The URL can be used to link to this page

Home My WebLink About13-4982 Supreme Court of Pennsyl -vania Cout 1 of Common Pleas t OvEi � ' For Frortionatarr LUs,- On r: 1 \11 O' Sheet Curnberland� C ounty Da�EtNo: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service of leadin s or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR TINA M. OLEWILER BY MERGER TO NATIONAL CITY MORTGAGE, A T DIVISION OF NATIONAL CITY BANK I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. . TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other 1E mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste B ❑Other ❑Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical. ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 W W W.KATi,i,A WGROiTP.COM PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN THE COURT OF COMMON PLEAS BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK OF Cumberland COUNTY 3232 Newmark Drive Miamisburg, OH 45342 CIVIL ACTION - LAW Plaintiff TINA M. OLEWILER vs. ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) „� y U, CTION' MORTGAGE LI 5544 Moreland Court Mechanicsburg, PA 17055 a M-� IP Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 170131 s G7 Os r LEGAL SERVICES INC , - 8 Irvine Row 0 3 • � = CZ5 C* Carlisle, PA 17013 C It �cl s� ? (� 5 t ' 717 - 243 -9400 / - . �� ws < AVISO r[ Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades a otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httl2://www.Dhfa.org/consumers/homeowners/real.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 -413 -2311 or via email at homeretention@kmllaw roup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 122601FC. Para informacion en espanol puede communicarse con Loretta. al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK, 3232 Newmark Drive, Miamisburg, OH 45342. 2. The name(s) and address(es) of the Defendant(s) is /are TINA M. OLEWILER, 5544 Moreland Court, Mechanicsburg, PA 17055, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 31, 2008 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE A DIVISION OF NATION CITY BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 05, 2008 as Instrument # 200803607. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of 07/01/2013: Principal Balance ............................... ............................... ....................$137,536.11 Interest from 01/01/2013 to 07/01/2013 at 5.8750 % .......... ......................$4,040.10 Monthly Interest $673.35 LateCharges ......................................... ............................... ........................$175.88 ProRata MIP ......................................... ............................... ........................$111.84 Fees........................................................ ............................... .........................$33.00 AppraisalCost ....................................... ............................... ........................$175.00 PropertyInspection ......................................................... ................ $12.00 $142,083.93 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $142,083.93, together with monthly interest at $673.35, and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the ortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By= KML LAW G b , �. . Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I Danielle Pegues , as a A% thnrized Signer of PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, and the facts set forth in 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 of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date: ` n PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION NAME: Danielle Pegues TITLE: ,l,tthorized Signer #122601FC - TINA M. OLEWILER 5544 Moreland Court Mechanicsburg, PA 17055 �E.xhi6itA All that certain condominium unit situated in Village of Moreland 11, A Condominium (the "Condominium "), Lower Allen Township, Cumberland County, Pennsylvania, being designated as Unit No. 5544 in the Declaration of the Condominium, dated and recorded December 20, 1989, in Cumberland County Miscellaneous Book 373, Page 1108, and the Declaration Plan of the Condominium