender to evaluate the transferee a if. a new loan were being made to the transferee. Borrower will continue to be obligated udder` the and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such sale or transfer, Lender may declare all of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such option to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NONUNIFORM COVENANTS. Borrower and Lender'furthe.r.,cgvenant and agree as follows: 17. Acceleration; Remedies. Except as provided in'paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying. (1) the breach; (2) the action required to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, by which such breach must be cured; and (4) that failure to cure such breach on or before the date specified in the notice may result in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The 11 - 11 - 05 MTG PA001306 I i�IIII�I�I�I��I�I�I�IDI��lll�lll��llllllllllll��llllllllllllll�lll�ll�llllllQ�l�lllllallll�nllllQ - K a686773F60971WIT139000PA0013050KKOUIWERD " ORIGINAL L 19 77P6382 I (Page 7 of 10) -7- notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and agreements of Borrower contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action as Lender may reasonably require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower hereby assigns to Lender the fents the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof„in abandonment of the Property, have the right to collect and retain such rents as they become due and payable. Upon acceleration under paragraph 7 hereof or abandonment of the Property, Lender shall be entitled to have a receiver appointed by a court to enter upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver shall be applied first to payment of the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually reyeived. 20. Release. Upon payment of all sums secured by this Mortgage, Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law.. ; 22. Interest Rate After Judgment. Borrower agrees the interest'rafe payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. 23. Arbitration Rider to Note. The Arbitration Rider attached to and made a part of the Note is hereby incorporated by reference and made a part of this Mortgage. 11 -11 -05 MTG l�lllllpill� PAGO1307 M QG88773FG097MTG9000PA0013070 ""OUINTERO " ORIGINAL BK 1977PG3822 (Page 8 of 10) t v y -8- REQUEST FOR NOTICE OF'DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage, of any default under the superior encumbrance an fan sale or other foreclosure action. --' s A. Quintero - Borrower Dawn M. A exander— Quintero - Borrower I hereby certify that the precise address of the Lender (Mortgagee) is: 25 Gateway Drive, Suite 107, Mechanicsburg, PA 17050 On behalf of the Lender. By: Ryan D Russell Title B ranch Manager COMMONWEALTH OF PENNSYLVANIA CumhPrland County ss: I, Lisa A Seay a Notary Public in and for said county and state, do hereby certify that To personally known to me or proven satisfactorily to be the same pe rsons • w ose names are subscribed to the foregoing instrument, appeared before me this day in person, and acknowledge that t he y signed and delivered the said instrument as their free voluntary act, or the uses and purposes therein set forth. ,..Given under my hand and official seal, this 26th day of December NOTARIAL SM o expires: LISA A SEAY Nosary Pubft "! •x � ?., �' t � OW OF WRRMSURG. DAMON OOUMY Note P �.. •` ° ' `, ` r t i ' ' MY comrdujon Exp M wl Z4, 2007 OALTH OF PENNSYLVANIA, County ss: } 4 + �`•^ `,W t - a Notary Public in and for said county and state, do hereby certify tl at personally known to me or proven satisf actorily to be te same persons whose name (s subscribed to the foregoing instrument, appeared before me this day in person, and acknowledge t he signed and delivered the said instrument as free voluntary act, for the uses and purposes therein set forth. Given under my hand and official seal, this day of , 20 My Commission expires: Notary Public 11 -11-05 MTG PA001308 II1111111 gin Ili 11H11IIII1111111111 I0I9 ' 0688773F6097MTG9000PA0013080 ""OUINTERO it ORIGINAL 8KI977PG3823 (Page 9 of 10) ` r I -9- (Space Below This Line Reserved For Lander and Recorder) i 11-11-05 mm PA001309 imp ICIIIIIICIII IIIHI MISSION MIIIINMIIII11111II1IIIIIMIIIIV1 NO BBB773F $097MTG9DDOPA0013090 " ORIGINAL BK 1977PG3824 (Page 10 of 10) EXHIBIT A (PAGE 1) ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF MONROE IN THE COUNTY 9F .CUMBERLAND•AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 04/08/2001 AND RECORDED 04/19/2001, AMOUNG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 243 AND PAGE 57. TAX MAP OR PARCEL ID NO.: 22 -11- 0284 -008 it y c 'crtify this to be reco 1,1 Cumberland County P .,., Recorder of Deeds IIIIIIII�IIIII�I����IIiII�III�1111nIII���IIII�I�II���IIII�I�IIID l�IIIII����IBll�llll�illl� K DS$ 9773FG097MT09000PA0013000 ""OUINTERO k ORIGINAL I 8KI977PG3825 ALL THAT CERTAIN tract of ground situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern right of way line of State Highway Route No. 174 at the dividing line between Lot Nos. 7 and 8 on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 19 degrees 29 minutes 30 seconds West, a distance of 150 feet to a point in line of land now or formerly of James R. Compton and Elmer F. Kester, thence along said lands now or formerly of Compton and Kester, by a line curving to the right and having a radius of 3044.93 feet, an arc distance of 106.72 feet to a point; thence still be lands now or formerly of James R. Compton and wife, South 13 degrees 5 minutes East, a distance of 150 feet to a point on the aforesaid northern right of way line; thence by said northern right of way in a westerly direction on a line curving to the left and having a radius of 2894.93 feet an arc distance of 100 feet to a point; the PLACE OF BEGINNING. The above described lot of ground is all of Lot No. 8 as shown on the Plan of Lots prepared by D.P. Raffensperger, Registered Surveyor dated June 8, 1955. UNDER AND SUBJECT to building and use restrictions as recorded in prior deeds. BEING the same premises which John A. Vorchak and Catherine A. Vorchak, husband and wife by Deed dated April 8, 2001 and recorded April 19, 2001 in the Office of the Recorder of Deeds for the County of Cumberland in Deed Book 243 Page 57 as Instrument No. 2001 - 010905, granted and conveyed unto Tomas A. Quintero and Dawn M. Alexander- Quintero, husband and wife, in fee. EXHIBIT STERN & EISENBERG, PC 410 THE PAVUJION 261 OLD YORK ROAD JENKINTOwN, PA 19046 (215) 572 -8111 Date: JuV/ d, 2012 Tomas A. Quintero and Dawn M. Alexander- Quintero 1558 Boiling Springs Road Boiling Springs, PA 17007 -9690 Property (if different than mailing address — notice also sent to property): 1558 Boiling Springs Rd. Boiling Springs, PA 17007 NOTICE OF INTENTION TO FORECLOSE MORTGAGE (ACT 6 NOTICE) The MORTGAGE held by Household Finance Consumer Discount Co. (hereinafter we, us or ours) on your property located at 1558 Boiling Springs Rd. , Boiling Springs, PA. IS IN SERIOUS DEFAULT BECAUSE YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from January 1, 2012 through and including June 29, 2012 as follows: Payments of $1,917.40 due on 01/01/2012 through and including 02/02/2012, inthe amount of ................ ............................... ......................$3,834.80 Payments of $1,926.06 due on 03/01/2012 inthe amount of ................ ............................... ......................$1,926.06 Payments of $1,925.04 due on 04/01/2012 through and including 06/01/2012 in the amount of ..:............. ............................... ......................$5,775.12 Other charges (explain/itemize): Latecharges :................... ............................... ........................$524.40 Other charges ( explain) ............................ ..............................$ 65.00 Uncollected Fees E BIT TOTAL AMOUNT PAST DUE . ............................... .....................$12,125.38 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $12,125.38. You may cure this default within THIRTY (30) DAYS of'the date of this letter, by paving to us the above amount of $12,125.38, plus anv additional monthly pawnents and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: Household Finance Consumer Discount Co. 2929 Walden Avenue Depew, NY 14043 Make sure your account number - 0016191645 is on your payment If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY. (3 0) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty 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 Sheriff's foreclosure sale. You may do so by paving the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and, i f applicable, pefform any other requirements under the mortgage also in default. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately four to six months from the initiation of a foreclosure action; however, the time to foreclose in each county is different. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default, including fees and costs, will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (866) 824 -0824. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You may also call us at the above number to see if there are other arrangements that may be available. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in the mortgaged property. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. ASSUMPTION OF MORTGAGE You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. Ifvou cure the defatdt, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, STERN kPSENBERG, PC BY: Stern & Eisenberg, PC Pursuant to notice published by the PHFA at 41 Pa.B. 2789 in accordance with 35 P.S. 1680.409c of the Act (35 P.S. 1680.101, et. seq., also known as Act 91), effective August 27, 2011 and until further notice of the PHFA, mortgagees may take legal action to enforce a mortgage without any further restriction or requirement of Act 91. Regardless of whether or not your mortgage loan is subject to the notice requirements under 41 P.S. §403 (Act 6), this notice is also given to you pursuant to the terms of your mortgage obligation. The dollar amount of mortgages covered by Act 6 may be found in the Pennsylvania Bulletin. VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND REGULAR MAIL NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE /LIEN AGAINST REAL PROPERTY. STERN & EISENBERG, PC 410 THE PAVILION 261 OLD YORK ROAD JENK1NTOWN, PA 19046 (215) 572 -8111 Date: �� a i 2012 Tomas A. Quintero and Dawn M. Alexander- Quintero 1558 Boiling Springs Road Boiling Springs, PA 17007 -9690 Property (if different than mailing address — notice also sent to property): 1558 Boiling Springs Rd. Boiling Springs, PA 17007 NOTICE OF INTENTION TO FORECLOSE MORTGAGE (ACT 6 NOTICE) The MORTGAGE held by Household Finance Consumer Discount Co. (hereinafter we, us or ours) on your property located at 1558 Boiling Springs Rd. , Boiling Springs, PA. IS IN SERIOUS DEFAULT BECAUSE YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from January 1, 2012 through and including June 29, 2012 as follows: Payments of $1,917.40 due on 01/01/2012 through and including 02/02/2012, in the amount of ................ ............................... ......................$3,834.80 Payments of $1,926.06 due on 03/01/2012 in the amount of ................ ............................... ......................$1,926.06 Payments of $1,925.04 due on 04/01/2012 through and including 06/01/2012 in the amount of ................ ............................... ......................$5,775.12 Other charges (explain/itemize): Latecharges: .......................................................................... $524.40 Other charges ( explain) ............................ ..............................$ 65.00 Uncollected Fees TOTAL AMOUNT PAST DUE: .................................................... $12,125.38 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $12,125.38. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paving to us the abol amount of $12,125.38, plus anv additional monthly pavnients and late charge which may . fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: Household Finance Consumer Discount Co. 2929 Walden Avenue Depew, NY 14043 Make sure your account number - 0016191645 is on your payment If you do not cure the default within THIRTY (30) DAYS, we intend to exercise out- right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to ,foreclose vour mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attornev's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty 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 Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the sale and, if applicable, perform any other requirements under the mortgage also in default. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately four to six months from the initiation of a foreclosure action; however, the time to foreclose in each county is different. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default, including fees and costs, will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (866) 824 -0824. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You may also call us at the above number to see if there are other arrangements that may be available. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in the mortgaged property. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. ASSUMPTION OF MORTGAGE -- You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. �f you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, STERN & tERG, PC BY: ' to isenberg, PC Pursuant to notice published by the PHFA at 41 Pa.B. 2789 in accordance with 35 P.S. 1680.409c of the Act (35 P.S. 1680.101, et. seq., also known as Act 91), effective August 27, 2011 and until further notice of the PHFA, mortgagees may take legal action to enforce a mortgage without any further restriction or requirement of Act 91. Regardless of whether or not your mortgage loan is subject to the notice requirements under 41 P.S. §403 (Act 6), this notice is also given to you pursuant to the terms of your mortgage obligation. The dollar amount of mortgages covered by Act 6 may be found in the Pennsylvania Bulletin. VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND REGULAR MAIL NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE/LIEN AGAINST REAL PROPERTY. SENDER:. COMPLETE THIS SECTI C OMPLETE . D ELIVERY • Complete items 1, 2, and 3. Also complete A. Stgnatu item 4 if Restricted Delivery is desired. • Print your name and address on the reverse X A9 t so that we can return the card to you. ressee • OWWhis Card to the back of the mailpiece, B. Received by (Printed Name) C. Date of Delivery or Oh" affront if space permits. 1: 4rtiadressed to: D. Is delivery address different from Item 17 ❑ Yes If YES, enter delivery address below: 0 No Oit O.4 -in-(erO 3. Service Type �✓ t 0 Certified Mail 0 Express Mail O Registered ❑ Retum Receipt for Merchandise L9 f ❑ Insured Mail ❑ C.O.D. 2. Article Number 4. Restricted Delivery? (Extra Fee) Yes (Transfer from service label _ ? 010 3090 0 0 0 2 8188 5426 PS Form 3811, February 2004 Domestic Retum Receipt 10 2595.02 -M -1540 C OMPLETE • CO MPLETE • Complete items 1, 2, and 3. Also complete A. Signat item 4. if Restricted Delivery is desired. • Print your name and address on the reverse X ❑Addressee so that we can return the card to you. ame) C. Date of Delivery • Attach this card to the back of the maiipiece, B. Received by (Prin d N or on the front if space permits. 1. Article Addressed to: D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No i`�5� �i �'t�� S�r ilfl �S �r✓� i io D� l 3. Service Type l G J) J r V� 13 3. Mail 11 Express Mail J � G 17 Registered ❑ Return Receipt for Merchandise l 0 Insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (rransfer from service iabei) 7 010 3090 0 0 0 2 8188 5433 PS Four, 3811 February 2004 Domestic Return Receipt 102595 -02 -M -1540 Po Serv Po stal • , • • • , RECEI ( Domestic Mail • No Insurance Coverage Provided m ( Domestic • No Insurance Coverage P Ln For delivery co FIC . � OFFICIA m CO , rq Postage $ � Postage $ co Certified Fee - Certified Fee Postmark ru rk� C3 Return Receipt Fee Here O Return Receipt Fee o e r O (Endorsement Required) r1� O (Endorsement Required) re Restricted Delivery Fee �!" O Restricted Delivery Fee O (Endorsement Required) O (Endorsement Required) v Er Er O Total Postage & Fees I s O Total Postage & Fees Is M Sent To I q C:3 'a ------- ---------- -- - - ---- - --- ------------ 1 �J 4 !_ /n C . ........... .......... r entTo n/� O Street, Apt. No.: N° wf2 - - Akn- - ------ LX� _ �. �! / (t!! [� or PO Box No. r , j/ O Street, Apt . .; y Ci � 155 ,� // �/��Gj( �� N or PO Box NO. �` fsJ•�LtY ' r }-�" 6� 1a rf � 1 / RS Form r rr. See Reverse for Instructions PS Fo 3800 August 2006- ( � 7 U.S. POSTAGE>> PITNEY BOWES U.S. POSTAGE > >PITNEY BOWES ' r $001.15 P ZIP 190466 001. ,p 1 5 r _ , ®® 02 IVN ZIP 19046 $ 001 f '. 0001371685 JUL. 02. 2012 r ' r r - ..;'�'; 02 ON 0001371685JUL 02, 2012. C7 r r O P r Z # ca z C� -r o ` U w �' C? ( Q z I h` o ° K O 1 .o p ^a le. P4 tr�� 1 u' o Gy 1V� y i Z " r o o �� W w �Q H V z H N p Q. G _ 0 ti C3 g o > 2Z Z a Z m U W O E `^ Z O LLI of Z) Q o .i ti J O Z o 0 y w O v i 000 FQ o w LL ° r r tl1LL m WO v Qp a wo m M O �w ' a M }O O ` li O M 0 EL -TI C:: :::> FORM 1 'GP� LA.1 a Household Finance Consumer Discount n �' �= f f IN THE COURT OF COMMON PLEAS OF .� Company CUMBERLAND COUNTY, PENNSYLVANIA C Plaintiff(s) � CD V5. Tomas A. Quintero and Dawn M.� Alexander - Quintero 1 �V 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 the 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. RV ectfullysub d: 6/27/13 Date Sior Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMERIPRIMARYAPPLICAVON 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 BORRO Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? INF ORMArIO 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 and 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: Asset 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. 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 payinsl EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and 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? 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: AUTH I/We, , authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /we understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed FORM 3 Household Finance Consumer IN THE COURT OF COMMON PLEAS OF Discount Company CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Tomas A. Quintero and Dawn M. Alexander - Quintero 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 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 Household Finance Consumer DISCOUnt Company : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Tomas A. Quintero and Dawn M. Alexander - Quintero 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 (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the Plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties in writing or at the discretion. of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 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 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. S. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f;L,E0-QF' 1C Sheriff ;,;-. .�Hr ROTH i4€;1'#,: 1' Jody S Smith Chief Deputy ; E . Richard W Stewart " GUMBERLAND COBTY Solicitor OF PENNSYLVANIA Household Finance Consumer Discount Company Case Number vs Tomas A Quintero (et al.) 2013-3829 SHERIFF'S RETURN OF SERVICE 07/05/2013 05:20 PM-Deputy Valerie Weary, 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 Tomas Quintero, Husband,who accepted as "Adult Person in Charge"for Dawn M Alexander-Quintero at 1558 Boiling Springs Road, Monroe Township, Boiling Springs, PA 17007. VALERIE WEARY, DEPUTY 07/05/2013 05:20 PM-Deputy Valerie Weary, 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:Tomas A Quintero at 1558 Boiling Springs Road, Monroe Township, Carlisle, PA 17007. VALERIE WEARY, DEPUTY SHERIFF COST: $50.78 SO ANSWERS, 6�� xlla�._�_ July 08, 2013 RbNW R ANDERSON, SHERIFF tcl^ountySuito Sheriff,Teleosott,Inc, STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) 1,01 10 TAW, °, CHRISTINA C.VIOLA,ESQUIRE(308909) *? Ilq ANDREW J.MARLEY(312314) At' STERN&EISENBERG,PC bIFl1,1VI) �� 1 1581 MAIN STREET,SUITE 200 PEN ' WARRINGTON,PENNSYLVANIA 18976 V ���A TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action Number: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Tomas A. Quintero and Dawn M. Alexander-Quintero, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty(20) days of service thereof. PRINCIPALBALANCE...............................................................................