dated and recorded December 20, 1989, in Cumberland County Plan gook 59, Page 118, under the provisions of the Uniform "Act ") Together with all right, title and interest of, in and to the Common Elements as more fuuy set forth in the aforesaid Declaration of Condominium and Declaration Plans, as amended from time to time. The Grantees, for and on behalf of the Grantees, and the Grantee's heirs, personal representatives, successors and assigns, by the acceptance of this deed, covenant and agree to pay such charges for the maintenance of, repairs to, replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Executive Board in accordance with the Act; and further, Grantees covenant and agree that the unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as applicable Sections of the Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed. The Grantees, for and on behalf of the Grantees, and the Grantee's heirs, personal representatives, successors and assigns, by acceptance of this deed, acknowledges that this conveyance is subject in every respect to the Declaration, the Declaration Plans, By- Laws and all amendments thereto; and the Grantees further acknowledge that each and every provision of the foregoing is essential to the best interest and for the benefit of all unit owners therein. Grantees and all owners of units in the Condominium covenant and agree, as a covenant running with the land, to abide by each and every provision of said documents. The Grantees, for and on behalf of the Grantees, acknowledges that the Grantees have received, no later that fifteen (15) days prior to this conveyance a full and complete Public Offering Statement for the Condominium and„ therefore, waives any and all rights under Section 34060 of the Act. Exhibit A — Legal Description Eyshibit *Exhibit has been redacted to remove all personally identifiable information or non-public information P � \ Attentions Collection Department MORTGAGE'"' (s6 YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 Milk b91fl TINA M OLEWILER gdfl8 9 111 8257 5544 MORELAND CT 7196 MECHANICSBURG, PA 17055 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: X1988 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA001 A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 800- 822 -5626 3237 Nawmark Dr Miamisburo OH 45342 P.O. Box 1820 Davton OH 45401 -1820 Date: 5/6/2013 Re: Loan No. ®'1988 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 5544 MORELAND CT, MECHANICSBURG, PA 17055, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,099.35 for the months of 21112013 through 511120I3. Late charges and other charges have also accrued to this date in the amount of $140.91. 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 $4,538.31. You may cure this default within THRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,538.31, plus any additional monthly payments 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 PNC Mortgage /Collections Center, Mail Code B6- YM09- 01 -01, 3232 Newmark Drive, Miamisburg, 01145342. 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 (30) 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 attomey'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 Sheriffs 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 foreclosure sale /and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately nine - ten months. 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 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: 1- 800 -523 -8654. 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 should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. 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. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHTTO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY s MORTGAGE, A DIVISION OF NATIONAL CITY Case No. 13 - BANK ---' Plaintiff vs. C.:3 _ 0.1 TINA TINA M. OLEWILER -» Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly .meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully fitted (Signa n Pl tiff) 8/20/2013 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: Borrower name(s): Property Address; City: State : _.._ _ . _ _._ Zip: Is the property for sale? Yes Ej No Lj Listing date: price: $ Realtor Narne: Realtor Phone: Borrower Occupied? Yes No o_� -- Mailing Address (if different): Ci ty: State: - Zip: _ - -- Phone Numbers: Home: O Two e: Cell: Other; Email; ## of people in household: How long? Mailing Address; City: State: Zip; Phone Numbers: Home: Office: Cell: Other: Email: ## of people in household: How long? First Mortgage Leader: Type of Loan: Loan Number: hate You Closed Your Loam: Second Mortgage Lender: Type of Loan: Loan Number. Total Mortgage Payments Amount: $ Included Taxes & lusurance; Date of Last Payrrnen Primary Reason for Default: is the loan in Bankruptcy? Yes 0 No El if Yes, provide names, location of court, case number & attorney: Assets Aniout it owed: Lazne: VaI ae: Other Real Estate: $ Retirement Funds; Jnvestments: Checking; Savings: $ ------ Other: $ — Autormbile #l; Model: Amount owed: Year Automobile #2: Model: Value; °- ` ---� Amount owed: Year: Value: �'°�--° ---- Other trap ortation automobiles boats motore eles : Model Year Amount owed Value Manil� Irics�me Name of Employers; I . 2. 3. Additional Income Description (not wages): 1 monthly amount: 2. ......... . monthly amount. Borrower Pay Days: Co- borrower Pay Days: Monthly .ExpenM (Tease only include expenses you are currently paying) EXPENSE AIifC}l1NT 1 XWN, Mo= a e AMOUNT 2` Molt a e Food Car lea en t s Utilities Auto Insurance Condo/Nei h. l=ees Auto fuel/re airs . Med. not covered Install I oan I'a mcnt Other ro . a meat Child 5u rfi'AEizxt. Cable TV - '/Chi CarelI°uit. S endin Mone Other Ex enses Amount Avaiiable for Monthly Mortgage Payments Based on Jncarne & Expenses: Have you. been working with a Housing Counseling Agency'? Yes 0 No El rf yes, please provide the following informa Counseling Agency: Coudselor: f Phone.(Office): fax: i f En2ai$: Have you made application for Homeowners Emergency Mortgage Assistance (HE1vfAP) assistance? Program Yes [] NO Byes, 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 delinquen Yes] No if yes, please indicate the status of those negotiations; Please provide the follo'Agng information, ifknow, regarding your lender or leader's loan servicing company; Lender's Contact (Na ,phone.: Servicing Company (Name): Contact: Phone: mom TI'4Ye, named , authorize the above to use /refer this information to my lend authorize for the style Purpose of evaluating my financial situation fox possible mo named rtgage options. YWe understand that I,iwe am/are unde no obligation to use the services provided by the above Borrower signature Date Co- Borrower ignature- Date Please Foriv,ard this document along with the following information to lender and lend'er's counsel; Proof of income Y } Past 2 bank statements 'Y{ Proof' of Any expected income for the last 45 days !' Copy of a current utility bill Letter explaining reason for delinquency and an { (hardship lette Y supporting docume Y fisting agreement (if property is currently on the marital ) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff } of eniuto,.r� Jody S Smith ' Chief Deputy . L 13 SEP 27 AM IC): 19 Richard W Stewart CUMBERLAND GO UN} Solicitor PENNSYLVANIA PNC Bank National Association Case Number vs. Tina M. Olewiler 2013-4982 SHERIFF'S RETURN OF SERVICE 09/17/2013 07:29 PM- Deputy Ryan Burgett, 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: Tina M. Olewiler at 5544 Moreland Court, Lower Allen Township, Mechanicsburg, PA 17055. f -- RYAN BURGETT, DEP SHERIFF COST: $50.60 SO ANSWERS, September 20, 2013 RONO R ANDERSON, SHERIFF :cu tv:�u e Snsr!f'.Tc..oseft.b'-c In the Court of Common Pleas of Cumberland County PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive No. 13-4982 Miamisburg,OH 45342 G Plaintiff _ vs. rn TINA M.OLEWILER -1 (Mortgagor(s)and Record Owner(s)) (�l)� 5544 Moreland Court �.- Mechanicsburg,PA 17055 c) =ry Defendant(s) p _ PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against TINA M.OLEWILER by default for want of an Answer. Assess damages as follows: $145,450.68 Debt Interest from 12/1/2013 to Date of Sale per Monthly diem at$673.35 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.23 .1 By: KML LA GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Ay Attorneys for Plaintiff AND NOW .. J \ . t ( d yy Judgment is entered in favor of PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY RGER TO NATIO• L CITY MORTGAGE,A DIVISI t • OF NATIONAL CITY BANK and against TINA M.OLEWILER by default for w. •t of an •••swe . amages asse in the sum of$145,450.68 as per the above certification. / Pro '• 41 3(181 s*' .#1,2 g,�/�q 3-7 �Ahi.P A n./Pe Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg,OH 45342 Plaintiff No. 13-4982 vs. TINA M.OLEWILER (Mortgagors and Record Owner(s)) 5544 Moreland Court Mechanicsburg,PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: "� Deputy I a)im If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 122601FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. ' DATE OF THIS NOTICE: November 21,2013 TO: TINA M.OLEWILER OLEWILER,TINA M. 5544 Moreland Court Mechanicsburg,PA 17055 In the Court of PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY Common Pleas MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF of Cumberland County NATIONAL CITY BANK 3232 Newmark Drive CIVIL ACTION-LAW • Miamisburg,OH 45342 Plaint VS. Action of TINA M.OLEWILER Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 5544 Moreland Court No. 13-4982 Mechanicsburg,PA 17055 Defendant(s) TO: TINA M.OLEWILER 5544 Moreland Court Mechanicsburg,PA 17055 IMPORTANT NOTICE • 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC I Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW G OUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa 1D 311835 215-627-1322 Attorneys for Plaintiff I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK Plaintiff vs. NO. 13-4982 TINA M.OLEWILER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): TINA M. OLEWILER, has a last known residence of 5544 Moreland Court, Mechanicsburg, PA 17055. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date Ly-� 6I By: 4 KML LAW GROUP,P P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P.Jenkins Pa. ID 306588 7..Alyk L. Oflazian Pa. ID 312912 / Attorneys for Plaintiff Department of Defense Manpower Data Results as of:Dec-27-2013 10:03:31 Center SCRA 3.0 ti4 Status Report want to Service/timbers Civil Relief Act Last Name: OLEWILER First Name: TINA Middle Name: M. Active Duty Status As Of: Dec-27-2013 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 individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Da of Active Duty Status Date Active Duty.Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active 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 No NA This response reflects whether the individual or his/her unit 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. yhomt. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 • The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 66RDB755901 E730 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION IN THE COURT OF COMMON PLEAS OF NATIONAL CITY BANK 3232 Newmark Drive of Cumberland County Miamisburg,OH 45342 Plaintiff vs. CIVIL ACTION LAW TINA M.OLEWILER (Mortgagor(s)and Record owner(s)) ACTION OF MORTGAGE FORECLOSURE 5544 Moreland Court Mechanicsburg,PA 17055 Defendant(s) No. 13-4982 ORDER FOR JUDGMENT Please enter Judgment in favor of PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK,and against TINA M.OLEWILER for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of $145,450.68. By: a"—.% KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Andrew F.Gornall Pa. ID 92382 1,7 L Attorneys for Plaintiff Gv I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg,OH 45342 and that the name(s)and last known address(es)of the Defendant(s)is/are TINA M.OLEWILER,5544 Moreland Court Mechanicsburg,PA 17055; By: KML LAW( OUP,P.C. Michael McKeever Pa. ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff 0174 az,;44i �O 3/dg/ • ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $137,536.11 Monthly Interest from 01/01/2013 $7,406.85 through 12/01/2013 Late Charges $175.88 Pro Rata MIP $111.84 Fees $33.00 Appraisal Cost $175.00 Property Inspection $12.00 $145,450.68 By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff 191 y k-- ( fib AND NOW,this a. day of OY' ,201 damages are assessed as above. /a9'l w Pro 13-4982/122601 FC PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. 