$177,686.93 INTEREST accrued thru 06/10/2013 of .......................................................$20,318.32 Interest after 06/10/2013 shall accrue at the per diem rate of$36.51.) ADVANCESFOR TAXES...........................................................................$4,265.49 ADVANCES FOR HAZARD INSURANCE ...............................................$2,444.78 LESS SUSPENSE(If any).............................................................................($1,049.87) Sub-Total Through Date of Complaint....................................................$203,665.65 ACCRUED INTEREST after 06/10/2013 shall accrue at the per diem rate of$36.51 to August 12, 2013.........................................$2,300.13 Q,, I b.5©Pict ss�s� J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx c/LIP(� C� � c� rrla,led TOTAL DUE THROUGH DATE OF REQUEST FORJUDGMENT.........................................................................................$205,965.78 STE & EN RG, PC BY: ST BERG ,EISEN ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE El M. GARZA, ESQUIRE .., CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff J:\Taylor\Sales\Cumber land\HSBC.Quintero.8.13.docx STEVEN K.EISENBERG,ESQUIRE(75736) st. M.TROY FREEDMAN,ESQUIRE(85165) I -tai�3 r' LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE 308909 4l ANDREW J.MARLEY(312314) r^ P. STERN&EISENBERG,PC i �r n� / 14ij f 1581 MAIN STREET,SUITE 200 f ��rai s 1y'� WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-81111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander-Quintero Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF BUCKS I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief,Defendants': 1. Last-known address is: 1558 Boiling Springs Road, Carlisle,PA 17007-9690 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers'Civil Relief Act of 1940, as amended. STE N IS LG,TM�+ v imBY: O R AAL SEAL x ❑ ST K. ty p1ANE TURANO,Notarl ESQUIRE °n T'9" October 3�4 ❑ M. TROY FREEDMAN,ESQUIRE Wartin9t ❑ JACQUELINE F. McNALLY,ESQUIRE CtMACOn1rnISS�Or�ExP ❑ LESLIE J. RASE,ESQUIRE ❑ LEN M. GARZA,ESQUIRE ,Z—CHRISTINA C. VIOLA,ESQUIRE ❑ ANDREW J. MARLEY,ESQUIRE Attorney for Plaintiff SwoPM,subscr' ed before me this y of 2p� Notary Public J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx Department of Defense Manpower Data Center Results as of:Aug-13.201312:14;02 SCRA 3.0 Status Report Pursuant to Servicememb ers Civil ReHef Act. Last Name: QUINTERO First Name: TOMAS Middle Name: Active Duty Status As Of: Aug-13-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA _ No• NA This response reflects the individual active duty siatus based n the Active Duty Status Date Left Active Duty Within 367 Days of Active duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA i NA •� =i i ;r,' Nd' .,. r NA This response reflects where the individual left acl ve.duty status within 367 days preceding the,Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA'• '� ,ti* •f,,-...� rNo NA This response reflects whether the individual a histheri"nit has received e y notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data-Center,-based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 4W2, A Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 �u.^�o�,smm� Department of Defense Manpower Data Center Results-- SCRA 3.0 Status ReTort Pursuant to Servicemembers Civil Relief Act Last Name: QUINTERO First Name: DAWN Middle Name: Active Duty Status As Of: Aug-13-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component This response reflects eindividuals'a siatus based.'nthe A dve'Du`ty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component This response reflects where the individual left act;e du6`status vvithi�36i;a prece�in" v" The Member or HisfHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date status Service Component This response reflects whether the indiVidual'or histher'uhit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data,Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY mvINDIVIDUAL. " ot ��_�r = Mary M.snavely-o/mm.Director Department m Defense'Manpower Data Center *ouo Mark Center Drive,Suite V4ers Arlington,v^20000 STERN&EISENBERG PC 1581 MAIN STREET,SurrE 200 WARRINGTON,PA 18976 TELEPHONE_:(215)572-8111 FAcsimILE:(215)572-5025 (COUNSEL FOR PL.AINTLFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Household Finance Consumer Discount Company (Plaintiff) Docket#: 13-3829- Civil V. Tomas A. Quintero and Dawn M.Alexander-Quintero TEN DAY NOTICE (Defendant(s)) NOTICIF PU ISUANT-TO Pa.R.C.P. 237.1 TO: DaNvn M.Alexander-Quintero 1558 Boiling Springs.Road Carlisle,PA 17007-9690 Date of Notice: Friday,July 26,2013 Ir11I'OA7ANT NOTICis YOU A.RE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER. A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH T.HE COURT YOUR. DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM TIIE DATE OF TH1S NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT :RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER. A. ONCE. IF YO DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE. THE FOLLOWING OFFICE TO .FIN1:) OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE T14E OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITII :INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HTR.E.A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER.LEGAL SERVICES TO ELIGIBLE PERSONS AT A R.EDUCBD FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford.Street Carlisle,PA 17013 800-990-9108 717-249-3166 STERN&EISENBERQ PC By: z � Z`Attorney for Plaintiff z k\Stephanie L\Ten Days\HSBC_Quintera.docx STERN&EISENBERG PC 1581 MAtN STREET,SLJITE 200 WARRINGTON,PA 18976 TELEPHONE:(2157'572-8'1 11 F AcsimiLE:(215)572-5025 (COUNSEL FOR PLAINT i"FF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUN'T'Y Household Finance Consumer Discount Company (Plaintiff) Docket#: 13-3829- Civil v. Tomas A. Quintero and Dawn N/1.Alexander-Quintero TEN DAY N0110E (Defendant(s)) NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Tomas A. Quintero 1558 Boiling Springs.Road Carlisle,PA 17007-9690 Date of Notice: Friday,July 26,2013 I)VIPOR T'ANT 1 NOT'I`CE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: 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 TIES OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland.County Bar Association 32 South Bedford Street Carlisle,PA 17013 800-990-9108 717-249-3166 STERN&EISENBRG,PC a �, By: - _ � - Attorney for Plaintiff - ; JAStephanie L\Ten Days\HSBC_Quintero.docx STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(5 8365) CHRISTINA C.VIOLA,ESQUIRE(308909) ANDREW J.MARLEY(312314) STERN&EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs .Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. ST & E ERG, PC tj BY: ❑ E BERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(851.65) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) ANDREW J.MARLEY(312314) STERN&EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Household Finance Consumer Discount Company 2929 Walden Avenue Depew, NY 14043 (Plaintiff) Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle, PA 17007-9690 (Defendant(s)) S E . BEN RG, PC BY: ❑ EN K. ISENB RG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE --®'CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff J:\Taylor\Sales\Cumberiand\IiSBC.Quintero.8.13.docx STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) ANDREW J.MARLEY(312314) STERN&EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. 10VE ENB I PC BY: . SENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE CHRISTINA C. VIOLA, ESQUIRE ❑ ANDREW J,. MARLEY, ESQUIRE Attorney for Plaintiff J:\Taylor\Sales\Cumberiand\HSBC.Quintero.8.13.docx 1 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION P AECIPE FOR WRIT OF EXECUTION Household Finance Uonsumer Discount Company ❑Confessed Judgment Plaintiff ❑Other Tomas A. Quintero and File No. 13-3829 Dawn M. Alexander-Quintero Amount Due $205,965.78 Defendant Interest from 8/12/13 @ the...per diem rate of until ju gment paid in f Address: Atty's Comm 1558 Boiling Spings Road Costs Carlisle , PA 17007 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account'based on a confession of judgment, but if it does, it is based on the appropriateroriginal proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 ofct974R amended. m ..: " Issue writ of execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs,upon the following described property of the defendant(s) �, See full legal description attached 51: PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County,for debt, interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) 1558 Boiling Springs Road, Carlisle, PA 17007 and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). ❑ (Indicate)Index this writ against the garnishee(s)as a lis tpen a airnst al estate of the defendant(s)described in the attached exhibit. Date 8/12/13 Signature:Print Name: Stlna 'Viola -09 Address: 1581 Main Street. Suite 200 67,16` caz' � Warrington, PA 18976 g Attorney for: Plaintiff ? 7s l/ // Telephone: 215-572-8111 (P S"� I� /� Supreme Court ID No: 308909 . So LL C' &SS jsg _ ALL THAT CERTAIN tract of ground situate in Monroe Township, Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern right of way line of State Highway Route No. 174 at the dividing line between Lot Nos. 7 and 8 on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 19 degrees 29 minutes 30 seconds West, a distance of 150 feet to a point in line of land now or formerly of James R. Compton and Elmer F. Kester; thence along said lands now or formerly of Compton and Kester, by a line curving to the right and having a radius of 3044.93 feet, an arc distance of 106.72 feet to a point; thence still be lands now or formerly of James R. Compton and wife, South 13 degrees 5 minutes East, a distance of 150 feet to a point on the aforesaid northern right of way line; thence by said northern right of way in a westerly direction on a line curving to the left and having a radius of 2894.93 feet an arc distance of 100 feet to a point; the PLACE OF BEGINNING. The above described lot of ground is all of Lot No. 8 as shown on the Plan of Lots prepared by D.P. Raffensperger,Registered Surveyor dated June 8, 1955. UNDER AND SUBJECT to building and use restrictions as recorded in prior deeds. BEING the same premises which John A. Vorchak and Catherine A. Vorchak, husband and wife by Deed dated April 8, 2001 and recorded April 19, 2001 in the Office of the Recorder of Deeds for the County of Cumberland in Deed Book 243 Page 57 as Instrument No. 2001-01.0905, granted and conveyed unto Tomas A. Quintero and Dawn M.Alexander-Quintero,husband and wife, in fee. J:l Tayl orl SaleslCumberland\HSBC.Quintero.8.13.docx STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) f ANDREW J.MARLEY(312314) l�j� 1 STERN&EISENBERG,PC R 1, .. 1581 MAIN STREET,SUITE 200 QL"N WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111. FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1558 Boiling Springs Road, Carlisle,PA 17007 1. Name and address of Owner(s) or Reputed Owner(s): Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle, PA 17007-9690 2. Name and address of Defendant(s) in the judgment: Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle,PA 17007-9690 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: FIA Card Services, N.A. 655 Papermill Rd, Newark, DE 19711 J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx FIA Card Services co Apothaker&Associates 520 Fellowship Road Mount Laurel, NJ 08054 Dell Financial Services, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Domestic Relations Tax Claim Bureau Cumberland County Cumberland County Courthouse 13 North Hanover Street One Courthouse Street Carlisle, PA 17013 Carlisle, PA 17013 Tenant(s)/Occupant(s) 1558 Boiling Springs Road Carlisle, PA, 17007. J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: August , 2013 n E JEI B RG, PC BY: El S EN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE HRISTINA C. VIOLA, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Sworn t subs ribed before me this 3 Day of , 201 Notary Public MONyyEAl.TH OR pZHNq%VAN1A NOTARIAL SEAL DIANE J.TURANO,Notary public Warrington Tw' 0atobet 31,200 commission Exp J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) .E ANDREW J.MARLEY(312314) STERN&EISENBERG,PC tIk tC � 1581 MAW STREET,SUITE 200 PE hd }, , ! 1 ' WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company V. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle, PA 17007-9690 Your real estate at 1558 Boiling Springs Road , Carlisle, PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday, December 4, 2013 at 10:00 A.M. , at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $205,965.78 obtained by Household against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stern &Eisenberg, PC the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern &Eisenberg PC, telephone (215) 572-8111. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. J:\Taylor\Sales\Cumberiand\HSBC.Quintero.8.13.docx You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern &Eisenberg PC, telephone(215) 572-8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern &Eisenberg PC, telephone(215).572-8111. 4. If the amount due from the buyer is not paid,to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J.\Taylor\Sales\Cumberland\HS BC.Quintero.8.l 3.docx w ALL THAT CERTAIN tract of ground situate in Monroe Township, Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern right of way line of State Highway Route No. 174 at the dividing line between Lot Nos. 7 and 8 on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 19 degrees 29 minutes 30 seconds West, a distance of 150 feet to a point in line of land now or formerly of James R. Compton and Elmer F. Kester; thence along said lands now or formerly of Compton and Kester, by a line curving to the right and having a radius of 3044.93 feet, an arc distance of 106.72 feet to a point; thence still be lands now or formerly of James R. Compton and wife, South 13 degrees 5 minutes East, a distance of 150 feet to a point on the aforesaid northern right of way line; thence by said northern right of way in a westerly direction on a line curving to the left and having a radius of 2894.93 feet an arc distance of 100 feet to a point;the PLACE OF BEGINNING. The above described lot of ground is all of Lot No. 8 as shown on the Plan of Lots prepared by D.P. Raffensperger,Registered Surveyor dated June 8, 1955. UNDER AND SUBJECT to building and use restrictions as recorded in prior deeds. BEING the same premises which John A. Vorchak and Catherine A. Vorchak, husband and wife by Deed dated April 8, 2001 and recorded April 19, 2001 in the Office of the Recorder of Deeds for the County of Cumberland in Deed Book 243 Page 57 as Instrument No. 2001-010905, granted and conveyed unto Tomas A.Quintero and Dawn M. Alexander-Quintero,husband and wife, in fee. J:\TaylorNSates\Cumberland\HSBC.Quintero.8.13.docx WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2013-3829 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff(s) From TOMAS A. QUINTERO,DAWN M.ALEXANDER-QUINTERO (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishees)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $205,965.78 L.L.: $.50 Interest FROM 08/12/2013 @ THE PER DIEM RATE OF$36.51 UNTIL JUDGMENT IS PAID IN FULL Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.53 Other Costs: Plaintiff Paid: Date: August 15,2013 David D. Bue 1,Prothonota (Seal) Deputy REQUESTING PARTY: Name: CHRISTINA C.VIOLA,ESQUIRE Address: STERN& EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PA 18976 Attorney for:PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No.308909 FORM 3 - f CD Household Finance Consumer IN THE COURT OF COMMON PLq t ' DISCOUnt Company CUMBERLAND COUNTY,PENNSY I@IA Z 9 ry Plaintiff F s) yC �;- �C•: �- VS. Tomas A. Quintero and Dawn M. Alexander-Quintero Defendant(s) ^2 c � Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated T .� �� 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 statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 7 Signature of D Lae t's C unsel/Appointed Date Legal Represe . %6 Z-7 Signature of Defendant Date v Signature of Defendant Date HOUSEHOLD FINANCE IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION � --2 NO. 13-3829 CIVIL zr : TOMAS A. QUINTERO and <> DAWN M. ALEXANDER- QUINTERO, =r. ° ' Defendants x c= CASE MANAGEMENT ORDER -' AND NOW, this S a day of September, 2013,the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on Q _ a� ;P,64 5_, at //,'00 a ,m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 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, Kevin ess, P.J. ,. drew Marley, Esquire 1617 JFK Blvd., Suite 1400 One Penn Center Philadelphia, PA 19103 For the Plaintiff Lorin Snyder, Esquire 129 South Pitt Street Carlisle, PA 17013 For the Defendants :rlm 1 9NO HOUSEHOLD FINANCE : IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION : NO. 13-3829 CIVIL TOMAS A. QUINTERO and • DAWN M. ALEXANDER- QUINTERO, • • Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this ' ' day of October, 2013, at the request of counsel, the conciliation conference scheduled for October 24, 2013, is continued to Friday,November 8, 2013, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin • . ess, P. J. Zndrew Marley, Esquire 1617 JFK Blvd., Suite 1400 One Penn Center Philadelphia, PA 19103 For the Plaintiff Lorin Snyder, Esquire 129 South Pitt Street Carlisle, PA 17013 �" For the Defendants ? Q ' • co - r 2'°' /j 'CS �T /0102 HOUSEHOLD FINANCE • IN THE COURT OF COMMON PLEAS OF CONSUMER DICOUNT CO., • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. • CIVIL ACTION TOMAS A. QUINTERO and • NO. 13-3829 CIVIL DAWN M. ALEXANDER-QUINTERO • Defendants CERTIFICATE OF SERVICE I hereby certify that I served the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) upon Christina C. Viola, Esquire, counsel for Plaintiff, via electronic mail on the Eighteenth day of October, 2013, from Carlisle, Pennsylvania, addressed as follows: cviola @sterneisenberg.com TURO ROBINSON Lorin A. ` yder, .quire 129 So h Pitt Stre=t Carlisle PA 17013 (717) 245-9688 Counsel • D- - dants L 2 Fr j --- r--fix -- L- 77-r`::' HOUSEHOLD FINANCE • IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • • vs. • CIVIL ACTION : NO. 13-3829 CIVIL TOMAS A. QUINTERO and DAWN M. ALEXANDER- • QUINTERO, • Defendants • IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held November 8, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Lorin Snyder, Esquire, counsel for the defendants. Certain documents remain to be submitted. Same will be forthcoming within fifteen(15) days. A continued conciliation conference is set by order of even date herewith. ORDER AND NOW, this 8th day of November, 2013, continued conciliation conference is set for Friday, January 10, 2014, at 2:00 p.m. in Chambers of the undersigned. BY THE COURT, Kevin ess, P. J. Nathan Wolf, Esquire c ' 10 West High Street -o a Carlisle, PA 17013 rn m C) For the Plaintiff ? :, r-271 Orin Snyder, Esquire � ' -0 _r 129 South Pitt Street Carlisle, PA 17013 r f For the Defendants ici.c.L -{ ;;, /1 /3//3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 'H;� r2},--,:o atixtitr Ot Catatat ,t7jr Jody S Smith Chief Deputy r( ' I , Richard W Stewart �j% �� � � Solicitor oFFicE OFTHE$KERIFF • PENNSYLVANIA Household Finance Consumer Discount Company vs. Case Number Tomas A Quintero (et al.) 2013-3829 SHERIFF'S RETURN OF SERVICE 09/23/2013 02:45 PM -Deputy Jamie DiMartle, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1558 Boiling Springs Road, Carlisle, PA 17007, Cumberland County. 