1X410 be Ql�JAN ;1, Suite 5000-BNY Independence Center 1 701 Market Street rkt ~2 I" () Philadelphia,PA 19106 Et 11-N ti COUNT Attorney for Plaintiff ��NS?IV NO PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK IN THE COURT OF COMMON PLEAS 3232 Newmark Drive Miamisburg,OH 45342 of Cumberland County Plaintiff vs. CIVIL ACTION—LAW TINA M.OLEWILER ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 5544 Moreland Court Mechanicsburg,PA 17055 No. 13-4982 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $145,450.68 Interest from 12/1/2013 to Date of Sale per Monthly diem at$673.35 (Costs to be added) pjj4 sl•• • Xt a so •(0O Cif l 6?•.)S (t " By: KM LAW GROUP,P.C. I S� I� " Michael McKeever Pa.ID 56129 S (�( Jay E.Kivitz Pa.ID 26769 V;1 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 a•aS ou d.. Jill P.Jenkins Pa. ID 306588 'SDI Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff CL4+-1 s y y1 J49'1 X19 q rat P4 O ¢ cn vnua ¢ cip U ¢ O F W C/) < U O i U z O O H 3 � W i U W W (j o F. J� U OE a 'Y p '0 a) o, ¢ E dU '" tu CA 0 at oo a, o M U O z O > O b a s 4� x., • N -" p ¢ pH �° � 3 °' � N CI " L:1'''r)CI F Hz ,T.--7t. 0 - m -8 -� c`i Z OZO Z to 0 CL) O /� ¢ OOa.co U H O H O x zw � y In Z z a U >" zril a" ,l ALL THAT CERTAIN condominium unit situated in Village of Moreland II,A Condominium (the"Condominium"),Lower Allen Township, Cumberland County,Pennsylvania,being designated as Unit No. 5544 in the Declaration of the Condominium, dated and recorded December 20, 1989, in Cumberland County Miscellaneous Book 373,Page 1108,and the Declaration Plan of the Condominium dated and recorded December 20, 1989, in Cumberland County Plan Book 59,Page 118,under the provisions of the Uniform"Act") TOGETHER with all right,title and interest of, in and to the Common Elements and more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans,as amended from time to time. THE GRANTEES, for and on behalf of the Grantees,and the Grantee's heirs,personal representatives, successors and assigns,by the acceptance of this deed,covenant and agree to pay such charges for the maintenance of,repairs to,replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Executive Board in accordance with the Act; and further,Grantees covenant and agree that the unit conveyed by this deed shall be subject to a charge for all amounts so assessed and that, except insofar as applicable Sections of the Act may relieve a subsequent unit owner of liability for prior unpaid assessments, this covenant shall run with and bind the land or unit hereby conveyed. THE GRANTEES, for and on behalf of the Grantees,and the Grantee's heirs,personal representatives,successors and assigns,by the acceptance of this deed,acknowledges that this conveyance is subject in every respect to the Declaration,the Declaration Plans,By-Laws and all amendments thereto; and the Grantees further acknowledge that each and every provision of the foregoing is essential to the best interest and for the benefit of all unit owners therein. Grantees and all owners of units in the Condominium covenant and agree,as a covenant running with the land,to abide by each and every provision of said documents. THE GRANTEES, for and on behalf of the Grantees,acknowledges that the Grantees have received,no later that fifteen(15)days prior to this conveyance a full and complete Public Offering Statement for Condominium and,therefore,waives any and all rights under Section 3406(c)of the Act. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Lower Allen Township BEING PREMISES: 5544 Moreland Court,Mechanicsburg,PA 17055 SOLD as the property of TINA M. OLEWILER, ADULT INDIVIDUAL TAX PARCEL# 13-24-0791-002D-U5544 BEING the same premises which STEVEN E. P. SANTIAGO AND KATHY SANTIAGO, HIS WIFE by deed dated 1/31/2008 and recorded 2/5/2008 in Cumberland County in Deed Book Instrument Number:200803605 granted and conveyed unto TINA M. OLEWILER, ADULT INDIVIDUAL. . KML Law Group,P.C. Suite 5000—BNY Independence Center " E ,—f' ,._ ^ P -� 4th's'°�l,L 701 Market Street w THE«P F;O j HO N O TA R'; Philadelphia,PA 19106 