09/23/2013 02:45 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Tomas A. Quintero, Husband, who accepted as"Adult Person in Charge"for Dawn M Alexander-Quintero at 1558 Boiling Springs Road, Monroe Township, Boiling Springs, PA 17007, Cumberland County. 09/23/2013 02:45 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Tomas A Quintero at 1558 Boiling Springs Road, Monroe Township, Carlisle, PA 17007, Cumberland County. 09/30/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. • SHERIFF COST: $142.79 SO ANSWERS, December 09, 2013 RONR ANDERSON, SHERIFF • � .c9..0 • CD, aw9 - - a1c33? (c)CountySuite Sheriff,Teleosoft,Inc. STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) ANDREW J.MARLEY(312314) STERN&EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1558 Boiling Springs Road, Carlisle,PA 17007 1. Name and address of Owner(s) or Reputed Owner(s): Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle, PA 17007-9690 2. Name and address of Defendant(s) in the judgment: Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle, PA 17007-9690 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: FIA Card Services, N.A. 655 Papermill Rd, Newark, DE 19711 J:\Taylor\Sales\Cumberland\HS BC.Quintero.8.13.docx J FIA Card Services co Apothaker&Associates 520 Fellowship Road Mount Laurel, NJ 08054 Dell Financial Services, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Domestic Relations Tax Claim Bureau Cumberland County Cumberland County Courthouse 13 North Hanover Street One Courthouse Street Carlisle, PA 17013 Carlisle, PA 17013 Tenant(s)/Occupant(s) 1558 Boiling Springs Road Carlisle, PA, 17007. J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: August , 2013 3 • EI` it B RG, PC 1 BY: . v f ❑ S' EN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ LESLIE J. RASE, ESQUIRE ❑ LEN M. GARZA, ESQUIRE HRISTINA C. VIOLA, ESQUIRE • ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Sworn tratrx1 subs ribed before me this ) Day of J. , 2013. Notary Public • COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DIANE J.TURANO,Notary Public Warrington Twp.,Bucks County Commission Expires October 31,2014 _ J:\Taylor\Sales\Cumberland\HS B C.Quintero.8.l3.docx r - 1 STEVEN K.EISENBERG,ESQUIRE(75736) M.TROY FREEDMAN,ESQUIRE(85165) LESLIE J.RASE,ESQUIRE(58365) CHRISTINA C.VIOLA,ESQUIRE(308909) ANDREW J.MARLEY(312314) STERN&EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE:(215)572-8111 FACSIMILE:(215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Household Finance Consumer Discount Company v. Civil Action: 13-3829 Tomas A. Quintero and Dawn M. Alexander- Quintero MORTGAGE FORECLOSURE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Tomas A. Quintero and Dawn M. Alexander-Quintero 1558 Boiling Springs Road Carlisle,PA 17007-9690 Your real estate at 1558 Boiling Springs Road , Carlisle, PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday, December 4, 2013 at 10:00 A.M. , at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $205,965.78 obtained by Household against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stem&Eisenberg, PC the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern &Eisenberg PC, telephone(215) 572-8111. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFFS SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern &Eisenberg PC, telephone (215) 572-8111. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call Stern &Eisenberg PC, telephone(215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Taylor\Sales\Cumberland\HSBC.Quintero.8.13.docx 1 ALL THAT CERTAIN tract of ground situate in Monroe Township, Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern right of way line of State Highway Route No. 174 at the dividing line between Lot Nos. 7 and 8 on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 19 degrees 29 minutes 30 seconds West, a distance of 150 feet to a point in line of land now or formerly of James R. Compton and Elmer F. Kester;thence along said lands now or formerly of Compton and Kester, by a line curving to the right and having a radius of 3044.93 feet, an arc distance of 106.72 feet to a point; thence still be lands now or formerly of James R. Compton and wife, South 13 degrees 5 minutes East, a distance of 150 feet to a point on the aforesaid northern right of way line; thence by said northern right of way in a westerly direction on a line curving to the left and having a radius of 2894.93 feet an arc distance of 100 feet to a point; the PLACE OF BEGINNING. The above described lot of ground is all of Lot No. 8 as shown on the Plan of Lots prepared by D.P. Raffensperger,Registered Surveyor dated June 8, 1955. UNDER AND SUBJECT to building and use restrictions as recorded in prior deeds. BEING the same premises which John A. Vorchak and Catherine A. Vorchak, husband and wife by Deed dated April 8, 2001 and recorded April 19,2001 in the Office of the Recorder of Deeds for the County of Cumberland in Deed Book 243 Page 57 as Instrument No.2001-010905, granted and conveyed unto Tomas A.Quintero and Dawn M.Alexander-Quintero,husband and wife, in fee. J:\Taylor\Sales\Cumber land\HS BC.Quintero.8.l3.docx WRIT OF EXECUTION and/or ATTACHMENT • COMMONWEALTH OF PENNSYLVANIA) NO. 2013-3829 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff(s) From TOMAS A.QUINTERO,DAWN M. ALEXANDER-QUINTERO (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due:$205,965.78 L.L.: 5.50 Interest FROM 08/12/2013 @ THE PER DIEM RATE OF$36.51 UNTIL JUDGMENT IS PAID IN FULL Atty's Comm: Due Prothy:$2.25 Atty Paid:$199.53 Other Costs: Plaintiff Paid: Date: August 15,2013 David D. Buell,Prothonotary (Seal) - �/ ice_ Deputy REQUESTING PARTY: Name: CHRISTINA C.VIOLA,ESQUIRE Address: STERN& EISENBERG,PC 1581 MAIN STREET,SUITE 200 WARRINGTON,PA 18976 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 308909 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This__di day of 20 Prothonotary • On August 16, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 1558 Boiling Springs Road, Carlisle, as Exhibit "A" filed with this „Q writ and by this Reference incorporated herein. Date: August 16, 2013 By: Real Estate Coordinator w�. HOUSEHOLD FINANCE • IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • vs. • CIVIL ACTION • NO. 13-3829 CIVIL TOMAS A. QUINTERO and • DAWN M. ALEXANDER- • QUINTERO, • Defendants • IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 10 day of January, 2014, on agreement of counsel, it is ordered and directed that all outstanding documents will be furnished to the plaintiff within fourteen(14) days. Within seven (7) days, the defendants will notify the plaintiff as to whether they have the funds necessary to pay a