215-627-1322 20111 JAN -2 AM II: 04 Attorney for Plaintiff CUMBERLAND COUNTY PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY PENNSYLVANIA MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF IN THE COURT OF COMMON PLEAS NATIONAL CITY BANK 3232 Newmark Drive Miamisburg,OH 45342 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW TINA M. OLEWILER (Mortgagor(s)and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 5544 Moreland Court Mechanicsburg,PA 17055 Defendant(s) No. 13-4982 AFFIDAVIT PURSUANT TO RULE 3129 PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5544 Moreland Court Mechanicsburg,PA 17055 1.Name and address of Owner(s)or Reputed Owner(s): TINA M. OLEWILER 5544 Moreland Court Mechanicsburg,PA 17055 2.Name and address of Defendant(s)in the judgment: TINA M.OLEWILER 5544 Moreland Court Mechanicsburg,PA 17055 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 z•+vkt-M. fr�a:.. ,,n. ens. _ _ ....'-3.r, '.%-,++P1v 4' '§. :._ .: - t.c--. n. ,.<. s—i.� 13-4982 KML Law Group,P.C. 1. '` ,L)r r ti~ Suite 5000-BNY Independence Center "' 'i i l'R O MONO V, 701 Market Street 2014 JA�� -2 ��} I(: 014 Philadelphia,PA 19106 27-1322 Attorney CUMBERLAND COUNTY Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY IN THE COURT OF COMMON PLEAS MORTGAGE,A DIVISION OF NATIONAL CITY BANK of Cumberland County 3232 Newmark Drive Miamisburg,OH 45342 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE TINA M. OLEWILER Mortgagor(s)and Record Owner(s) 5544 Moreland Court Mechanicsburg,PA 17055 Docket No. 13-4982 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: OLEWILER,TINA M. TINA M. OLEWILER 5544 Moreland Court Mechanicsburg,PA 17055 Your house at 5544 Moreland Court,Mechanicsburg,PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$145,450.68 obtained by PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK 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: PNC BANK NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG,OH 45342 PNC BANK NATIONAL ASSOCIATION c/o Lois M.Vitti,Esquire/Vitti Vitti&Associates,P.C. 215 FOURTH AVENUE PITTSBURGH,PA 15222 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 5544 Moreland Court Mechanicsburg,PA 17055 VILLAGE OF MORELAND II,A CONDOMINIUM 337 Lincoln Street Carlisle,PA 17013 VILLAGE OF MORELAND II,A CONDOMINIUM Sterling Property Management Inc. 1442 Trindle Road Carlisle,PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my 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. DATED: / ° "/ / By: 41 f KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff Myk— L. %07 1 3/a 7 r 13-4982 1. The sale will be cancelled if you pay to PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK,the back payments,late charges,costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may fmd out the price bid price by calling the Sheriff of 717-240-6390. 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 fmd out if this has happened,you may call the Sheriff of 717-240-6390. 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 within thirty(30)days from the date of the Sheriffs Sale. 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 schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-4982 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionAkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 122601FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-4982 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,A DIVISION OF NATIONAL CITY BANK Plaintiff(s) From TINA M.OLEWILER (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: $145,450.68 L.L.: $.50 Interest FROM 12/1/2013 TO DATE OF SALE PER MONTHLY DIEM AT$673.35 Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.35 Other Costs: Plaintiff Paid: Date: 1/2/14 - 2P4e.,11ee David D. Buell,Prothonotary (Seal) C Deputy REQUESTING PARTY: Name: ALYK L.OFLAZIAN,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.312912 KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff PNC BANK, NATIONAL ASSOCIATION, EN SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, OH 45342 F, 122601FC CF: 08/21/2013 SD: 06/04/2014 $145,450.68 vs. TINA M. OLEWILER Mortgagor(s) and Record Owner(s) 5544 Moreland Court