required down payment. Continued conciliation conference is set for Friday, February 21, 2014, at 3:15 p.m. in Chambers of the undersigned. BY THE COURT, • - 4. Kevi A Hess, P. . athan Wolf, Esquire 10 West High Street -";1-" Carlisle, PA 17013 FT: _. For the Plaintiff -- Lorin Snyder, Esquire c 129 South Pitt Street c>> Carlisle, PA 17013 For the Defendants :rim ELS ir&i(irks // nt HOUSEHOLD FINANCE IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION NO. 13-3829 CIVIL TOMAS A. QUINTERO and DAWN M. ALEXANDER- QUINTERO, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this z z day of January, 2014, continued conciliation conference set for February 21, 2014, is continued to Wednesday, February 26, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi A. Hess, P. J. -,' Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff Lorin Snyder, Esquire 129 South Pitt Street °_- Carlisle, PA 17013 C— r*$i For the Defendants -v Gnr- N =6 .tD C, t :rlm sQ CJ LL _'ia mcs ANDREW J. MARLEY, ESQUIRE l'HE P E TH O NO l f"\i V' STERN &EISENBERG PC 1581 Main Street, Suite 200 P � The Shops at Valley Square CUMBERLAND COUNTY Warrington, PA 18976 PENNSYLVANIA (215) 572-8111 I.D. #312314 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION—LAW Household Finance Consumer Discount Civil Action Number: 13-3829 Civil Company' v. MORTGAGE FORECLOSURE Tomas A. Quintero and Dawn M. Alexander- Quintero Defendant(s) PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 Kindly substitute LSF8 Master Participation Trust, as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: An assignment transferring the mortgage to LSF8 Master Participation Trust, is in the process of being recorded in the Office of the Recorder of Deeds for Cumberland County Kindly amend the information on the docket accordingly. STERN &EIS -► ,:/C BY: 11; I ' WJ. A'.' EY Attorney for 'la' tiff 2/17/14 HOUSEHOLD FINANCE IN THE COURT OF COMMON PLEAS OF CONSUMER DISCOUNT CO., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION cD --n r: 3;7� 00 NO. 13-3829 CIVILj� TOMAS A. QUINTERO and DAWN M. ALEXANDER- C) QUINTERO, ' , c c r� Defendants ,, IN RE: CONCILIATION CONFERENCE MEMORANDUM AND ORDER Present at a conciliation conference held February 26, 2014, were Nathan Wolf, Esquire, attorney for the plaintiff, and Lorin Snyder, Esquire, attorney for the homeowners. It appears that the servicer of the loan has changed in this case and is now a company by the name of Caliber Home Loan. They are willing to entertain a new application. Documentation will be forthcoming within fourteen (14) days and a continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this Z l• ` day of February, 2014, continued conciliation conference is set for Wednesday, April 16, 2014, at 2:45 p.m. in Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. i/ Nathan Wolf, Esquire For the Plaintiff ./ Lorin Snyder, Esquire For the Defendants a LL 7// / Y HOUSEHOLD FINANCE CONSUMER DISCOUNT CO., Plaintiff vs. TOMAS A. QUINTERO and DAWN M. ALEXANDER- QUINTERO, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION : NO. 13 -3829 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this !6 day of April, 2014, following conciliation conference, it appearing that there continues to be certain outstanding documents, not the fault of the defendants, it is directed that the remaining documents be submitted within fourteen (14) days and a continued conciliation conference is set for Friday, May 23, 2014, at 1:45 p.m. in Chambers of the undersigned. Lathan Wolf, Esquire For the Plaintiff Daniel Puskar, Esquire ` , For the Defendants rte' rn Z u) r-- rz zo BY THE COURT, HOUSEHOLD FINANCE CONSUMER DISCOUNT CO., Plaintiff vs. TOMAS A. QUINTERO and DAWN M. ALEXANDER- QUINTERO, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION : NO. 13-3829 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 2 2 ` day of May, 2014, at the request of the parties, the conciliation conference set for May 23, 2014, is continued to Friday, July 11, 2014, at 1:30 p.m. in Chambers of the undersigned. Ka -than Wolf, Esquire For the Plaintiff XDaniel Puskar, Esquire For the Defendants Xnielle Savoni Stern & Eisenberg PC 1581 Main Street, Suite 200 The Shops at Valley Square Warrington, PA 19876 :rim C C• i £.SSi la Z,P BY THE COURT, Kevin . Hess, P. J. HOUSEHOLD FINANCE CONSUMER DISCOUNT CO., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. TOMAS A. QUINTERO and DAWN M. ALEXANDER- QUINTERO, Defendants CIVIL ACTION NO. 13-3829 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this I Y day of July, 2014, on agreement of the parties, the conciliation conference herein is continued to Friday, September 19, 2014, at 2:30 p.m. in Chambers of the undersigned. Xathan Wolf, Esquire For the Plaintiff ✓Daniel Puskar, Esquire For the Defendants :rim ylies7 /40V • BY THE COURT, Kevin Hess, P. J. rri C° -;c::" • HOUSEHOLD FINANCE CONSUMER DISCOUNT CO., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 13-3829 CIVIL TOMAS A. QUINTERO and DAWN M. ALEXANDER- QUINTERO, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 17th day of September, 2014, upon agreement of both parties, the conciliation conference scheduled for Friday, September 19, 2014, at 2:30 p.m. is hereby cancelled. Nathan Wolf, Esquire For the Plaintiff Daniel Puskar, Esquire For the Defendants :rlm Colo I es. /17.4 Lk. BY THE COURT, Kevin Al Hess, P. J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW EDWARD J. MCKEE, ESQ. STERN & EISENBERG, PC The Shops at Valley Square 1581 Main Street, Suite 200 Warrington, PA 18976 215) 572-8111 I.D. #316721 LSF8 Master Participation Trust Plaintiff v. Tomas A. Quintero and Dawn M. Alexander -Quintero Defendant(s) Civil Action Number: 13-3829 MORTGAGE FORECLOSURE PRAECIPE TO VACATE JUDGMENT WITHOUT PREJUDICE C) TO THE PROTHONOTARY: Kindly mark the judgment entered in favor of the Plaintiff and against the Defendant(s) in the above -captioned matter "vacated without prejudice" upon payment of your costs only STERN : ISENBERG, PC BY: Dated: 10/24/2014 EDWARD J. MCKEE, E Attorney for Plaintiff Q. 0q.sLpS ally CilL-44 tga I 3iatoga IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW EDWARD J. MCKEE, ESQ. STERN & EISENBERG, PC The Shops at Valley Square 1581 Main Street, Suite 200 Warrington, PA 18976 215) 572-8111 I.D. #316721 LSF8 Master Participation Trust Plaintiff v. Tomas A. Quintero and Dawn M. Alexander -Quintero Defendant(s) Civil Action Number: 13-3829 MORTGAGE FORECLOSURE PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE To the Prothonotary: Kindly mark the above captioned matter as settled, discontinued and ended, without prejudice, upon payment of your costs only. Dated: 10/24/2014 STERN EISENBERG, PC BY: EDWARD J. MCKEE, ESQ. Attorney for Plaintiff