Mechanicsburg, PA 17055 Plaintiff Defendant(s) s YL `/A ,-041 THE COURT OF COMMON PLEAS I of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-4982 Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) ( ) ( ) ( ( ) ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, Y: Veronica Cosme Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERCER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK; et seq. Plaintiff (Petitioner) V. TINA M. OLEWILER; et al. Defendant (Respondent) Complaint 0 Summons CASE and/or DOCKET No.: 13-4982 Sheriff's Sale Date: 6/4/2014 AFFIDAVIT OF SERVICE n Other: NOTICE OF SALE 1, RYAN MARKS, certify that i am eighteen years of age or older and that 1 am not a party to the action nor an employee nor relative of a party , and that I served TINA M. OI.EWILER the above process on the 13 day of January, 2014, at 2:45 o'clock, PM; at 5544 MORELANI) COURT MECHANICSBURG, PA 17055 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: 0 By handing a copy to the Defendant(s) Description: Approximate Age 4I-45 Height 5'5 Weight 160 Race WI 1ITE Scx FEMALE Hair BROWN Military Status: No El Yes Branch: Commonwealth/State of et ) SS: County of f�e�wi Before me, the undersigned notary pubtic is day, personally, appeared duly sworn according to law, depos y following: I hereby swear or a rifts Mw-l'f s set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File Number: I 22601FC to me known, who being Subscribed and sworn to be - me this 1'! day of o Sr Case ID #:3856725 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflorbach, Notary Public Washington Township, Berks County My Commission ENplre7 November 18, 2017 Name and Address of Sender ;Ot,dBECK Ili ITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured Affix Stamp Here (If issued as a of mailing, or for additional copies of this bit) Postmark and Date of Receipt 2I �O r '�� : �r�;;� • a ,'"'ifi::.:f 02 ,. 'Q 0004285957 y ` h �' `` • MAILED y•kP 190 rt RR Fe Ar a/ 1M FROM - - PITNEY $ FEB04 ZIP CODE BOWES 03.22° =--' 2014 19106 Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Char e. 9 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 TENANTS/OCCUP 5544 Mcreland Mechanicsburg, Co P NTS rt 17055 2'337 ' -/ N - \�, PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 VILLACi OF MOH Lin••In Street Carlisle, PA 17013 VILLAG OF MOR LAND II, LAND II A (:UNUOIVIINIUM A CONDOMINIUM 3. d t,, •" �' : �•J:, i ,. '` � PNC BANK NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG, OH 45342 Sterling 'roperty M 1442 Tri dle Road Carlisle, PA 17013 nagement Inc. • ' _ s 4. �,, r ""`"' %' PNC BANK NATIONAL ASSOCIATION c/o Lois M. Vitti, EsquireNitti Vitti & Associates, P.C. 215 FOURTH AVENUE PITTSBURGH, PA 15222 5. 6. 7. 8. �''''Total Number of Pieces Total Number of Piece()Received Listed by Sender at Post 0 Postmaste Per (Name of receiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) 122601 FC Cumberland County Sale Date: 06/04/2014 TINA M. OLEWILER Complete by Typewriter, Ink, or Ball Point Pen Name and Address of Sender :ML LAW GROUP, P.C. UITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Y Postmark and Date of Receipt Article Number m Addressee (Nae, Street City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. VILLAGE OF MORELAND II, A CONDOMINIUM c/o Mark Wayne Allshouse, Esquire 4833 Spring Road Shermans Dale, PA 17090-8313 2. LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN RD. NEW CUMBERLAND, PA 17070 ({`•- ,A. `{i 3, LOWER ALLEN TOWNSHIP AUTHORITY iiX•`% • • s. c/o Steven Paul Miner, Esquire 4 sxY• 635 N. 12th Street, Suite 101 �. > . • • • -k' Lemoyne, PA 17043-1225 tr. Jtot.DStq% 4. 0S. 0 €: ‘ V" :I: PIP \ t, s il. ' 4 0�� 5. 'AN,.c,, -.._- A°i-'e� :`fo U?Asp ', �� c-3 /,' 6. >� f� s‘ >��y �o�v 1 ; J! r� V> .TA. ,1 1 F • R-ip° ca z m Wit. 8. Total Number of Pieces Total Number of Pieces Postmaster, Per m of eceiving employee) Listed by Sender 3 Received at Post Office See Privacy Act Statement on Reverse PS Fomt 3877, February 2002 (Page 1 of 2jr Complete by Typewriter, Ink, or Ball Point Pen 122601 FC . Cumberland County Sale Date: 06/04/2014 TINA M. OLEWILER KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, OH 45342 vs. TINA M. OLEWILER Mortgagor(s) and Record Owner(s) 5544 Moreland Court Mechanicsburg, PA 17055 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-4982 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5544 Moreland Court Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): TINA M. OLEWILER 5544 Moreland Court Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: TINA M. OLEWILER 5544 Moreland Court Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 PNC BANK NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG, OH 45342 PNC BANK NATIONAL ASSOCIATION c/o Lois M. Vitti, Esquire/Vitti Vitti & Associates, P.C. 215 FOURTH AVENUE PITTSBURGH, PA 15222 LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN RD. NEW CUMBERLAND, PA 17070 LOWER ALLEN TOWNSHIP AUTHORITY c/o Steven Paul Miner, Esquire 635 N. 12th Street, Suite 101 Lemoyne, PA 17043-1225 VILLAGE OF MORELAND II, A CONDOMINIUM c/o Mark Wayne Allshouse, Esquire 4833 Spring Road Shermans Dale, PA 17090-8313 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 5544 Moreland Court Mechanicsburg, PA 17055 VILLAGE OF MORELAND II, A CONDOMINIUM 337 Lincoln Street Carlisle, PA 17013 VILLAGE OF MORELAND II, A CONDOMINIUM Sterling Property Management Inc. 1442 Trindle Road Carlisle, PA 17013 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. DATED: May 20, 2014 ML Law Group, P.C. BY: Veronica Cosme Legal Assistant Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY !1. PROTHONOTARY ?JI1,SJUH-2 PM 2:52 CUMBERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. Tina M. Olewiler Case Number 2013-4982 SHERIFF'S RETURN OF SERVICE 03/28/2014 03:18 PM - Deputy Dawn Kell, 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 5544 Moreland Court, Lower Allen - Township, Mechanicsburg, PA 17055, Cumberland County. 06/02/2014 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: $1,115.00 June 02, 2014 c1 CountySuae Sneriif, Teleosoft, Inc. SO ANSWERS, RONttR ANDERSON, SHERIFF r LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-4982 Civil Term PNC Bank National Association vs. Tina M. Olewiler Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 5544 More- land Court, Mechanicsburg, PA 17055. SOLD as the property of TINA M. OLEWILER. TAX PARCEL #13 -24 -0791 -002D - U5544. 88 1 f PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. c - Lisa Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this da of Ma 2014 Notary 1 COMMONWEALTH Of PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO.. CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 2029 Technology Pkwy Suite 309 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the patriot*News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 20134982 Civil Term PNC Bank National ' Association Vs Tina M. Olewiler Atty: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 5544 Moreland Court Mechanicsburg, PA 17055 SOLD as the property of TINA M. OLEWILER TAX PARCEL #13 -24 -0791 -002D -U5544 This ad ran on the date(s) shown below: 04/13/14 04/20/14 04127/14 Swor d .ubscribed before me this 462 POI d of May, 2014 A. ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES KML LAW GROUP, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff vs. TINA M. OLEWILER (Mortgagor(s) and Record owner(s)) 5544 Moreland Court Mechanicsburg, PA 17055 TO THE PROTHONOTARY: Defendant(s) FILE -OFFICL THE _ 214 JUL. o�r0 rAt� 7 SMI. I& CUNEHHSAND rLVAICOUNTY IN THE COURT OF COMMON PLEAS of Cumberland County PRAECIPE TO VACATE JUDGMENT Kindly vacate the judgment upon payment of your costs only. By: LA ' GROUP, P. Mi ael McKeever Pa. ID 56129 J . E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, PA ID 313897 Jennifer Lynn Frechie, PA ID 316160 Attorneys for Plaintiff No. 13-4982 eQ -,10�89-H,16 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff vs. TINA M. OLEWILER (Mortgagor(s) and Record owner(s)) 5544 Moreland Court Mechanicsburg, PA 17055 Defendant(s) r rHE PRO ITHONO TA 10 vA IN THE COURT ICOMMON PLEAS OF CUMBERLAND COUNTY No. 13-4982 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: ,AMic . el McKeever P .. ID 56129 Ja . Kivitz Pa. ID 26769 isa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff